What operations require a 100-hour inspection? (Part 91)

Landis

Landis

Well-Known Member
So, this question was pretty simple. Then I got in to a discussion with some people at work (aerial mapping) and found that there's apparently a lot of operations that don't require the 100-hour inspection as I thought they did. I've always generalized 91.409 as requiring the 100-hour for commercial part 91 operations. Well, after this discussion it turns out that there are a number of operations that I'm told don't *need* the inspection - but it's a good idea in case the feds want to pick a nit.

Apparently not required:
  • Aerial photography not carrying a "passenger" (whether you have a camera operator and a pilot or the pilot is the camera operator)
  • A pipeline patrol aircraft
  • Traffic reporting carrying a reporter (apparently not a "passenger" since they're the reason you're flying - I guess that makes them a "crewmember")
  • FBO providing a rental aircraft (not providing the instructor)
  • Flight school with "associated" flight instructors who are not employees

Please feel free to make that list bigger or completely destroy it. I'd appreciate links to other references saying that my new found understanding is incorrect.

91.409(b) said:
(b) Except as provided in paragraph (c) of this section, no person may operate an aircraft carrying any person (other than a crewmember) for hire, and no person may give flight instruction for hire in an aircraft which that person provides, unless [annual/100-hour]
Click to expand...
 
Landis said:
So, this question was pretty simple. Then I got in to a discussion with some people at work (aerial mapping) and found that there's apparently a lot of operations that don't require the 100-hour inspection as I thought they did. I've always generalized 91.409 as requiring the 100-hour for commercial part 91 operations. Well, after this discussion it turns out that there are a number of operations that I'm told don't *need* the inspection - but it's a good idea in case the feds want to pick a nit.

Apparently not required:
  • Aerial photography not carrying a "passenger" (whether you have a camera operator and a pilot or the pilot is the camera operator)
  • A pipeline patrol aircraft
  • Traffic reporting carrying a reporter (apparently not a "passenger" since they're the reason you're flying - I guess that makes them a "crewmember")
  • FBO providing a rental aircraft (not providing the instructor)
  • Flight school with "associated" flight instructors who are not employees

Please feel free to make that list bigger or completely destroy it. I'd appreciate links to other references saying that my new found understanding is incorrect.
Click to expand...

I will say that with my experience managing airplanes used for instruction, I found that even if it wasn't required, they kind of needed to see a mechanic ever 100hrs anyway.
 
I know I would not feel safe flying an airplane as much as we did (mapping) without a 100 hour, even if it's not required. Our FSDO said it was, but as I read the reg it doesn't seem like it should be. I helped with 7 of them, and only once did we not find anything at all. Most of the time, there was something found that if let go for a good while longer would have turned into a major issue, probably in the air where you can't do anything about it at that time. With the amount of time I spent over mountains in that little (SE)airplane also at night and occasional imc, that could have turned into something terrible.

Also, preventative mx tends to cost significantly less then waiting for it to break.
 
Landis said:
So, this question was pretty simple. Then I got in to a discussion with some people at work (aerial mapping) and found that there's apparently a lot of operations that don't require the 100-hour inspection as I thought they did. I've always generalized 91.409 as requiring the 100-hour for commercial part 91 operations.
Click to expand...
Well, that's your fault for not reading the reg you linked to:

==============================
no person may operate an aircraft carrying any person (other than a crewmember) for hire, and no person may give flight instruction for hire in an aircraft which that person provides
==============================

That doesn't translate to all Part 91 commercial ops. How would one fir solo pipeline patrol or rental aircraft into those requirements?

I'm not too sure about the traffic reporting issue - it would depend how the compensation piece is done and I can see variations making a difference in the applicability of the reg.

I'm also not convinced that "Flight school with 'associated' flight instructors who are not employees" is an exception. I know it's been tried as a way of getting around the 100 hour but doubt that it would pass a closer look. So far, anyway, I haven't seen too many FBOs (or their insurance companies) who will place responsibly for the airplane in the hands of a pilot without even a student certificate rather than int the hands of the CFI.
 
MidlifeFlyer said:
Well, that's your fault for not reading the reg you linked to:
Click to expand...

Um, ouch. That's why I bring it up here so we can discuss and all learn. I couldn't be the only one under that impression.

And on traffic reporting those planes would regularly go through 1500 hours a year. I sure hope they'd be inspected more than annually.
 
MidlifeFlyer said:
Well, that's your fault for not reading the reg you linked to:

==============================
no person may operate an aircraft carrying any person (other than a crewmember) for hire, and no person may give flight instruction for hire in an aircraft which that person provides
==============================

That doesn't translate to all Part 91 commercial ops. How would one fir solo pipeline patrol or rental aircraft into those requirements?

I'm not too sure about the traffic reporting issue - it would depend how the compensation piece is done and I can see variations making a difference in the applicability of the reg.

I'm also not convinced that "Flight school with 'associated' flight instructors who are not employees" is an exception. I know it's been tried as a way of getting around the 100 hour but doubt that it would pass a closer look. So far, anyway, I haven't seen too many FBOs (or their insurance companies) who will place responsibly for the airplane in the hands of a pilot without even a student certificate rather than int the hands of the CFI.
Click to expand...

An FBO renting to someone is considered carrying passengers for hire if the renter has a passenger!
I currently work with a group that has some planes that are used for flight instruction, that are not required to have a 100 hr, as agreed by our fsdo. The instructors are not employees of a "flight school", as they are paid directly for their time, they are not providing the aircraft, as the student pays for the time and the cfi is not an employee of any company. Again as agreed by our fsdo. However, even tho a 100 hr is not required to be done, the owner does em anyway for the same reason someone else stated here, it acutally can help keep maintenance costs lower, and the aircraft in better condition. Especially since these aircraft are flying almost 7 days/week.
 
OP: That sounds really familiar...

z987k said:
I know I would not feel safe flying an airplane as much as we did (mapping) without a 100 hour, even if it's not required. Our FSDO said it was, but as I read the reg it doesn't seem like it should be. I helped with 7 of them, and only once did we not find anything at all. Most of the time, there was something found that if let go for a good while longer would have turned into a major issue, probably in the air where you can't do anything about it at that time. With the amount of time I spent over mountains in that little (SE)airplane also at night and occasional imc, that could have turned into something terrible.

Also, preventative mx tends to cost significantly less then waiting for it to break.
Click to expand...

It should (in the sense of "what is safe," not in the sense of "this is what is legally mandated") be required for mapping and other aerial work ops—but isn't legally. Insurance companies, though, might require it as a condition of coverage, and I sure feel safer having them done.
 
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