New A&P - TSO questions...

Checkout_my_Six said:
Tom would sign it off....;)
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So would Jim. So would half a dozen A&P/IA on my field. You got yourself an anal mechanic who has a pretty high opinion of himself. Run, do not walk away from this guy.

I cannot think of ONE thing that has to be TSOd on a part 91 airplane. See what I said carefully. Several of them (transponders, ADSB, and the like) need to MEET the TSO but not BE TSOd. So they don't get a TSO stamp on the side and depending on the mechanic they get a logbook entry that state this OR if (s)he wants to cover their butts a bit more they can do a 337 and send it in to Ok City. That's their call. Demanding TSO on a part 91 airplane is ridiculous.

As to the person that said ASS has TSO'd engine control cables, would you please point me to a part number for the TSOd control? I'm not finding it.

Thanks,

Jim
 
Tom-D said:
an 8130-3 with a new part?
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Yep. If the vendor also sells outside the US they'll issue a -3 form on all their parts. Even some OEMs have started to issue -3 forms. The -3 form has been "harmonized" with EASA and other CAAs and is an accepted document globally.
 
Tom-D said:
Really? an 8130-3 with a new part?
I get the rest of it, and agree with the though that the records most owners keep don't last as long as the parts.
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Absolutely, I've gotten them from Cessna for thousands of new parts everything from door seal by the foot to horizontal stabilizer actuators. Other OEMs may send a CofC or nothing but a shipping ticket.
Bell206 said:
Yep. If the vendor also sells outside the US they'll issue a -3 form on all their parts. Even some OEMs have started to issue -3 forms. The -3 form has been "harmonized" with EASA and other CAAs and is an accepted document globally.
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Exactly

Could be something as small as a light bulb, or door seal by the foot. Most 135 operators won't accept items like this without them.
 
McFarlane only sends Cofc if requested. I document part number installed and any date codes on them since there are ADs on components that aren't serialized and may be impossible to determine if affected later in service.
 
CC268 said:
I mean the A&P is right isn't he? We need TSO'd equipment in our aircraft.
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You need approved equipment or an authorization to use other stuff.
Your aircraft has part numbers for these controls, and there are after market parts that are PMA approved for the PA-28. if these controls are not PMA'd they are not legal with out a STC or field approval.
I have serious doubts that the FAA would approve a 337 requesting use of cheap non PMA'd engine controls.
Anyway, you should have a maintenance record entry installing these controls, I'd like to know what that entry says.
The person who installed these controls may have done it as a minor modification on a log book entry, and your new guy doesn't believe it is. ( a minor)
 
Bell206 said:
Yep. If the vendor also sells outside the US they'll issue a -3 form on all their parts. Even some OEMs have started to issue -3 forms. The -3 form has been "harmonized" with EASA and other CAAs and is an accepted document globally.
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Yeah OK I just went and looked it up.

https://www.faa.gov/documentlibrary/media/form/faa_form_8130.pdf

I very seldom see one that block 13a is used, Normally I see them returning a used reworked part to service or condemning the part.
And our parts supplier only sends a purchase order
 
Tom-D said:
You need approved equipment or an authorization to use other stuff.
Your aircraft has part numbers for these controls, and there are after market parts that are PMA approved for the PA-28. if these controls are not PMA'd they are not legal with out a STC or field approval.
I have serious doubts that the FAA would approve a 337 requesting use of cheap non PMA'd engine controls.
Anyway, you should have a maintenance record entry installing these controls, I'd like to know what that entry says.
The person who installed these controls may have done it as a minor modification on a log book entry, and your new guy doesn't believe it is. ( a minor)
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Hey, Tom, all the person has to do is to bend the end of the cable to fit the airplane and it is a 21.303(b)(2) owner produced part (reference the letter from the FAA General Counsel). Even if they do a 337 on it, it goes directly to OK City where it is filed by a GS-1 who has no idea what it means. Just scan it and file it. The FAA has no more interest in approving 337s for piddledy little stuff like this. It is your and my @$$ on the line when we sign it and send it in to Ok City.

Jim
 
Maybe you just didn't say - but my big concern here is that he didn't communicate well and didn't bother explaining what he meant. If you go with this guy, you can expect more of the same in the future. He will dictate that you must do things or he won't work with you. He is literally blackmailing you to gain your compliance.

This is not how I want to work with a mechanic. I need things broken down and explained. I need someone to point at the TSO and show me why a particular cable doesn't meet the standard. Keep in mind that I was a QA inspector on a nuclear submarine...I'm totally in favor of using approved parts. I'm just not in favor of someone blowing in, declaring that something isn't right but not explaining why.
 
