Airworthiness: You Are Using ATOMATOFLAMES Wrong!
For years, private pilot candidates have been memorizing and reciting the acronyms ATOMATOFLAMES and FLAPS. While these acronyms are a useful way to remember the required equipment from 14 CFR 91.205, they don't provide the information necessary to determine if an aircraft can be flown with inoperative equipment. The FAA recommends a better way. Let's get started.
A Fundamental Question: What Instruments Should Be Working?
Let me ask you a question.
What instruments and equipment should be working on an airplane? If you answered "all of them," you're correct. Every instrument and part installed on an aircraft should be functional. Unfortunately, that's not always true. When you find inoperative equipment, you need to follow a step-by-step process to determine whether or not a flight can still be made.
The Correct Procedure: Following 14 CFR 91.213
The FAA provides step-by-step guidance for how to decide whether or not a flight can be made in 14 CFR 91.213. While it uses roundabout language, 14 CFR 91.213(a) through (d) notes that if you have or need an approved Minimum Equipment List (MEL), you need to make sure you can make the flight under the conditions and limitations defined within the MEL. However, most small aircraft do not have or need an MEL. Here are the steps you need to follow if your aircraft doesn’t have an MEL:
Type Certification Data Sheet (TCDS)
Kinds of Operations Equipment List (KOEL)
14 CFR 91.205, 91.207, and other CFRs
Airworthiness Directives (ADs)
Removal or Deactivation
Proper Documentation
Safety of Flight
Step 1: Does Your Aircraft Have an MEL?
First, determine if your aircraft has an MEL. If it does, ensure you're compliant. If your aircraft doesn't have an MEL, move on to the next step.
Step 2: Type Certification Data Sheet (TCDS)
The second step is to determine whether or not the inoperative component is part of the VFR day equipment required within the type certification. This information can be found by looking in the equipment section of the Type Certification Data Sheet (TCDS) for your aircraft.
Step 3: Equipment List or Kinds of Operations Equipment List (KOEL)
Determine whether or not the equipment is required as part of the aircraft's equipment list or a Kinds of Operation Equipment List (KOEL). The equipment list is often found in Section 6 of the Pilot Operating Handbook (POH), along with the weight and balance information. Not all aircraft have a KOEL, but if yours does, it will be listed in Section 2 of the POH.
Step 4: Required by CFRs
This is where ATOMATOFLAMES or FLAPS comes in. For VFR, day equipment includes altimeter, tachometer, oil pressure gauge, magnetic direction indicator, airspeed indicator, temperature gauge, oil temperature gauge, manifold pressure gauge, fuel gauge, landing gear position indicator, anti-collision lights, magnetic compass, ELT, and safety belts.
Step 5: Airworthiness Directives (ADs)
The search for applicable ADs may take a little longer because it can be difficult to determine all of the ADs that apply to your specific aircraft. It would be best to work with your aviation mechanic to make a list of any equipment that might fall under this category.
Step 6: Removal or Deactivation
Before flying, you will either need to remove or deactivate inoperative equipment, and the cockpit controls and indicators must be placarded as inoperative. If the removal or deactivation required maintenance, appropriate entries must also be made in the maintenance logs.
Step 7: Safety of Flight
The final step is for the pilot or an appropriately certificated mechanic to determine if the flight can be completed safely. This process can be hard to remember, and 91.213 is a little difficult to read. To help, the FAA used to publish a flowchart. However, I’ve added a couple modifications to try and make it even more useful.
Practical Examples: Walking Through the Process
Let's use the flowchart to walk through three examples.
Example 1: Piper Archer III - Magnetic Compass Leak
Scenario: During the pre-flight inspection of a Piper Archer III, you notice all the fluid has leaked out of the magnetic compass.
Step-by-Step Process:
MEL: Our Archer III does not have an MEL.
TCDS: No mention of the magnetic compass in the equipment section.
KOEL: The Archer III POH does not have a KOEL.
Equipment List: Section 6 lists the magnetic compass as item 95, but it's unclear if it’s required.
CFR 91.205: It is required by 14 CFR 91.205(b)(3) – a magnetic direction indicator is required.
Conclusion: We cannot make this flight without first fixing the compass.
Example 2: Cessna 172N - Stall Warning Inoperative
Scenario: During the pre-flight of a 1978 Cessna 172N, the stall warning doesn’t work.
Step-by-Step Process:
MEL: There's no MEL for this aircraft.
TCDS: The stall warning is specifically mentioned as required in the TCDS.
KOEL: No KOEL for the 172N. The equipment list prefixes the pneumatic stall warning with a "−R," indicating it is required.
Conclusion: The stall warning must be fixed prior to flying.
Example 3: Piper Warrior - Landing Light
Scenario: Planned a night cross-country in a Piper Warrior, but the landing light is not working.
Step-by-Step Process:
MEL: The Piper Warrior does not have an MEL.
TCDS: The landing light is not required.
KOEL: The Warrior does not have a KOEL. The equipment list contains the landing light but does not list it as required.
CFR 91.205: Requires a landing light only if the flight is for hire. Since this flight is not for hire, the light is not required.
ADs: No applicable ADs requiring the landing light.
Safety Check: The destination airport has minimal runway lighting and a high overcast is forecasted. The prudent choice would be to delay the flight until the landing light is repaired for safety.
Understanding the Process
Does this process make sense? Can you see why relying only on ATOMATOFLAMES and FLAPS could lead to incorrect go/no-go decisions?
"Every instrument and part installed on an aircraft should be functional. Unfortunately, that's not always true."
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As always, thank you for reading. Fly safely, and I will see you next time.