Owner Produced Parts

AKBill

AKBill

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AKBill
I produced a yoke bushing/bearing for my Sport. I know a few owners who have expressed interest in buying the part I produced. The part is not a major alteration in anyway just a copy of the OEM part.

So the question is can they install this part in their certified aircraft without affecting the planes airworthiness? I installed the part in my Sport yesterday and see no problems with construction or operation.

Yoke 5.JPG

In reading the regulations I see no problem with others using this part. I do not want to jeopardize other owners airworthiness If there is a question of who produced the part. The price of the part I produced is inexpensive compared to OEM or other manufactures.

Comments.
 
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AKBill said:
I produced a yoke bushing/bearing for my Sport. I know a few owners who have expressed interest in buying the part I produced. The part is not a major alteration in anyway just a copy of the OEM part.

So the question is can they install this part in their certified aircraft without affecting the planes airworthiness? I installed the part in my Sport yesterday and see problems with construction or operation.

View attachment 71537

In reading the regulations I see no problem with others using this part. I do not want to jeopardize other owners airworthiness If there is a question of who produced the part. The price of the part I produced is inexpensive compared to OEM or other manufactures.

Comments.
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As the question is written, Legally no. you do not have Parts Manufacturing Authority.
 
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AKBill said:
The price of the part I produced
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This is the key part. If you produce (manufacture) the item to sell, Part 21 approvals come into play. However, if you put that idea in diagram format and sell the diagram... no Part 21. The owner you sell the drawing to came even turn right around and request/help you manufacture it. But he has to initiate the process and mark it accordingly to his aircraft.

However, keep in mind there are specific stipulations you need to follow as noted by Bill B's article. You may also want to have a discussion with your IA as they may have an input or two during your next annual if they spot it. Owner produced parts are underused in the GA side whereas they are used widely in Part 135/121.
 
AKBill said:
In reading the regulations I see no problem with others using this part. I do not want to jeopardize other owners airworthiness If there is a question of who produced the part. The price of the part I produced is inexpensive compared to OEM or other manufactures Comments.
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No, you cannot produce the part and sell it. Yes, you can give the owner the drawing used to produce the part, (s)he can look at it, put his/her name on it, sign it, date it, and ask you how much you would charge to make his/her part in accordance with his/her drawing. Because now it isn't YOUR drawing (you would be so goofy as to put your name on the drawing, would you?) but the owner's drawing. Capiche?

Let's be real. The FAA isn't so stupid as to go against years of enforcing a statute against bogus parts, but the General Counsel gave them a way to keep our supra-aging fleet flying. Follow Bill O'Brien's advice to the letter and you will be OK. Just don''t flaunt it in the face of an FAA weenie.

Jim
 
What I would do to get around the legality of the issue.

sell the raw stock to the customer

1. provide the manufacturer with the design or performance data from which to make the part, or
2. provide the manufacturer with the materials to make the part, or
3. provide the manufacturer with fabrication processes or assembly methods to make the part, or
4. provide the quality control procedures to make the part, or
5. personally supervised the manufacturer of the part.

 
It seems like there are a number of ways to skin this particular cat. You could have them send you the materials (the printing filament) from which to make the part. They could even email the STL file (the design) from which to make the part, and for good measure specify the materials to be used, infill percentage, outer layer thickness and other parameters; they could specify that you make two identical copies and test one to failure (the fabrication process and quality control procedures). They could visit you while the part is being printed.
 
" I installed the part in my Sport yesterday and see problems with construction or operation."

Are you sure this is what you meant? If so then this is all moot :)
 
Or you could simply apply for a PMA
 
JAWS said:
" I installed the part in my Sport yesterday and see problems with construction or operation."

Are you sure this is what you meant? If so then this is all moot :)
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I guess I could have said to see if there were any issues with construction or operation. None problems were found....:rolleyes:
 
AKBill said:
wonder what that would cost?
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Probably enough that your parts become nearly as expensive as OEM. :(

Personally, in this increasingly litigious society I'm not sure I'd want to be producing parts or even drawings for any aircraft, other than my own. Maybe.
 