I don’t have any opinion about the actual topic, but about the mechanic sending text, in my experience most people I have encountered in aviation world prefer text over a phone call.


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He sounds pointedly inflexible and pre-loaded to nit-pick. Sounds like a recipe for overpaying for mx and souring the ownership experience beyond what regulations already do. I won't do business with such an AP. People like him would probably be quick to retort I'm looking for a pencil whipped annual. Nothing could be further from the truth, but this guy just wears that inclination like a neon sign. Like I said, I'd pay him for his time and move on to an AP with a "wider lens" in life.
 
weirdjim said:
Hey, Tom, all the person has to do is to bend the end of the cable to fit the airplane and it is a 21.303(b)(2) owner produced part (reference the letter from the FAA General Counsel). Even if they do a 337 on it, it goes directly to OK City where it is filed by a GS-1 who has no idea what it means. Just scan it and file it. The FAA has no more interest in approving 337s for piddledy little stuff like this. It is your and my @$$ on the line when we sign it and send it in to Ok City.

Jim
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You are a lot more liberal with you signoffs than I am.
Owner produced parts, why would any sane A&P want to get in that liability loop.
When an owner can't buy the proper parts that are PMA'd or OEM equipment. They won't be my customer long.
We as A&Ps take enough liability, in doing our job right, Just don't get the owner produced part for a PA-28 or C-1??
 
hindsight2020 said:
He sounds pointedly inflexible and pre-loaded to nit-pick. Sounds like a recipe for overpaying for mx and souring the ownership experience beyond what regulations already do. I won't do business with such an AP. People like him would probably be quick to retort I'm looking for a pencil whipped annual. Nothing could be further from the truth, but this guy just wears that inclination like a neon sign. Like I said, I'd pay him for his time and move on to an AP with a "wider lens" in life.
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Very very well said. This mirrors my thoughts to a T. Maybe the post of the year haha
 
hindsight2020 said:
He sounds pointedly inflexible and pre-loaded to nit-pick.
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Naw, he's probably saying to himself. " I am too busy now to get involved with these guys, this will scare them off"
 
bflynn said:
Maybe you just didn't say - but my big concern here is that he didn't communicate well and didn't bother explaining what he meant. If you go with this guy, you can expect more of the same in the future. He will dictate that you must do things or he won't work with you. He is literally blackmailing you to gain your compliance.

This is not how I want to work with a mechanic. I need things broken down and explained. I need someone to point at the TSO and show me why a particular cable doesn't meet the standard. Keep in mind that I was a QA inspector on a nuclear submarine...I'm totally in favor of using approved parts. I'm just not in favor of someone blowing in, declaring that something isn't right but not explaining why.
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Another post which mirrors my thoughts to a T.
 
WannFly said:
I don’t have any opinion about the actual topic, but about the mechanic sending text, in my experience most people I have encountered in aviation world prefer text over a phone call.


Sent from my iPhone using Tapatalk
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Interesting...you millennials are out of control :p
 
Not sure that it matters at this point, but I have answered your questions in blue below.

Bell206 said:
First, look in your aircraft records for any entries covering the 3 items you listed. Be thorough and read each entry. Note any pertinent info. I still need to do this, but do not have time tonight. I agree this needs to be done.

Second, read this AC on replacement parts and their approval requirements for background info. Every one seems stuck on "TSO." Remember a TSO is only a production specification and not an installation approval. Plus a TSO is not the only option for replacement parts:
http://www.faa.gov/documentLibrary/media/Advisory_Circular/AC 20-62E.pdf



Just to clarify, by "control" do you mean the airframe cable assembly or something on the engine? Which ever one look for any and all identifying information on the cable assy or whatever. Might even have to get a mirror and look behind the panel. Cable Assembly. The throttle cable assembly is made by ACS Product Co. (http://acsproducts.co/?page_id=90) and is the A-750 model number. The mixture cable assembly is made by ACS Product Co. and is the A-790 model number (http://acsproducts.co/?page_id=99).


Verify P/N of gauge and we'll go from there. That is indeed the gauge that is in the airplane - PN 10-01239


You're getting ahead of the game. What you have may be perfectly legal.....
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When we replaced the engine in our Cessna 210 we requested replacing the throttle with a vernier control. They make flying a glide slope much easier for me. The certified Cessna repair station, which I hold in high regard, refused as there is no vernier throttle control approved for a 210 K model. And the AI is of the opinion that the FAA is keen on throttle control issues. So if anyone has a suggestion I would sure like to hear it too. But I am not real interested in spending a bunch of money to develop a new 337 and blaze new ground.
 
