Question - FAR 121.309(d)(4)
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Question - FAR 121.309(d)(4)
Hi Guys,
I am living in outside of US, and our A/C (Airbus) is operated under local authority regulations. Our local authority have quite identical guidance (Advisory Circular) for emergency equipment which may be directly translated from US FAR 121.309. Recently we have some doughtful situation about emergency equipment so, I am wondering if I can give me your consultation about historical back ground for the clarification of FAR 121.309(d)(4).
FAR 121.309(d)(4) said:
(4) When carried in a compartment or container, must be carried in a compartment or container marked as to contents and the compartment or container, or the item itself, must be marked as to date of last inspection.
Our local authority officer suggested if "last inspection dates" are written in label or not, but we did not label or write last inspection date on the box nor bin which store the emer equipments
. As you well know, large A/C is normally maintained by operator's maintenance program based on A/C manufacturer's MPD, and there are taskcards which require to perfoem emergency equipment inspections. So, all the inspection date and results are recoreded in maintenance document. So, we have curious feeling if we really need to label last inspection date on the actual container or compartment door. When I search this, similar (identical) requirements are exist within Part 91 and Part 135. So, I feel actual labeling of last inspection date may be required for only small aircraft which do not have maintenance program.....
If anybody in have any idea for my question, your consultation is highly appreciated.
I am living in outside of US, and our A/C (Airbus) is operated under local authority regulations. Our local authority have quite identical guidance (Advisory Circular) for emergency equipment which may be directly translated from US FAR 121.309. Recently we have some doughtful situation about emergency equipment so, I am wondering if I can give me your consultation about historical back ground for the clarification of FAR 121.309(d)(4).
FAR 121.309(d)(4) said:
(4) When carried in a compartment or container, must be carried in a compartment or container marked as to contents and the compartment or container, or the item itself, must be marked as to date of last inspection.
Our local authority officer suggested if "last inspection dates" are written in label or not, but we did not label or write last inspection date on the box nor bin which store the emer equipments
. As you well know, large A/C is normally maintained by operator's maintenance program based on A/C manufacturer's MPD, and there are taskcards which require to perfoem emergency equipment inspections. So, all the inspection date and results are recoreded in maintenance document. So, we have curious feeling if we really need to label last inspection date on the actual container or compartment door. When I search this, similar (identical) requirements are exist within Part 91 and Part 135. So, I feel actual labeling of last inspection date may be required for only small aircraft which do not have maintenance program..... If anybody in have any idea for my question, your consultation is highly appreciated.
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The problem is with simply doing it on the maintenance task cards, the crew are unable to see that the items are in date and have been checked, hence why they require labelling as well, so it is clearly visible to those checking the emergency equipment it is serviceable and in date.
https://www.law.cornell.edu/cfr/text/14/121.803
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https://www.law.cornell.edu/cfr/text/14/121.803
..
Last edited by NutLoose; 29th Nov 2016 at 16:13.
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If you operate into Europe you may have to consider the requirements of an EASA SAFA Ramp Check, part of the check is verification of the status of the safety equipment, amongst other things.
You may track your safety equipment lives on AMOS or similar, but you will need to demonstrate compliance to the equipment manufacturers maintenance or life requirements.
The SAFA ramp check guide says
Note: ICAO does not require life jackets to have an expiration (or next check) date. Operators may employ various systems to
monitor the condition of the life jackets. A life jacket or flotation device without a date does not necessarily constitute a
finding. However, if the expiry date (or next inspection date) is overdue, consider it as unserviceable.
Note: In the case where spare life jackets have been found to be unserviceable, this should reported as a General Remark (Cat.G)
You may track your safety equipment lives on AMOS or similar, but you will need to demonstrate compliance to the equipment manufacturers maintenance or life requirements.
The SAFA ramp check guide says
Note: ICAO does not require life jackets to have an expiration (or next check) date. Operators may employ various systems to
monitor the condition of the life jackets. A life jacket or flotation device without a date does not necessarily constitute a
finding. However, if the expiry date (or next inspection date) is overdue, consider it as unserviceable.
Note: In the case where spare life jackets have been found to be unserviceable, this should reported as a General Remark (Cat.G)
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Thank you NutLoose and Arthur.
If anybody could do me a favor, could you please attach the photo of examples of expiration date exhibition?
Especially, FAR said the emergency equipment is stored in compartment (e.g.) it should be exhibit outside of the door. I would like to see practices of other operators.... if possible....
If anybody could do me a favor, could you please attach the photo of examples of expiration date exhibition?
Especially, FAR said the emergency equipment is stored in compartment (e.g.) it should be exhibit outside of the door. I would like to see practices of other operators.... if possible....
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I wish photo
If you are living in US and under FAR, could you please send me some photo (example) of the "last inspection date" exhibition??? I sometimes flew with US operator's airpolane, but could not recognize such label outside of the bin where the emergency item is stored?????
