Blowing of steam.

[Dave Siciliano]

Actually, you may want to read this http://www.faa.gov/avr/afs/300/memo.doc

It sheds an interesting light on the rule. It appears that the sticker is on "for sale", as in selling parts. If a part is produced "for use" as in a one off application, there is much more leeway. The mechanic or any machine shop may produce the part even if there is just a minimal involvement by the owner as spelled out in answered questions by the Assistant Chief Councel.

Very interesting read. Thanks for posting this.

Dave

 

[Henning]

Very interesting read. Thanks for posting this.

Dave

Yeah, if the owner hands the mechanic or anyone a part and says "Copy this" that qualifies. The FAA uses an even broader interpretation than I was taught. As was taught to me if the owner actually construct the part, but they are saying I can ring a bent/cracked part to a shop and say "See this? I need one of these." That would create an owner produced part, as would watching the machining/fabricating, or a post production quality inspection.

Even mechanics in the employ of an aircarrier can manufacture parts for that carriers aircraft.

You just can't manufacture the part and then sell it to somebody else for use on their certified aircraft.

Interesting huhB)

 

[Tom-D]

Actually, you may want to read this http://www.faa.gov/avr/afs/300/memo.doc

It sheds an interesting light on the rule. It appears that the sticker is on "for sale", as in selling parts. If a part is produced "for use" as in a one off application, there is much more leeway. The mechanic or any machine shop may produce the part even if there is just a minimal involvement by the owner as spelled out in answered questions by the Assistant Chief Councel.

You may want to ask Nisley Welding in Lomis Ca, how many millions of bucks they paid by doing this when Cessna sued them for copy rite infringement. when they were manufacturing exhaust parts with out PMA. And how many aircraft the FAA sent urgent letters to saying they were unairworthy due to unauthorized replacement exhaust systems parts.

If the records at Knisley weren't so great, every Cessna and Piper of all models would have gotten an AD. As it was, some 100+ aircraft got new exhausts and Knisley paid 11 mil, if I remember correctly.

The worst the FAA can do to you is suspend your A&P or ground your aircraft, But watch the lawyers, they have a different approach. The liability alone would scare ya.

Remember also, Cessna/Piper produces a product, their product can't be your product. So when you are manufacturing parts for your product, it better not say Cessna/Piper on the type certificate.

A&Ps in the field can repair, they can't manufacture. UNLESS the repair manual for that make and model says they can.

Such AS:

the structural repair manual for Cessna single engine series, says that you can manufacture new skin from stock as per blue print #xxx. Then YES, you can REPAIR a wing by manufacturing a new skin, IAW the repair manual.

That will require a REPAIR to be entered in the logs and a 337 for return to service by an A&P-IA.

Your field approval route for a better than OEM will get FSDO to put you through the STC hoops. bad way to go, See AC 43-210.

 

[Richard]

That does not apply if the part is no longer manufactured or the part is still manufactured but the mfg will not sell the part to you.

The above statement was based on what was told to me by an ex-FAA A&P/IA. I followed up on this today and he said it is found in CFR Part 43. He did allow that perhaps he had misinterpreted the section but he added that he has used parts he manufactured on aircraft as required and hasn't experienced any ill effect from the FAA.

He operates under his A&P as a restorer only. He is particular about which birds he'll work on and he sometimes will become a part owner on the bird before he begins any work, if that makes any difference. He sells his share after all work is completed and signed off. This is not confined to birds in Experimental category.

 

[Tom-D]

The above statement was based on what was told to me by an ex-FAA A&P/IA. I followed up on this today and he said it is found in CFR Part 43. He did allow that perhaps he had misinterpreted the section but he added that he has used parts he manufactured on aircraft as required and hasn't experienced any ill effect from the FAA.

He operates under his A&P as a restorer only. He is particular about which birds he'll work on and he sometimes will become a part owner on the bird before he begins any work, if that makes any difference. He sells his share after all work is completed and signed off. This is not confined to birds in Experimental category.

I'd be willing to wager that he is signing off "repairs" and not stating he is manufacturing.

I made all new wooden parts for my F-24 Fuselage, but that was IAW the AC 43,13-2b and the Fairchild blue prints and will be signed off as a repair. I will not state that I manufactured any thing.