Did you guys see this? I think it is a relatively new FAR - had no idea the FAA was involved in pricing. I guess they can see the practical side of things occasionally.

FAR §43.19 Approval of Non-OEM/TSO/PMA parts on Light Aircraft
"When the producer of any part has priced their part at a which exceeds the internationally recognized standard Parts Price Rating System (PPRS) levels of 'Silly' or 'Stupid', aircraft owners and operators are permitted to find reasonable alternatives to the OEM part including but not limited to non-TSO parts, non-OEM parts, non-PMA parts, owner-produced parts, NAPA (National Aviation Parts Association) parts."
In addition, when the producer of a part has that part priced at a level equal to or exceeding PPRS level of "Extortion" or "Just Plain Gouging", the producer is to provide that part to aircraft owners or operators at whatever price the buyer states, then compensate buyer for their egregiously wrong pricing practices with 5 (five) hours of aviation fuel of their choosing."
 
Let'sgoflying! said:
Did you guys see this? I think it is a relatively new FAR - had no idea the FAA was involved in pricing. I guess they can see the practical side of things occasionally.

FAR §43.19 Approval of Non-OEM/TSO/PMA parts on Light Aircraft
"When the producer of any part has priced their part at a which exceeds the internationally recognized standard Parts Price Rating System (PPRS) levels of 'Silly' or 'Stupid', aircraft owners and operators are permitted to find reasonable alternatives to the OEM part including but not limited to non-TSO parts, non-OEM parts, non-PMA parts, owner-produced parts, NAPA (National Aviation Parts Association) parts."
In addition, when the producer of a part has that part priced at a level equal to or exceeding PPRS level of "Extortion" or "Just Plain Gouging", the producer is to provide that part to aircraft owners or operators at whatever price the buyer states, then compensate buyer for their egregiously wrong pricing practices with 5 (five) hours of aviation fuel of their choosing."
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You are three days late for April Fools Day?
 
Briar Rabbit said:
When we replaced the engine in our Cessna 210 we requested replacing the throttle with a vernier control. They make flying a glide slope much easier for me. The certified Cessna repair station, which I hold in high regard, refused as there is no vernier throttle control approved for a 210 K model. And the AI is of the opinion that the FAA is keen on throttle control issues. So if anyone has a suggestion I would sure like to hear it too. But I am not real interested in spending a bunch of money to develop a new 337 and blaze new ground.
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Why won't they do it on a field approval ?
 
Tom-D said:
Why won't they do it on a field approval ?
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Which would require a 337. The AI at this firm was not willing to take the liability. If FAA would sign off without asking for more info other than McFarlane’s specs it might have been acceptable. But I was told it would probably take more than that:

If the Aircraft Certification Office reviews the data, they may:
  • Determine that the data package is acceptable as is and can be approved as a Field Approval;
  • Support the field approval with engineering review, advocate additional data or testing, assist with the flight test and Airplane Flight Manual supplements;
  • Recommend that the project should be an Aircraft Certification Office managed Supplemental Type Certification project, and should proceed with the Supplemental Type Certification process
Do you think the “data package” would be straight forward - I seriously do not know? I am not keen on an engineering study and extended downtime on the airplane.
 
bnt83 said:
Absolutely, I've gotten them from Cessna for thousands of new parts everything from door seal by the foot to horizontal stabilizer actuators. Other OEMs may send a CofC or nothing but a shipping ticket.


Exactly

Could be something as small as a light bulb, or door seal by the foot. Most 135 operators won't accept items like this without them.
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Almost everything we buy at my shop has an 8130 or Form 1. Sometimes multiple ones, depending on how many hands the part has gone through.
 
From the Q+A section of Aircraft Spruce & Specialty page for the ACS 750 throttle control:

Are these A-750 vernier controls FAA Approved?
No, to install these on a certified aircraft you will need to file a 337 Field Approval. The only ACS controls that are FAA approved are A-790-12 (red knob) and A-800-12 (black knob) and they are only approved for certain Cessna models.

An old style Cherokee with a modern vernier control is a dead give away that it was changed. Now hopefully you can find that it has been certified properly with a 337. Maybe it was done as a minor mod, as was mentioned. Sounds like a bit of a treasure hunt!

I am sure the form, fit and function is acceptable, just the technical aspect is apparently in limbo.
 
