Part 91 jet ops and “open write ups”

[FL350]

I’ve been used to flying in the part 121 world for the last few years so my head is a little out of the part 91 jet/ turbine operations game. I know with piston ops you look at 91.213

I just got type rated in this plane, currently being operated part 91. It currently has a couple issues with flight deck lighting and other items which I would assume are NEF items, we don’t have an NEF. If these are broken, but we have no NEF, is the aircraft technically grounded? Or if they‘re communicated to Mx? I don’t know if they’re in a written up in a logbook at this point.

They aren’t addressed in the MEL, and aren’t required for operating the aircraft. My previous understanding is that any open write up grounds the plane unless there is guidance from the MEL or NEF. Is there any relief?

 

[Stone Cold]

Where's the popcorn??

Boris, stop hogging the popcorn...

 

[FL350]

Where's the popcorn??

Boris, stop hogging the popcorn...

uh oh.. have I started something?

 

[Stone Cold]

uh oh.. have I started something?

Eh, it's just that, depending on the operator, Part 91 can be exactly like the wild west. Some may have a secret discrepancy list for when you go to mx, others may play by the rules as much as possible. It's a lot tougher in a single airplane Part 91 to follow the rules, mx wise.

You didn't do anything wrong, I just see where this discussion is headed eventually.

 

[FL350]

Eh, it's just that, depending on the operator, Part 91 can be exactly like the wild west. Some may have a secret discrepancy list for when you go to mx, others may play by the rules as much as possible. It's a lot tougher in a single airplane Part 91 to follow the rules, mx wise.

You didn't do anything wrong, I just see where this discussion is headed eventually.

Yeah that makes sense. Unfortunately.
Is it correct that any open write up technically grounds the plane? Even if it’s something that should be an NEF for example.

 

[spbrian]

Flight deck lighting would most likely follow along the MEL lines not the NEF. With no D095/D195 authorization and an approved MEL then yes, the aircraft is technically grounded until repaired.

D095 isn't a tough process and highly recommend pushing the necessary people internally to begin the paperwork, even if never used it can bring piece of mind.

 

[FL350]

Flight deck lighting would most likely follow along the MEL lines not the NEF. With no D095/D195 authorization and an approved MEL then yes, the aircraft is technically grounded until repaired.

D095 isn't a tough process and highly recommend pushing the necessary people internally to begin the paperwork, even if never used it can bring piece of mind.

The MEL we have doesn’t cover flight deck lighting, so was just something I was using as an example. I’ll look into D095 and seeing if we can get approval.

thanks

 

[Space Monkey]

I’ve been used to flying in the part 121 world for the last few years so my head is a little out of the part 91 jet/ turbine operations game. I know with piston ops you look at 91.213

I just got type rated in this plane, currently being operated part 91. It currently has a couple issues with flight deck lighting and other items which I would assume are NEF items, we don’t have an NEF. If these are broken, but we have no NEF, is the aircraft technically grounded? Or if they‘re communicated to Mx? I don’t know if they’re in a written up in a logbook at this point.

They aren’t addressed in the MEL, and aren’t required for operating the aircraft. My previous understanding is that any open write up grounds the plane unless there is guidance from the MEL or NEF. Is there any relief?

Write Ups?? In Part 91? Never heard of her.

Oh, Sonny. ... Part 91?
You're in a different country now, speaking a different language.
You're the bad guy in a Western now.
You're Honey Badger now.

 

[spbrian]

Write Ups?? In Part 91? Never heard of her.

Oh, Sonny. ..
You're in a different country now, speaking a different language.
You're the bad guy in a Western now.
You're Honey Badger now.

There have been a lot of times that I have used the MEL outside of normal write up convention.

Its great for a ramp check, also let's say the plane is in maintenance and they are unable to fix something in time for a trip. I have seen shops list items that are broken and not fixed on their paperwork, without a MEL that is easy hot water to step into.

 

[FL350]

@spbrian thats exactly what I’m trying to figure out. How is it great for a ramp check? Sorry can’t tell if that was supposed to be sarcasm.

and very curious what you mean about a shop listing broken items on their paperwork leading to hot water? I’m assuming you mean they make a list of open discrepancies and do nothing about them. As a pilot you may never get a chance to see this either.

Couldn’t the mx shop deactivate and secure certain items rendering them inop and close it out that way?

 

[pwttogfk]

So also about to get out the popcorn but I’m going to make the bold prediction there will be a lot more posts like this from airline pilots trying to remember basic pilot stuff.

91.213. That is all.

 

[FL350]

So also about to get out the popcorn but I’m going to make the bold prediction there will be a lot more posts like this from airline pilots trying to remember basic pilot stuff.

91.213. That is all.

I am familiar with 91.213, that's actually what lead me to asking these questions. Enjoy the popcorn, just trying to get some help and understanding from fellow pilots.

 

[FL350]

I think I have my answer. Thanks for the advice guys. I was hoping there was something I was missing in the regs or an AC. There's no relief beyond having an MEL and NEF. We are in the process for getting an MEL, so just waiting on that.

 

[Space Monkey]

I think I have my answer. Thanks for the advice guys. I was hoping there was something I was missing in the regs or an AC. There's no relief beyond having an MEL and NEF. We are in the process for getting an MEL, so just waiting on that.

Review 91.213. And review the MEL, if any. If you are attempting to utilize an MEL, make sure your MEL applies to your operation and/or your aircraft. Typically, MELs apply to the aircraft THROUGH the CFR part under which the plane is being operated at the time. The first part of the MEL will typically explicate the MEL's applicability/scope.

 

[gotWXdagain]

If your MEL is not yet approved, check 91.213. If your MEL/NEF is approved, that is the only controlling document. You cannot fall back to 91.213 if you don’t like your MEL/NEF.

 

[Fly_Unity]

So also about to get out the popcorn but I’m going to make the bold prediction there will be a lot more posts like this from airline pilots trying to remember basic pilot stuff.

91.213. That is all.

The deferral process in 91.213 without an MEL does not apply to Jet Aircraft even it if is part 91.

 

[FL350]

Thank you all for your explanations. I am very familiar with how an MEL/NEF are you used. And I understand 91.213 doesn’t apply to jet aircraft.

I was really hoping there might be something else simple I was missing, but it appears I am not.

 

[gotWXdagain]

The deferral process in 91.213 without an MEL does not apply to Jet Aircraft even it if is part 91.

Good thing I don’t operate for a part 91 outfit

 

[pwttogfk]

Good thing I don’t operate for a part 91 outfit

Good thing 91.213 covers all these scenarios

Also, if you work for a 91 jet operator too cheap to get a MEL or fly planes with no writeups...you're probably in south Florida.

 

[spbrian]

I had a ramp check where the inspector asked if we had any problems with the aircraft and the very next question after the no was do you have an MEL. Not saying not having an MEL is a deal stopper but it builds confidence.

If you are operating an aircraft that leaves the US and goes into Europe you must have an approved MEL and the D095 does not meet the requirements.