Your friends refference is:
§43.13 Performance rules (general).

(a) Each person performing maintenance, alteration, or preventive maintenance on an aircraft, engine, propeller, or appliance shall use the methods, techniques, and practices prescribed in the current manufacturer's maintenance manual or Instructions for Continued Airworthiness prepared by its manufacturer,

----->or other methods, techniques, and practices acceptable to the Administrator,------

(That's a pre-approval by FSDO)

except as noted in §43.16. He shall use the tools, equipment, and test apparatus necessary to assure completion of the work in accordance with accepted industry practices. If special equipment or test apparatus is recommended by the manufacturer involved, he must use that equipment or apparatus or its equivalent acceptable to the Administrator.

(b) Each person maintaining or altering, or performing preventive maintenance, shall do that work in such a manner and use materials of such a quality, that the condition of the aircraft, airframe, aircraft engine, propeller, or appliance worked on will be at least equal to its original or properly altered condition (with regard to aerodynamic function, structural strength, resistance to vibration and deterioration, and other qualities affecting airworthiness).

 

[Henning]

You may want to ask Nisley Welding in Lomis Ca, how many millions of bucks they paid by doing this when Cessna sued them for copy rite infringement. when they were manufacturing exhaust parts with out PMA. And how many aircraft the FAA sent urgent letters to saying they were unairworthy due to unauthorized replacement exhaust systems parts.

If the records at Knisley weren't so great, every Cessna and Piper of all models would have gotten an AD. As it was, some 100+ aircraft got new exhausts and Knisley paid 11 mil, if I remember correctly.

But you have to see the difference, they were violating the spirit and substance of the rule. The individual aircraft owner has to be involved someway, "but ordering the part is not enough". Basically I have to come in the shop and hand you a part or drawing and say "Make this". Then you can make that owner that part for use in that owners airplane. You CANNOT produce a batch of 100 and have people call in and order them.

The worst the FAA can do to you is suspend your A&P or ground your aircraft, But watch the lawyers, they have a different approach. The liability alone would scare ya.

Remember also, Cessna/Piper produces a product, their product can't be your product. So when you are manufacturing parts for your product, it better not say Cessna/Piper on the type certificate.

A&Ps in the field can repair, they can't manufacture. UNLESS the repair manual for that make and model says they can.

Such AS:

the structural repair manual for Cessna single engine series, says that you can manufacture new skin from stock as per blue print #xxx. Then YES, you can REPAIR a wing by manufacturing a new skin, IAW the repair manual.

That will require a REPAIR to be entered in the logs and a 337 for return to service by an A&P-IA.

Your field approval route for a better than OEM will get FSDO to put you through the STC hoops. bad way to go, See AC 43-210.

Not according to that letter from the Asst Chief Counsel.

What that says is I can take any part from my plane and take it to anyone I deem competent hand it to them and say "Make me a new one of these", or I can make it myself, or I can watch them make it, or I can inspect it after they make it, or I can do the finish work, whatever, so long as I am involved in the design(which was interpreted as being able to bring a part to be copied as sufficient), the supervision of manufacture, or quality control the product manufactured, I am legal to have that part installed on MY aircraft. I an NOT legal to take that part and sell it to you to put on your plane, I don't even think I can give it to you. You have to be involved in your plane. As to the manufacturer suing me for copyright infringement, he can't since I own the plane and rights tranfer with ownership. The whole key is owning the aircraft you are contracting a Specific part for.

What this means to you is any of those parts you want to make for YOUR Warner engine you are free and clear to make for YOUR aircraft.

 

[Richard]

I'd be willing to wager that he is signing off "repairs" and not stating he is manufacturing.

I made all new wooden parts for my F-24 Fuselage, but that was IAW the AC 43,13-2b and the Fairchild blue prints and will be signed off as a repair. I will not state that I manufactured any thing.

Your friends refference is:
§43.13 Performance rules (general).

(a) Each person performing maintenance, alteration, or preventive maintenance on an aircraft, engine, propeller, or appliance shall use the methods, techniques, and practices prescribed in the current manufacturer's maintenance manual or Instructions for Continued Airworthiness prepared by its manufacturer,

----->or other methods, techniques, and practices acceptable to the Administrator,------

(That's a pre-approval by FSDO)

except as noted in §43.16. He shall use the tools, equipment, and test apparatus necessary to assure completion of the work in accordance with accepted industry practices. If special equipment or test apparatus is recommended by the manufacturer involved, he must use that equipment or apparatus or its equivalent acceptable to the Administrator.