Briar Rabbit said:
Do you think the “data package” would be straight forward - I seriously do not know?
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Neither do I, you need to read and follow AC43-210,
It needs to have a cover letter stating you would like to used Cable xxxxxxx in Lew of the OEM part number xxxxxx.
Then fill out a 337 form, and in block 8 on the back explain what you have done.
Send that into your A&P-IA's PMI. see what happens.
if they stamp block 4 as approved .. yer good to install as written in block 8.
they get you A&P-IA to sign it as returned to service. then make 3 copies 1 for you 1 for the IA, 1 for the FAA.
 
If I have learned one thing (and only one thing) from POA over the years, it's that A&P / AIs generally do not agree on what is legal and acceptable for anything major or minor. They just go by what they personally think should be done - and typically they will have some reference in some document or another to support their claim no matter how radically different it is to some other A&P / AI's opinion.

Just find an AI that matches your vision of what is OK vs not and go with that.
 
JAWS said:
From the Q+A section of Aircraft Spruce & Specialty page for the ACS 750 throttle control:

Are these A-750 vernier controls FAA Approved?
No, to install these on a certified aircraft you will need to file a 337 Field Approval. The only ACS controls that are FAA approved are A-790-12 (red knob) and A-800-12 (black knob) and they are only approved for certain Cessna models.

An old style Cherokee with a modern vernier control is a dead give away that it was changed. Now hopefully you can find that it has been certified properly with a 337. Maybe it was done as a minor mod, as was mentioned. Sounds like a bit of a treasure hunt!

I am sure the form, fit and function is acceptable, just the technical aspect is apparently in limbo.
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Yea I’m gonna dig around because I have a hard time believeing that the guy who basically rebuilt this airplane and did such a great job on it would have done something like that without the approval.
 
I’ve never seen a TSO’d throttle, mixture, or prop cable. Mine are PMA approved MacFarlanes, like most planes use when replacing cables. As for EGT and CHT, are either required equipment in your airplane? My orginal Cessna CHT was as basic an instrument as there ever was and had no TSO markings that I ever saw. Because it was required equipment (cowl flaps) my replacement instrument had to be approved as a primary. My Aerospace Logic instruments are STC approved but to my knowledge are not TSOd. My EGT is not required equipment so it does not need to be approved.
 
750's are not approved....but, that's what was field approved in the end.
JAWS said:
From the Q+A section of Aircraft Spruce & Specialty page for the ACS 750 throttle control:

Are these A-750 vernier controls FAA Approved?
No, to install these on a certified aircraft you will need to file a 337 Field Approval. The only ACS controls that are FAA approved are A-790-12 (red knob) and A-800-12 (black knob) and they are only approved for certain Cessna models.

An old style Cherokee with a modern vernier control is a dead give away that it was changed. Now hopefully you can find that it has been certified properly with a 337. Maybe it was done as a minor mod, as was mentioned. Sounds like a bit of a treasure hunt!

I am sure the form, fit and function is acceptable, just the technical aspect is apparently in limbo.
Click to expand...
 
CC268 said:
Not sure that it matters at this point, but I have answered your questions in blue below.
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Once you review your records for the cables will see what you find. No sense wasting time on them now if there is an existing paper trail.

But for FYI, there would be 2 options to install these cables: install as a “replacement part” or as an alteration to the aircraft.

In general, replacement parts can fall under one of the Part 21 part production standards (PC, TSO, PMA, STC, etc) and would be considered “approved” parts. Use of these types of parts is without question except a TSO part still does not guarantee an installation approval like a PMA/STC and might require using an alteration process to install.

To throw the proverbial wrench in the mix, as mentioned above in a post, if the previous owner had purchased these cables from Piper, and Piper decided to use ACS cables for that year, he would have received the ACS cable in a Piper package with probably only a pick ticket. Since there is no FAR requirement to log part traceability….

However, FAA guidance also allows the use of “acceptable” replacement parts on a TC’d aircraft which must pass one of a number of listed methods. Acceptable parts require a determination by the installer that they are qualified for use on the aircraft.

On the other hand, say these cables don’t fit under any of the replacement part definitions. They can still be installed but as an alteration. As with acceptable replacement parts, the installer (not the mfg’r or vendor) determines if the cables fall under a minor or major alteration. If a major, approved data and a 337. If a minor, acceptable data and a simple logbook entry.

That is indeed the gauge that is in the airplane - PN 10-01239
Was the Westach indicator a replacement for an OEM indicator or an addition to the basic panel. Either way it would fall under one of the methods above.
 
