Tom-D
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the main body might say "replaced interior with the same color and materials as the original"
why would you need a burn cert?
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the main body might say "replaced interior with the same color and materials as the original"
why would you need a burn cert?
RotorAndWing
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bnt83
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Interesting stuff on field approvals
http://www.faa.gov/about/office_org...300/media/Major_Repair_Alteration_Job-Aid.pdf
http://www.faa.gov/about/office_org...300/media/Major_Repair_Alteration_Job-Aid.pdf
Tom-D
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How can you prove it's the same material as the original?
By using some thing you do not seem to have.
RotorAndWing
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So you can just look at material and determine it's manufacturer and if the proper treatments were used?
What if an Airworthiness Inspector is looking over the airplane and notices the new interior. He ask to see the signoff and there is no reference to any data for the material.
Will you just tell him you determined the material meets CAR3 3.388 or 14 CFR 23.853 and no documentation is required?
How does that get you around 14 CFR 43.9 (a)(1)?
Tom-D
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So you can just look at material and determine it's manufacturer and if the proper treatments were used?
What if an Airworthiness Inspector is looking over the airplane and notices the new interior. He ask to see the signoff and there is no reference to any data for the material.
Will you just tell him you determined the material meets CAR3 3.388 or 14 CFR 23.853 and no documentation is required?
That statement above was what was actually in my F-24 Logs, the FAA inspectors whet over the books with a fine tooth comb, and were OK with it.
there are many materials that have been tested so many times we already know the results.
when you have the experience you will know what you are working on and what the original interior materials were..
bnt83
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So you can just look at material and determine it's manufacturer and if the proper treatments were used?
What if an Airworthiness Inspector is looking over the airplane and notices the new interior. He ask to see the signoff and there is no reference to any data for the material.
Will you just tell him you determined the material meets CAR3 3.388 or 14 CFR 23.853 and no documentation is required?
In the case of a kit from a vendor such as Airtex, just say "replaced existing interior upholstery pieces using Aitex interior kit #xxxx. Weight and Balance record has been updated (or change was negligible). Signed Joe Bloe 123456
For the stuff purchased at the auto shop for a CAR 3 airplane, get a copy of the certificate of conformance that should list the DOT burn cert and reference that in the log entry, such as:
Replaced existing carpet with SOOPER DOOPER carpet part # XXX. Reference Certificate of Conformance (or?) dated 06/06/06 for DOT burn approval. Weight and Balance record has been updated (or change was negligible) Signed Joe Bloe 123456
Now when we get into Part 23, Part 25, Part 135 stuff etc then buildups including any adhesives, paints, or varnishes, even the direction of the weave can affect the results of vertical burn tests and fireblocking, so they fabricate burn coupons and send to a place like Flame-Out, a DER who can burn and approve the materials used. Now back in the good old days the burn coupon had to MATCH the panel being recovered, meaning they CUT OUT a chunk of the sidewall, reupholstered it and burn it. Then the part had to be repaired and the materials used to repair it also had to be burned. Its Madness.
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RotorAndWing
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Airtex supplies the burn certification upon request.
My point is there is data to be had, whether a shop does it or you use automotive grade material.
RotorAndWing
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Sure Tom.
So to satisfy 14 CFR 43.9(a)(1) you can just write down "I have the experience to look at this fabric and certify it meets the requirement of CAR3 3.388 (or 14 CFR 23.853)"
Really??
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Tom-D
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Where does it say we can't do our own test IAW Rotor's link. ?
RotorAndWing
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Tom-D
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So to satisfy 14 CFR 43.9(a)(1) you can just write down "I have the experience to look at this fabric and certify it meets the requirement of CAR3 3.388 (or 14 CFR 23.853)"
Really??
when the factory uses a pure wool and leather interior, isn't the test already completed?
And why can't we do our own tests as per your link and determine the quality of the materials.
secondly, what burn certs would you use on a late model 172?
there is no requirement for any burn cert.
Tom-D
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Of course you can do your own test.
But you've been claiming it's not required.
It's not.
RotorAndWing
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Depends.
You can, but you keep claiming it's not required.
The data from the fabric manufacturer.
You can't comprehend the regulations.
RotorAndWing
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So why would you do your own test?
Tom-D
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I wouldn't.
OBTW, a late 172 has a plastic interior.
what are the burn certs for after market plastic interiors.
Can you show us how many interiors you have replaced. Or how you can tell wool from wool, or leather from leather.
One must have a little experience.
bnt83
Final Approach
I wouldn't.
OBTW, a late 172 has a plastic interior.
what are the burn certs for after market plastic interiors.
Can you show us how many interiors you have replaced. Or how you can tell wool from wool, or leather from leather.
One must have a little experience.
Don't need burn certs for PMA'ed aftermarket plastic interior parts. That's covered under the PMA.
RotorAndWing
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OK, I wasn't aware the seats in the late model 172 were covered in plastic.
Read the regulations, either CAR3 or 14 CFR Part 23.
Just over a dozen in various airplanes and helicopters.
One is wool and the other is leather.