(b) Each person maintaining or altering, or performing preventive maintenance, shall do that work in such a manner and use materials of such a quality, that the condition of the aircraft, airframe, aircraft engine, propeller, or appliance worked on will be at least equal to its original or properly altered condition (with regard to aerodynamic function, structural strength, resistance to vibration and deterioration, and other qualities affecting airworthiness).

You're right, he is making repairs. In fact, when I asked him specifically about the wing ribs he replaced with ribs he made his response was that it was a repair. If he so repairs the wing piece by piece and as time goes by he has repaired each piece so that the entire wing has been repaired he still has not replaced nor made a wing. That is my understanding of his comments and the point he was making. In this is seems he and you are in agreement of your undestanding of the process involved.

How this relates to my earlier comment about being able to manufacture the parts if they are otherwise unavailable is this:

1)they better not say Cessna on them. (as you already mentioned)

2)your repairs are in accordance with the design or latest permutation thereof.

EDIT: I'd love to make the wing ribs for you. I have full access to a fully equipped shop including a CNC mill. I'd have to come onboard as a part owner since I could not sell you the parts. After the work is completed and signed off I could sell back my share at the new price. What tax code or FAA reg does that violate?

 

[Dave Siciliano]

Here's what Mike Busch had to say when I sent this link.

Dave


The yes it does below is in reference to me asking if I could fabricate a fix on something like my aircraft baffling.

--------------------------------------------------------------------------------
Yes, it does. However, unless you're an A&P, the owner-produced part does you no good unless you can persuade your A&P that it's okay to install and approve the aircraft for return to service. Thus, it's a very wise idea to get your A&P firmly on board before undertaking the manufacture of an owner-produced part.
If the part is to be used in a minor repair or alteration (via a simple logbook entry), then it's normally sufficient to convince your A&P that the part is identical in form, fit and function to the OEM part it replaces.

If the part is to be used in a major repair or alteration (involving a Form

337 and inspection and approval by an IA), it is typically necessary either to obtain the manufacturer's drawings and specs for the part (which is often impossible) or to hire a DER to approve drawings and specs reverse-engineered from the original part. (How do you know the original part is made of 2024-T3 and not 7075-T6?)

Bottom line is that an owner-produced inspection plate or fairing is usually a piece of cake, while an owner-produced wing spar or ruddervator is tough.

 

[Henning]

Where did you learn that?

Please quote the reference.

Because I would love to manufacture a few engine parts for my Warner or a 440 Ranger.

or better yet, would you manufacture a couple main wing spars for a F-24, you could get $10k each.

You can make your Wagner part, and if an F-24 owner comes in and directs you to make that part, you are good to proceed. You MAY NOT make the spar and then look for someone to sell it to.

 

[Richard]

Here's what Mike Busch had to say when I sent this link.

Dave


The yes it does is in reference to me asking if I could fabricate a fix on something like my aircraft baffling.

--------------------------------------------------------------------------------
Yes, it does. However, unless you're an A&P, the owner-produced part does you no good unless you can persuade your A&P that it's okay to install and approve the aircraft for return to service. Thus, it's a very wise idea to get your A&P firmly on board before undertaking the manufacture of an owner-produced part.
If the part is to be used in a minor repair or alteration (via a simple logbook entry), then it's normally sufficient to convince your A&P that the part is identical in form, fit and function to the OEM part it replaces.

If the part is to be used in a major repair or alteration (involving a Form

337 and inspection and approval by an IA), it is typically necessary either to obtain the manufacturer's drawings and specs for the part (which is often impossible) or to hire a DER to approve drawings and specs reverse-engineered from the original part. (How do you know the original part is made of 2024-T3 and not 7075-T6?)

Bottom line is that an owner-produced inspection plate or fairing is usually a piece of cake, while an owner-produced wing spar or ruddervator is tough.

What I get from that is without the A&P cert you just can't do it--legally speaking.

 

[Tom-D]

You can make your Wagner part, and if an F-24 owner comes in and directs you to make that part, you are good to proceed. You MAY NOT make the spar and then look for someone to sell it to.

