Legal Interpretations
Faber 1994
Summary
The Question
After a progressive inspection program is discontinued, from which progressive inspection is the next 100-hour inspection measured under 14 CFR 91.409(d)(4)?
Background
A requester asked how to read the phrase "last complete inspection under the progressive inspection program" in 14 CFR 91.409(d)(4) when a progressive inspection program is discontinued and the next 100-hour inspection comes due.
The FAA’s Interpretation
From the number four progressive inspection, the one completing the yearly cycle. The next 100-hour inspection is due within 100 hours of the time at that inspection. The FAA reasoned that a progressive inspection program substitutes for the 100-hour and annual inspections, and only a completed full cycle assures that all aspects of the aircraft have been inspected in a manner equivalent to those requirements.
- Requester
- Faber
- Issued
- July 18, 1994
- Subject
- General Operating & Flight Rules
Regulations Cited
- 14 CFR 91.4
Page 1
July 18, 1994
Robyn O. Faber
Dear Ms. Faber:
This is in response to your letter requesting an interpretation of 14 CFR 91.4O9 (d)(4). Your question relates to the discontinuation of a progressive inspection program, and the triggering date for measuring when the next 100-hour inspection is due. In particular, you requested interpretation of the language referring to the last complete inspection under the progressive inspection program.
Our review of the relevant section leads to the conclusion that the 100-hour inspection would be due within 100 hours of the techs time at the number four progressive inspection, the one completing the yearly cycle. The progressive inspection program is intended to substitute for the otherwise applicable 100-hour and annual inspection requirements. Only when the full cycle of inspection has been completed is there an assurance that all aspects of the aircraft have been inspected in a manner equivalent to the 100-hour and annual requirements.
Richard D. McCurdy
Attorney
Regulations Referenced
Snapshot retrieved August 6, 2026.