AKBill said:
wonder what that would cost?
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As the saying goes... "if you have to ask, it's probably too expensive." The initial design approval documents by a DER would probably run around $6K+. Then there would be the production approval docs, the actual process approvals, and so on. But the good thing is once you get your 1st PMA the rest are a piece of cake more or less. Stick to the owner produced. Much easier.
https://www.faa.gov/aircraft/air_cert/design_approvals/pma/
 
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AKBill said:
wonder what that would cost?
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Actually the paper work is free It's done thru the manufacturing side of the FSDO/FAA.

Cost would be a trial and error thing, you never know until you try
 
AKBill said:
I produced a yoke bushing/bearing for my Sport. I know a few owners who have expressed interest in buying the part I produced. The part is not a major alteration in anyway just a copy of the OEM part.

So the question is can they install this part in their certified aircraft without affecting the planes airworthiness? I installed the part in my Sport yesterday and see problems with construction or operation.

View attachment 71537

In reading the regulations I see no problem with others using this part. I do not want to jeopardize other owners airworthiness If there is a question of who produced the part. The price of the part I produced is inexpensive compared to OEM or other manufactures.

Comments.
Click to expand...
Ha, I did the same thing when the Cessna column corrosion issues came to light and we had to pull everything apart for X-ray/ultrasonic inspection.
 
Tom-D said:
Actually the paper work is free It's done thru the manufacturing side of the FSDO/FAA. Cost would be a trial and error thing, you never know until you try
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If you're talking about the FAA application forms, yes those are free. And some of the data review is free also. But every other supporting documents will cost as the FAA does not perform lab work, certain calculations, etc. The last costs I saw on DER signed 8110-3s were $1200 to $1600 per page depending on discipline required. The link above gives all the basic info about PMAs with contact info to ask questions. No sense blowing sunshine around. It is what it is. The last thing you want to do is go into this on a trail and error basis as you don't get refunds.

He'll make more beer money and have a better time selling his drawings and assisting others on the owner produced side than going through the goat roping PMA process.

FYI: PMAs and other design/production approvals are only approved/issued by an ACO. The MIDOs provide field level review and verification if needed. The FSDOs have very little involvement if any unless requested by the MIDO. And if you prefer to have the MIDO handle has much of the data review as possible since its "free" plan on waiting years to get a slot. That is why most need to use DERs or DARs.
 
Bell206 said:
If you're talking about the FAA application forms, yes those are free. And some of the data review is free also. But every other supporting documents will cost as the FAA does not perform lab work, certain calculations, etc. The last costs I saw on DER signed 8110-3s were $1200 to $1600 per page depending on discipline required. The link above gives all the basic info about PMAs with contact info to ask questions. No sense blowing sunshine around. It is what it is. The last thing you want to do is go into this on a trail and error basis as you don't get refunds.

He'll make more beer money and have a better time selling his drawings and assisting others on the owner produced side than going through the goat roping PMA process.

FYI: PMAs and other design/production approvals are only approved/issued by an ACO. The MIDOs provide field level review and verification if needed. The FSDOs have very little involvement if any unless requested by the MIDO. And if you prefer to have the MIDO handle has much of the data review as possible since its "free" plan on waiting years to get a slot. That is why most need to use DERs or DARs.
Click to expand...

I still believe these small parts can be done cheaper than most believe. All DERs are not corporate raiders. All MIDO's are slow.
 
GRG55 said:
Probably enough that your parts become nearly as expensive as OEM. :(

Personally, in this increasingly litigious society I'm not sure I'd want to be producing parts or even drawings for any aircraft, other than my own. Maybe.
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After some thought I've decided not to sell the yoke bearing to the two individuals that asked to purchase it. I know my yoke bearing is a good product and is as good as the OEM part if not better. I was just trying to help fellow owners out...
 
Tom-D said:
Actually the paper work is free It's done thru the manufacturing side of the FSDO/FAA.

Cost would be a trial and error thing, you never know until you try
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wrong.....he likely would not qualify for a PMA.
 
AKBill said:
After some thought I've decided not to sell the yoke bearing to the two individuals that asked to purchase it. I know my yoke bearing is a good product and is as good as the OEM part if not better. I was just trying to help fellow owners out...
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Jim gave you a good method for the owner to "request" an owner produced part.
 