How would you document that?

The owner of the Warner type certificate won't give up the blue prints, How would you document the reverse engineering?

Remember we are dealing with the FAA. What are you going to place in block 8 of the 337?

What will the next Annual reveal? 4 years and two owners from now? what are you going to place in the logs?

What will the Prebuy discover? would you buy an aircraft that has "owner manufactured parts"?

It's a real can o worms

And finally, would you bet your livelyhood (A&P-IA ticket) on the word of ""Assistant Chief Counsel for Regulations, AGC-200""??

 

[Tom-D]

Here's what Mike Busch had to say when I sent this link.

Dave


The yes it does is in reference to me asking if I could fabricate a fix on something like my aircraft baffling.

--------------------------------------------------------------------------------
Yes, it does. However, unless you're an A&P, the owner-produced part does you no good unless you can persuade your A&P that it's okay to install and approve the aircraft for return to service. Thus, it's a very wise idea to get your A&P firmly on board before undertaking the manufacture of an owner-produced part.
If the part is to be used in a minor repair or alteration (via a simple logbook entry), then it's normally sufficient to convince your A&P that the part is identical in form, fit and function to the OEM part it replaces.

If the part is to be used in a major repair or alteration (involving a Form

337 and inspection and approval by an IA), it is typically necessary either to obtain the manufacturer's drawings and specs for the part (which is often impossible) or to hire a DER to approve drawings and specs reverse-engineered from the original part. (How do you know the original part is made of 2024-T3 and not 7075-T6?)

Bottom line is that an owner-produced inspection plate or fairing is usually a piece of cake, while an owner-produced wing spar or ruddervator is tough

Mike is dead on as always,

 

[Ed Guthrie]

Quote:
Originally Posted by NC19143
You may want to ask Nisley Welding in Lomis Ca, how many millions of bucks they paid by doing this when Cessna sued them for copy rite infringement. when they were manufacturing exhaust parts with out PMA. And how many aircraft the FAA sent urgent letters to saying they were unairworthy due to unauthorized replacement exhaust systems parts.

If the records at Knisley weren't so great, every Cessna and Piper of all models would have gotten an AD. As it was, some 100+ aircraft got new exhausts and Knisley paid 11 mil, if I remember correctly.

But you have to see the difference, they were violating the spirit and substance of the rule. The individual aircraft owner has to be involved someway, "but ordering the part is not enough". Basically I have to come in the shop and hand you a part or drawing and say "Make this". Then you can make that owner that part for use in that owners airplane. You CANNOT produce a batch of 100 and have people call in and order them.

Henning, your reply ignores an element of Tom's comments that is very valid and is the basis for why your comments about taking a part to a machine shop and telling them, "make one of these" is fraught with peril. Note Tom's statement that Cessna sued for patent/copyright infringement. It would not surprise me that Cessna patents/copyright registers their designs. What most folks don't realize is that there is a world of patent law involving design (form) patents. When you tell the shop "make one of these" you are copying the form/design and you may very well be stepping into a patent/copyright infringement situation. The FAA doesn't enforce those items, the civil courts do.

 

[Henning]

Henning, your reply ignores an element of Tom's comments that is very valid and is the basis for why your comments about taking a part to a machine shop and telling them, "make one of these" is fraught with peril. Note Tom's statement that Cessna sued for patent/copyright infringement. It would not surprise me that Cessna patents/copyright registers their designs. What most folks don't realize is that there is a world of patent law involving design (form) patents. When you tell the shop "make one of these" you are copying the form/design and you may very well be stepping into a patent/copyright infringement situation. The FAA doesn't enforce those items, the civil courts do.

Actually, I didn't ignore it, I answered it in one line. If I own a product, certain rights come with that ownership, like I have the right to copy a part to replace a worn or broken part on the unit I own, I bought those rights with the unit. I do not have the right to produce the part and sell them to other people, that would require a substantive modification to the part, and we know what a can of worms that is (although not insurmountable, there's a **** pot of STCs out there).

