182T strobe light system

Had a pilot refuse to fly a 182T on mission because one (1) strobe light was inop. I said one light does not make the system inop. He said it does. The "kinds of equipment" list in POH section 2 says the "Strobe light system" is required for any flight.  So my question is, what constitutes the "system". I cannot find anything that clearly defines the system (ie. how many working lights required). Anyone have any experience with this issue?

Well what comes with the "system" when the fbo shop buys a full replacement kit would be a good question to ask too. I bought a strobe system for my car for my firefighting activities, and I received 6 strobe bulbs, wiring, and a controller. One could argue the system as a whole is now inop, or just that part. Point of view.

Strobes are also designed to be "attention getters" and aid in determining the shape of the plane to vfr pilots and atc.

Seems the pilot is keeping safety in mind, but went too far down the bookworm road in stating it. I would have just said I find the plane to be in unsafe condition and will not jeopardize myself or my credentials. That should be the end of discussion.

PIC.....his call.

+1

FAR 91.205 lists the required equipment for both day and night VFR as well as IFR.

For day VFR for example it states:

(11) For small civil airplanes certificated after March 11, 1996, in accordance with part 23 of this chapter, an approved aviation red or aviation white anticollision light system. In the event of failure of any light of the anticollision light system, operation of the aircraft may continue to a location where repairs or replacement can be made.

So basically you need one complete operable system.  If an aircraft has two systems, i.e. red rotating beacon being one system and strobes being another, only one of these systems has to be operable.  So you could have all the strobes out as long as the beacon is operable or vice versa. 

My thought is that the pilot was technically wrong but you can't force an unwilling pilot to fly.  I know... as a maintenance controller for an airline, I have tried.   



 

Had a pilot refuse to fly a 182T on mission because one (1) strobe light was inop. I said one light does not make the system inop. He said it does. The "kinds of equipment" list in POH section 2 says the "Strobe light system" is required for any flight.  So my question is, what constitutes the "system". I cannot find anything that clearly defines the system (ie. how many working lights required). Anyone have any experience with this issue?

If the POH didn't break it down to individual componants, i.e. 3 light assemblies installed, 2 required for flight. Then you need the entire system to be "legal" and the PIC was right.

In the event of failure of any light of the anticollision light system...


I guess the issue is the interpetation of "any" and "system".

If your plane come equipted with just a single anti collision strobe.....then it is a no brainer.
But if plane come equipted with two strobes and a red tail light......then that is the "system".....and if "ANY" of the lights are out...then you can only fly it to get it fixed...i.e. not on a CAP mission.

I can see where two pilots and their maintenance guys could interpet it differently.

So...on the spot is it the PICs call......and if you need clarification then the DO or LG (Ops Officer or Aircraft Manager) would be who you would ask for guidance.

KOEL in the aircraft's POH states strobe system has to be operable; the beacon does not.  Seems like either/or would be OK, but that is not the way the KOEL was written and FAA approved.

Our squadron has a 182T and a thorough group of pilots.  The strobe system (both strobes of course) on this aircraft *is* the anticollision system.  The red beacon is no different than a Christmas tree decoration, as far as the C182T POH is concerned. 

Faulty strobe = no anticollision system = no FAR authorization to fly unless it's a ferry to a repair facility. 

Other nearby squadrons with 182T's have reached the same conclusion when their strobe went out, so it's not an overcautious PIC thing.  It's a FAR thing.

Thanks for all the comments. We eventually came to the same conclusion, one time flight to get fixed.

One of these bulbs is around $300. Add the labor and its around $500. Not cheap!

Cessna, and other manufacturers, used strobes as the anti-collision systems on all aircraft models using the Garmin 1000 or similar systems on new model certifications. If you call Cessna they will inform you that the anti-collision system on Garmin equipped C 182 and C 172 models is the wing tip strobes. The red beacon is not in the anti-collision system and is a "0" in the required equipment list. The strobes are the anti-collision system and are a "1" in the required equipment list for both day and night VFR flight. Since the C182T POH does not say "either wing tip strobe", but does say "STROBE light system", both strobes are required.

FAR Part 91; 91.205(11) states that the anti-collision system (not light or lights) is required for flight. One can argue or speculate over the definition of "system" but a hearing will default to the manufacturer's definition of "system". In the case of the C182 and C172 models with Garmin equipment, Cessna's definition is the wing tip strobes- both of them.

The decision not to fly the aircraft on a mission was a sound one and appears to be based on FAA requirements, not just CAP requirements.

The regulation says ALL anti-collision lights must be on, any time the aircraft is operated. Daytime, nighttime, doesn't matter. All isn't equivocated, and daytime/nighttime aren't mentioned in the regulation any where.

What is mentioned is an allowance for shutting them off if a safety problem is caused by "high-intensity" anti-collision lights. This is the only decision left to the PIC in the FAR.

