Inspection of the leading edge skin/spar junction was incorporated into pre/post
flight inspections nearly a year ago as a result of Robinson Helicopter Company's
safety notice. Common maintenance practice is to address the skin/spar bond
line any time paint erosion warrants such action. I do not understand the AD?s
requirement to make entries prior to each flight in the maintenance log. How do
these log book entries improve safety? If the pilot detects an unsafe condition, the
aircraft will be taken off line until maintenance can address it.
The AD states ?An owner/operator (pilot) holding at least a private pilot certificate
may perform this visual check and must enter compliance into the aircraft
maintenance records in accordance with 14 CFR 43.11 and 91.417(a)(2)(V).? ?
please explain how this affects renter pilots? It precludes student pilots on a solo
cross country from stopping for fuel; how does this improve safety? Student pilots
require another pilot (rated private or better) to sign the visual inspection log prior
to their solo flights ? how does this stand legally, especially in light of 91.7?
Please consider the many flight schools with potential for 5-8 (or more) entries per
day per aircraft. How does this ?visual pollution? in the aircraft maintenance
records improve safety? I submit the opposite is true ? these ?checks? will distract
from seeing real maintenance trends in the aircraft documentation. This ?paper
trail? doesn?t appear to be intended for safety so much as it is for lawyers &
prosecutors.
Summary, continued incorporation of this bond line inspection during pre/post
flight and the mechanic?s maintenance log book entries after performing rotor blade
service are amply sufficient for flight safety. The burden of a pilot making a log
entry pre-flight is unnecessary and will not add value to this AD?s safety initiative;
therefore, I submit this requirement of the AD be deleted.
Mike Rhodes
This is comment on Rule
Airworthiness Directives; Robinson Helicopter Company Models R22, R22 Alpha, R22 Beta, R22 Mariner, R44 and R44 II Helicopters
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