 

[Tom-D]

Quote
Henning, your reply ignores an element of Tom's comments that is very valid and is the basis for why your comments about taking a part to a machine shop and telling them, "make one of these" is fraught with peril. Note Tom's statement that Cessna sued for patent/copyright infringement. It would not surprise me that Cessna patents/copyright registers their designs. What most folks don't realize is that there is a world of patent law involving design (form) patents. When you tell the shop "make one of these" you are copying the form/design and you may very well be stepping into a patent/copyright infringement situation. The FAA doesn't enforce those items, the civil courts do.

The whole interpretation is in this statement

§21.303 Replacement and modification parts.

(b) This section does not apply to the following:

(2) Parts produced by an owner or operator for maintaining or altering his own product.

Define "his own product"

 

[Henning]

The whole interpretation is in this statement

§21.303 Replacement and modification parts.

(b) This section does not apply to the following:

(2) Parts produced by an owner or operator for maintaining or altering his own product.

Define "his own product"

I really thought this letter did a very good job of clarifying that.
http://www.faa.gov/avr/afs/300/memo.doc

 

[Keith Lane]

I plan to tell mine to do something they like doing, so long as they won't starve in the the process. Life's too short to go through it hating your job. And there's nothing wrong with changing your mind and trying something new if your first choice doesn't work out like you though it would.

Jeff

Remembr Emmett the fix-it guy on Andy Griffith?
A while back, I decided that's the job I want when I grow up. Heck, it's what I do every weekend and evening anyway, and I am happiest at the workbench fixing whatever comes along from the house, neighborhood or friends and co-workers. Unfortunately, there isn't a way to make a living doing it. Our society has become a throwaway one. Wal-Mart and others have gotten the prices of consumer items so low that it's far cheaper to replace stuff than to fix it. There goes the need for skilled repairmen. There goes too the good paying jobs that come with the need for those skills needed to fix problems rather than throwing parts at them.
</rant>

 

[Ed Guthrie]

Actually, I didn't ignore it, I answered it in one line. If I own a product, certain rights come with that ownership, like I have the right to copy a part to replace a worn or broken part on the unit I own, I bought those rights with the unit.

The reality of copyright/patent rights would depend on what is patented/copyrighted (IOW, the aircraft or the pieces). Take for example the exhaust "duplication" by a shop posted above. If Cessna design patented the exhaust you do not have the right to copy that exhaust. You may have the right to repair the existing exhaust piece, but when you completely discard the existing exhaust and tell the shop "match this" you have stepped into creating an additional part beyond the one you purchased, which, if the part is design patented, is a violation of Cessna's patent rights.

I do not have the right to produce the part and sell them to other people

Under patent law you may not have the right to create a patented part for your own use--there are use patents, too.

that would require a substantive modification to the part, and we know what a can of worms that is (although not insurmountable, there's a **** pot of STCs out there).

You clearly do not understand patents, nor do you appear to properly differentiate between patent law and FARs. If you make a substantive modification to a part you may work yourself free and clear of patent/copyright infringement--that's how patent/copyright law works. IOW, substantive change is an FAR problem, not a patent/copyright problem as you state above.

 

[Missa]

This item http://www.knots2u.com/2430lug.htm is $139 from Knots2U. I am told that the same thing for a Ford product is around $7. So, $7 for the product and $132 for the supporting paperwork. It took me 5 minutes to install it and 5 minutes for my mechanic to inspect it and take care of the paperwork.

Hey and I used to design those! (for the auto industry)

"The Luggage Door Strut kit for the six window Comanche aircraft is a new fix for an old problem! It eliminates the old slide track and in minutes replaces it with a pneumatic strut. The door will never fall on you again! The kit comes complete with everything necessary to install including all hardware, step-by-step instructions, and is fully STC’d"

Don't belive it. In Five years it will be falling on you head agian.

Missa

 

[Carol]

Hey and I used to design those! (for the auto industry)

"The Luggage Door Strut kit for the six window Comanche aircraft is a new fix for an old problem! It eliminates the old slide track and in minutes replaces it with a pneumatic strut. The door will never fall on you again! The kit comes complete with everything necessary to install including all hardware, step-by-step instructions, and is fully STC’d"

Don't belive it. In Five years it will be falling on you head agian.

Missa

For $139 it darn well better NOT!