ON is the requirement. Period.

FAA Chief Counsel's office backed this up with a formal Opinion, by the way:

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2011/Murphy.pdf

Various other techniques are taught by huge numbers of people, including instructors and check airmen, many of whom were taught under different rules at an airline or charter organization. (Part 121 and 135.)

Those organizations must follow their own written and approved operational procedures which have zero legal bearing on Part 91 operations.

Many teach  "strobes on on when taking the runway" and it's common to see that taught.  This is not in compliance with the Part 91 FARs if there's no safety problem caused by operating the strobes on the ground. The Chief Counsel's office agrees.

Minimum equipment lists may or may not trump operational FARs. 

PIC gets to decide two choices:

- Whether there's a safety concern large enough to turn any available anti-collision lighting off.
- Whether they choose to hang their ticket on the equipment list, which is usually trumped legally by the operational FAR requirements.

Choose wisely. Read the above Chief Counsel Opinion/Interpretation carefully.  Wasn't a matter of record until January 11, 2011.

Personally, I will give copies to pilot friends, instructors, and even DPEs if they want you to turn the lights off or operate without them for any reason other than safety.  It will take decades to break bad habits that put licenses in jeopardy.

Even I only truly learned of this legal requirement this year, and am still breaking the habit to reach for the on/off switches. If the aircraft is in motion for the purpose of flight, including taxi, the reg says "all on" unless the PIC determines there's a safety reason to turn them off.

In the earlier part of 10 years that I spent as the president of a flying club, the operations officer and a particular owner of a Citabria 7ECA were at stubborn odds over the legality of the aircraft with it's rotating beacon inoperative. The light socket and bulb had corroded to where the contacts barely existed on either. It required a good slap and it might work until the door was slammed when boarding. Or the opposite.

The aircraft was not equipped with the rotating beacon when it was manufactured and certified.

The owner's stance was that it was added equipment, not on the MEL, and thus not required to work.

The operations officer, with his debits and credits, black and white, no real people skills method of dealing with people was adamant that it wasn't so. It must work.

An entire assembly was in the process of being acquired to outright replace it, but being a Citabria, dope and fabric, they (the owner and A&P's) were after a specific lightweight, lower power option. But it was taking "far too long". They could have removed the thing, and that would have been that. It was listed on a recent weight and balance certificate, but the weight was marked insignificant. Probably because no one could get their head in under it, or a mirror and a light to read the weight off the thing.

As usual, the debates and arguments came to me as an unofficial mediator, and I told the ops officer I would call the FSDO and get an answer/opinion from them. He looked it up down the serial number of that specific aircraft, the airworthiness certificate issuance and the MEL and came to the conclusion that it was not required. (and was fully aware of the argument going on, that there was intending to be one installed, etc. )

Making matters sort of worse was that there was no real log book entry for that thing even being installed, but the paperwork clearly showed it did not come from the factory with it. There were even older photos of the aircraft in the books. It was not there.

The operations officer was hell bent on being right, the owner wanted his opportunity for revenue to continue in the interim, noting that it's clearly on the squawk sheet, the switch is marked INOP, and the PIC could decide to fly it or not.

When I informed the operations officer of my outcome with the FSDO he didn't like it, and started on me about "well, you can get the answer you want with how you ask the question you know, so what did you ask them?" .... "I want to know if this aircraft, which has a rotating beacon installed, but was not originally certified with it, and it's not on the MEL, is legal to operate with the beacon inoperative."

Well.. well.. umm.. you loaded that question. I want this thing grounded. He proceeds to call the FSDO, who really are nice people here, easy to work with, etc. The end result of that was they actually came 30 miles and physically grounded the airplane. I talked to the same person some weeks later and he said "with what you told me, we were fine with it. I was getting sick of listening to him, and hadn't been there in a while so I decided to go for a drive anyway and have a look around." The aircraft was operating in the pattern at the time he arrived, and he said he waited until the pilot was done and walked away, he didn't want to hassle anyone else.

The irony was that the parts showed up the next morning unexpectedly, much earlier than the estimate given by the vendor and it was repaired by Lunch. We were figuring another couple weeks. It had been going on for about that long already.

The Citabria had been a staple item at the airport for many years, had a small but loyal following, and had just recently been mostly re-skinned, new plexiglas, totally re-painted, and the beacon issue surfaced about a week after that and was only intermittent in the beginning, but got worse over time.  Had that portion of the airframe been opened they would have replaced it with a nice efficient strobe light then, as the thing that was installed was a bit heavy, mechanical and loud. Both electrically and physically.

In the end, the airplane left a few months later, the owner just got sick of dealing with it after that and people were left with nothing preferred to fly. "Oh, they'll just fly the 152s .. " .. obviously not a marketing or customer relations specialist.

No, they left instead.