CC268 said:
Yea I’m gonna dig around because I have a hard time believeing that the guy who basically rebuilt this airplane and did such a great job on it would have done something like that without the approval.
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If you aren't going to use the nit picker why worry about it? at your next annual, if the inspector gripes it, have them deal withe the 337 field approval.

or stick the old one back in until they are out of sight.
 
the problem with that....your FSDO may disagree and require the field approval....like in my case. :confused:
Bell206 said:
Once you review your records for the cables will see what you find. No sense wasting time on them now if there is an existing paper trail.

But for FYI, there would be 2 options to install these cables: install as a “replacement part” or as an alteration to the aircraft.

In general, replacement parts can fall under one of the Part 21 part production standards (PC, TSO, PMA, STC, etc) and would be considered “approved” parts. Use of these types of parts is without question except a TSO part still does not guarantee an installation approval like a PMA/STC and might require using an alteration process to install.

To throw the proverbial wrench in the mix, as mentioned above in a post, if the previous owner had purchased these cables from Piper, and Piper decided to use ACS cables for that year, he would have received the ACS cable in a Piper package with probably only a pick ticket. Since there is no FAR requirement to log part traceability….

However, FAA guidance also allows the use of “acceptable” replacement parts on a TC’d aircraft which must pass one of a number of listed methods. Acceptable parts require a determination by the installer that they are qualified for use on the aircraft.

On the other hand, say these cables don’t fit under any of the replacement part definitions. They can still be installed but as an alteration. As with acceptable replacement parts, the installer (not the mfg’r or vendor) determines if the cables fall under a minor or major alteration. If a major, approved data and a 337. If a minor, acceptable data and a simple logbook entry.

That is indeed the gauge that is in the airplane - PN 10-01239
Was the Westach indicator a replacement for an OEM indicator or an addition to the basic panel. Either way it would fall under one of the methods above.
Click to expand...
 
Capt. Geoffrey Thorpe said:
If I have learned one thing (and only one thing) from POA over the years, it's that A&P / AIs generally do not agree on what is legal and acceptable for anything major or minor.
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In my travels, I would say 25% of A&P/IAs are set in their ways and would not change their “personal opinions” on how they do maintenance/inspection regardless what the FARs state. And they have that right.

For the other 75%, it’s more how an A&P/IA “interprets” the FARs that drives the varying results between them. It may seem to be the same (opinion/interpretation) but opinions usually lack documented references or go against an established reference. This post is a prime example: one mechanic says TSO cables, period (opinion). Yet there is no FAA requirement for a TSO and 5 different installations options to install the cables legally (interpretation X 5).
 
Bell206 said:
Once you review your records for the cables will see what you find. No sense wasting time on them now if there is an existing paper trail.

But for FYI, there would be 2 options to install these cables: install as a “replacement part” or as an alteration to the aircraft.

In general, replacement parts can fall under one of the Part 21 part production standards (PC, TSO, PMA, STC, etc) and would be considered “approved” parts. Use of these types of parts is without question except a TSO part still does not guarantee an installation approval like a PMA/STC and might require using an alteration process to install.

To throw the proverbial wrench in the mix, as mentioned above in a post, if the previous owner had purchased these cables from Piper, and Piper decided to use ACS cables for that year, he would have received the ACS cable in a Piper package with probably only a pick ticket. Since there is no FAR requirement to log part traceability….

However, FAA guidance also allows the use of “acceptable” replacement parts on a TC’d aircraft which must pass one of a number of listed methods. Acceptable parts require a determination by the installer that they are qualified for use on the aircraft.

On the other hand, say these cables don’t fit under any of the replacement part definitions. They can still be installed but as an alteration. As with acceptable replacement parts, the installer (not the mfg’r or vendor) determines if the cables fall under a minor or major alteration. If a major, approved data and a 337. If a minor, acceptable data and a simple logbook entry.

That is indeed the gauge that is in the airplane - PN 10-01239
Was the Westach indicator a replacement for an OEM indicator or an addition to the basic panel. Either way it would fall under one of the methods above.
Click to expand...

Thanks for the feedback and help. I'm out of town this weekend, but I plan to dig into the records and see if I can find anything.
 
Tom-D said:
If you aren't going to use the nit picker why worry about it? at your next annual, if the inspector gripes it, have them deal withe the 337 field approval.

or stick the old one back in until they are out of sight.
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Yea I don't disagree...more just curious at this point to look at logs/history and see how these were installed and if there is a 337,etc. Good learning experience I guess.
 
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