 

[Missa]

That's not exactly accurate. You will get the gas strut for $7. You will not find those mounts under production anywhere, someone has to make them, and I'll bet at the production scale they are done at, they are made by hand (a skilled hand will be able to make it in under 5 minutes in a proper shop). You could have looked at an existing one and made the same thing yourself and had it installed on a field approval. It would have cost you $30 in materials and about 2 hrs of your time (4.5 if you want it to look really good, lotsa sanding and polishing time) and whatever you have to spend on the tools to make it if you don't have access to them already. Then there is the time you'll pay the mechanic to get the paperwork done.

The lower ball mount on the strut I know can find in current production by Stabilus (#1 gas spring manuf in the world), AVM (#2), Suspa (#3), Cofap and the Korean company I can't spell.. and I would assume all the minor players have it as well.

The upper mount is a little bit different it looks like a clevis, I know Cofap and Stabilus don't have that, but they have blades made to mount to a clevis on a bracket (inverse of the mount shown) in current regular production use.

I can't read the text on the side of the gas spring so I can't identify the manufacture, but I know the Japanese companies do freaky brackets all the time...

BTW, You don't pay $139 for the parts, you pay $139 for the parts and convenience of having this nice modified better performing part, installed, functioning and legal, 10 minutes after you got to the plane with it. BTW,
$139 is not an unfair price for what you get there.

Stabilus charged $25 for 1 up prototype speciality gas springs (3 yrs ago when I worked for them) + brackets... The brackets are fairly simple... I'd say max... $50.

If you think $89 for the paperwork is a good price then it's not unfair... a bit much for me... but I've designed and built these buggers till I was ready to hold my breath until I turned blue....

Missa

 

[Missa]

For $139 it darn well better NOT!

Sorry sweetie... it's a gas spring. It uses gas pressure to push a rod out of the tube. No seal is perfect, over time the gas seeps out and the gas spring losses it's effectiveness slowly. Remember how many 1970's hatchbacks had broom handles in the back of them to hold the hatch up in the 80's? (mine did)Depending on the seal and the pressure the est life is 7-10 years on most of them. I can't read enough of the text on the tube to tell the manufacturer but it didn't look like Stabilus, AVM or Suspa... which is why I gave it 5 years.

Missa

 

[Henning]

If you think $89 for the paperwork is a good price then it's not unfair... a bit much for me... but I've designed and built these buggers till I was ready to hold my breath until I turned blue....

Missa

Like I said, you can manufacture the part reasonably inexpensively, what had I figured $30 and a couple hours. However, if you are not making that part identical to the part you are replacing, you have to provide a good bit of documentation. If you have to pay someone $40 hr to do the paperwork, $89 is a bargain, at least 50% off. It's what is your time, or the persons whose time you're paying, worth. Everything is documentable, Feild Approvals are not Voodoo, it just all takes time, and time is money.

 

[Tom-D]

I really thought this letter did a very good job of clarifying that.
http://www.faa.gov/avr/afs/300/memo.doc

In two lawsuits Cessna and Piper both disagree with the ASSISTANT

but to a second point, study

§65.81 General privileges and limitations.

(a) A certificated mechanic may perform or supervise the maintenance, preventive maintenance or alteration of an aircraft or appliance, or a part thereof, for which he is rated (but excluding major repairs to, and major alterations of, propellers, and any repair to, or alteration of, instruments), and may perform additional duties in accordance with §§65.85, 65.87, and 65.95. However, he may not supervise the maintenance, preventive maintenance, or alteration of, or approve and return to service, any aircraft or appliance, or part thereof, for which he is rated unless he has satisfactorily performed the work concerned at an earlier date. If he has not so performed that work at an earlier date, he may show his ability to do it by performing it to the satisfaction of the Administrator or under the direct supervision of a certificated and appropriately rated mechanic, or a certificated repairman, who has had previous experience in the specific operation concerned.

(b) A certificated mechanic may not exercise the privileges of his certificate and rating unless he understands the current instructions of the manufacturer, and the maintenance manuals, for the specific operation concerned. [Doc. No. 1179, 27 FR 7973, Aug. 10, 1962, as amended by Amdt. 65-2, 29 FR 5451, Apr. 23, 1964; Amdt. 65-26, 45 FR 46737, July 10, 1980]

Please tell me how an A&P can return to service on any parts that does not have the proper 8030-3 tag attached.

or

§65.95 Inspection authorization: Privileges and limitations.