Please remember if it never gets put in the logs, it never happened.
 
AKBill said:
I was just trying to help fellow owners out...
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Bill, please reconsider how you do this, if at all. I have learned "there is such a thing as trying to help too much". Or, no good deed goes unpunished.
The liability; omg. Even if your part is absolutely foolproof and has zero to do with a crashed airplane in the future, will the attorneys for the decedent's family agree? It's horrible, I agree - I'd want to help my flying buddies too...but you could be putting it all on the line.
 
benyflyguy said:
I’m fairly certain he’s joking. Written word sometimes just can convey tone. At least I hope he’s joking.
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I was once told that by my PMI, he was dead serious.
He was at the time trying to prove who did a pop rivet repair on a Mooney nose wheel well.

The owner refused to admit who did the repair and said he just bought the aircraft and didn't know.

I don't know if it ever got resolved or not.
 
benyflyguy said:
I’m fairly certain he’s joking. Written word sometimes just can convey tone. At least I hope he’s joking.
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I hope so too, but he's claimed some odd things in the past and wasn't joking. The little smiley things help convey some degree of tone.
 
Let'sgoflying! said:
Bill, please reconsider how you do this, if at all. I have learned "there is such a thing as trying to help too much". Or, no good deed goes unpunished.
The liability; omg. Even if your part is absolutely foolproof and has zero to do with a crashed airplane in the future, will the attorneys for the decedent's family agree? It's horrible, I agree - I'd want to help my flying buddies too...but you could be putting it all on the line.
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I'm picking up what you are putting down. I do have an OEM yoke bushing to copy. I think what I am going to do is loan the part out to owners who want to copy it. I can advise them on how I made the part. That way all the regulations can be satisfied and I am out of the picture as far as liability goes. I may talk to the local PAIM about a PMA.

I do hold a BSME maybe that will help with a PMA.
 
AKBill said:
I'm picking up what you are putting down. I do have an OEM yoke bushing to copy. I think what I am going to do is loan the part out to owners who want to copy it. I can advise them on how I made the part. That way all the regulations can be satisfied and I am out of the picture as far as liability goes. I may talk to the local PAIM about a PMA.

I do hold a BSME maybe that will help with a PMA.
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The PMA is for your shop, not you. It isn't transferrable if you move next door. You'd be far better off producing an "experimental" part and letting buyers do what they may with it, including spinning tales of how they designed and/or produced it. Or they can simply use it quietly. Don't ask, don't tell. It was good enough for the government, right? Remember, there's nothing to prohibit you from making cool parts, but there are regulations that prohibit you from selling aircraft parts for certificated aircraft.
 
AKBill said:
I'm picking up what you are putting down. I do have an OEM yoke bushing to copy. I think what I am going to do is loan the part out to owners who want to copy it. I can advise them on how I made the part. That way all the regulations can be satisfied and I am out of the picture as far as liability goes. I may talk to the local PAIM about a PMA.

I do hold a BSME maybe that will help with a PMA.
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How many do you plan to make?
 
This sort of discussion on a public website is a really bad idea if you go on to sell a single part to a single owner of a certificated airplane. Intent is already established. Bye bye to deniability.
 
Stewartb said:
This sort of discussion on a public website is a really bad idea if you go on to sell a single part to a single owner of a certificated airplane. Intent is already established. Bye bye to deniability.
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Understood...:( Plane is preheating as we speak, I'm going flying just because..:rolleyes:
 
AKBill said:
That's a good article. Thanks
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It misses a major factor - there is enormous overhead cost associated with "certifying" and tracking the certification of parts. I put certifying in quotes because some of the parts that are in your airplane are literally from the same manufacturing batch that you buy at Lowe's, but they have been measured and/or tested, then certified to become an airplane part. I just did a supply chain project kick off with an aviation parts supplier and saw what goes on under the covers.

If you want to produce parts for friends and the community, then I'd suggest talking with your FSDO about the proper way to provide documentation with your part to show that it conforms to the airplane's TC. If you can do that, then you're in business as an airplane part manufacturer. Do it under a corporation and enjoy the paperwork. Once you figure out what is needed, it's really not that bad. If you charge a lot, you could even make a profit doing it.
 
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