Tom-D
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Maybe, but you say we can do our own tests, where would the certification come from?
if a test facility certifies the material meets the aviation requirements. they issue the certificate.
If I do my own test, and then sign off the installation didn't the same thing happen with out any other paper work?
that is exactly what happened under 43.9/ and 43.13
Tom-D
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Yep and they don't have burn certs. or data from the manufacturer.
RotorAndWing
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"I have tested fabric xxxx using the methods described under Appendix F of 14 CFR Part 23 and I certify that it meets the requirement within."
Or even easier just ask for the manufactures data and reference that.
As long as you reference you did the test in the signoff.
Tom-D
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see even you can tell, all you need is a sample to know what the material is. and after many many manufacturers have used them for years and years you can pretty much tell it will meet the requirements.
and I wouldn't bother the owner with a burn cert chase.
Tom-D
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"I have tested fabric xxxx using the methods described under Appendix F of 14 CFR Part 23 and I certify that it meets the requirement within."
Or even easier just ask for the manufactures data and reference that.
The requirements are the same in the automotive industry. Car manufacturers long ago realized it was bad having customers burn to death in their product.
As long as you reference you did the test in the signoff.
still, show me in the 43 rules for return to service that is a requirement.
43.9
(4) If the work performed on the aircraft, airframe, aircraft engine, propeller, appliance, or component part has been performed satisfactorily, the signature, certificate number, and kind of certificate held by the person approving the work. The signature constitutes the approval for return to service only for the work performed.
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RotorAndWing
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43.9 Content, form, and disposition of maintenance, preventive maintenance, rebuilding, and alteration records (except inspections performed in accordance with part 91, part 125, § 135.411(a)(1), and § 135.419 of this chapter).
(a) Maintenance record entries. Except as provided in paragraphs (b) and (c) of this section, each person who maintains, performs preventive maintenance, rebuilds, or alters an aircraft, airframe, aircraft engine, propeller, appliance, or component part shall make an entry in the maintenance record of that equipment containing the following information:
(1) A description (or reference to data acceptable to the Administrator) of work performed.
You have to use the whole regulation, not just the part you cherry picked.
And yet Airtex sends the burn cert along with the material so there's no questions or problems.
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bnt83
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Maybe there should be a dedicated Alteration/Repair thread...
dell30rb
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How many A&P's does it take to screw in a light bulb?
Skylane81E
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Tom-D
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There is nothing in that statement that requires me to use a burn certificate to do that.
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Time for a refresh... Glad we finally got to the jokes!
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tmyers
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Maybe I should just duct tape a mag light to my head. It has a focused beam for flood and spot beams and will illuminate where I look.
Skylane81E
Final Approach
Go to the next bill goodman's purchase the biggest o lite you can afford
Thank me later
Tom-D
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This page is noted for the thread creep. very few threads go past 10 posts before they get morphed into a different subject.
bnt83
Final Approach
Actually they do advertise as "DROP IN REPLACEMENTS"
So again, how is this a major alteration? I'm not buying the whole "because an STC exists they are all major alterations"...
Negligable weight difference with a decrease in electrical load and in the Cessna 205 or 172 etc example, there is NO MOIFICATIONS to the light frames required. And yet Alaska Float LLC has an STC to install them on 45+ pages of aircraft. Do you seriously think they evaluated each and every install physically or just did some catch all show compliance using the TCDS of said aircraft?
http://www.whelen.com/pb/Aviation/Product Sheets/Parmetheus_Series.pdf
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Skylane81E
Final Approach
For the same reason the fresh pick is, it is spelled out in FAR.
The FAA has taken a very strict stance on what the term "basic design" means. They consider the guts of the lamp part of the electrical system and have decided that an incandescent bulb and a bank of multiple diodes are not basically of the same design.
Were I king it would be a minor alteration that could be installed by any airframe mechanic, but I'm not king. While I may not like it, and don't feel that in this case requiring an STC is in the best interests of safety, legally they aren't wrong to do so.
Come up with a petition to reclassify PMAed LED lights as a minor alteration (the same way they just dropped GPS updates from the list of preventative maintenance items) and you will have my signature.
For now though we have to play by the rules in place.
bnt83
Final Approach
No its not. The Fresh Prick increases the type certificated gross weight of the aircraft which could affect most of the certification basis of the airplane, which is obviously a major alteration.
Skylane81E
Final Approach
Changes to the basic design of the electrical system are spelled out as major as well,
Just because it "should" be a minor alteration (or even just PM) doesn't mean it is.
Just because it "should" be a minor alteration (or even just PM) doesn't mean it is.
Skylane81E
Final Approach
Save you some time,
14CFR43 maintenance
appendix A major alterations, major repairs and preventative maintenance
(a) major alterations
(1) airframe major alterations
(xii) Changes to the basic design of the fuel, oil, cooling, heating, cabin pressurization, electrical, hydraulic, de-icing, or exhaust systems.
14CFR43 maintenance
appendix A major alterations, major repairs and preventative maintenance
(a) major alterations
(1) airframe major alterations
(xii) Changes to the basic design of the fuel, oil, cooling, heating, cabin pressurization, electrical, hydraulic, de-icing, or exhaust systems.