(a) The holder of an inspection authorization may-

(1) Inspect and approve for return to service any aircraft or related part or appliance (except any aircraft maintained in accordance with a continuous airworthiness program under part 121 of this chapter) after a major repair or major alteration to it in accordance with part 43 of this chapter, if the work was done in accordance with technical data approved by the Administrator.

(2) Perform an annual, or perform or supervise a progressive inspection according to §§43.13 and 43.15 of this chapter.


So only after proper paper work APPROVING the documentation on the home made part, can the A&P or A&P-IA approve the return to service, and in my humble opinion hell will be a fun place before that happens.

Here is why.

The FAA will not except engineering that is not acceptable data. Most aircraft manufacturers will not give that information out. manufacturing as per sample is not acceptable data. So handing a machinest a part and telling them to make me one of these is not going to have any acceptable data for the FAA/ A&P/A&P-IA to use as data to return the aircraft to service.

 

[Let'sgoflying!]

Where is Marty with his details on the latest SUPR, I wonder what those documents have to say about such parts.

 

[Henning]

How would you document that?

The owner of the Warner type certificate won't give up the blue prints, How would you document the reverse engineering?

Remember we are dealing with the FAA. What are you going to place in block 8 of the 337?

What will the next Annual reveal? 4 years and two owners from now? what are you going to place in the logs?

What will the Prebuy discover? would you buy an aircraft that has "owner manufactured parts"?

It's a real can o worms

And finally, would you bet your livelyhood (A&P-IA ticket) on the word of ""Assistant Chief Counsel for Regulations, AGC-200""??

As for me, the way I go about it is to ask at the FSDO who to talk to, and I'd meet with him/her with the drawings I had made off the measurements and samples I took from the part I'm replacing and ask what they would like me to do to proceed. I don't know your local Feds, but the ones I have dealt with in SoCal and N.Tx were pretty easy to deal with. If you are doing a major mod to something, you may need to pay an engineer to go over your stuff and put a stamp on it. Depending on who you know and what you are doing, that can cost from a bottle of booze or a case of beer to a couple grand. As for the spar, there are formulas to use that use known standards of strength for materials, and as long as your design falls within the parameters given, your design will pass, same for the engine parts. All depends on what they are worth to you. Granted, dealing with the Feds can be arduous, it's not impossible.

 

[Tom-D]

As for me, the way I go about it is to ask at the FSDO who to talk to, and I'd meet with him/her with the drawings I had made off the measurements and samples I took from the part I'm replacing and ask what they would like me to do to proceed. I don't know your local Feds, but the ones I have dealt with in SoCal and N.Tx were pretty easy to deal with. If you are doing a major mod to something, you may need to pay an engineer to go over your stuff and put a stamp on it. Depending on who you know and what you are doing, that can cost from a bottle of booze or a case of beer to a couple grand. As for the spar, there are formulas to use that use known standards of strength for materials, and as long as your design falls within the parameters given, your design will pass, same for the engine parts. All depends on what they are worth to you. Granted, dealing with the Feds can be arduous, it's not impossible.

Remember we were talking about a 148 dollar part.


Why is it that a $2.00 piece of metal cost $148.00 just because it goes on an airplane?

Dean


The paper work route you suggest could take years. and maybe never gain approval.

Also remember any change, and it is a MODIFICATION, you must prove it is exactly like the OEM part. If you can't do that, you are in the pre-approval 337 mode, or the STC certification paper work mess.

 

[Ed Guthrie]

In two lawsuits Cessna and Piper both disagree with the ASSISTANT

I don't believe Cessna or Piper would have standing to sue on behalf of the FAA. IOW, the suit was not an FAR beef, it was a design patent or copyright beef. Those are issues under which Piper & Cessna would be able to sue.

 

[gismo]

You may want to ask Nisley Welding in Lomis Ca, how many millions of bucks they paid by doing this when Cessna sued them for copy rite infringement.

AFaIK you cannot "copyright" a part. If there was a copyright infringement I think it had to involve copying some document (printed or electronic).

 

[Dean]

Re: Blowing off steam.

Well I got my $148.00 part today, I found one out east from a very nice gentleman. Total price with S&H was $15.00 and that included the spring as well. He said he had shipped two of these to MO this week alone, before this he had not sold one in years.