owner produced parts

Tom-D

Tom-D

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Tom-D
and the sale of them..

can I as an owner, produce a part for my aircraft, and approve it under 21.9?


and then remove it and sell it as a "as removed" part?

If you buy used parts, How do you know who made them?
 
You can commission someone to make a part for you, so this seems OK, but I am no expert. You would probably need to disclose it.
 
It is possible, with liabilities of course, to make your own, but not to sell. Seems like a dark grey area selling after install... I wouldn't


Here is a pretty good article I found informative with a case study also.
http://mobile.aviationpros.com/article/10387511/owner-produced-parts-how-they-affect-maintenance

Tom-D said:
and the sale of them..

can I as an owner, produce a part for my aircraft, and approve it under 21.9?


and then remove it and sell it as a "as removed" part?

If you buy used parts, How do you know who made them?
Click to expand...




-VanDy
 
What is your answer Tom? I'm very interested to hear it


-VanDy
 
VanDy said:
What is your answer Tom? I'm very interested to hear it-VanDy
Click to expand...

If I had the answers I'd not be asking.

I know I can build parts for my aircraft, But If I part the 24 out, can I legally sell the parts I built?
 
kgruber said:
No...Can only be used on the owners aircraft. Cannot be sold.

There are numerous sites, but here is one.

http://150cessna.tripod.com/parts.html
Click to expand...

IMO, the article you cite is ambiguous regarding whether an owner manufactured part could be sold. My read is that owners can't "produce" parts for others. However, the article doesn't seem to address the issue of selling "used" owner produced parts . EG owner produced parts which came from an aircraft which is being parted out.
 
kgruber said:
No...Can only be used on the owners aircraft. Cannot be sold.

There are numerous sites, but here is one.

http://150cessna.tripod.com/parts.html
Click to expand...

Site your reference ?

If you supervised a part being built such as a fuselage panel, then I buy the fuselage from a salvage yard, do i have to remove that panel?

don't think so, but I see no reference to back it up.
 
If it wasn't Kelly, who cares?

Tom-D said:
and the sale of them..

can I as an owner, produce a part for my aircraft, and approve it under 21.9?


and then remove it and sell it as a "as removed" part?

If you buy used parts, How do you know who made them?
Click to expand...
 
Tom-D said:
Site your reference ?

If you supervised a part being built such as a fuselage panel, then I buy the fuselage from a salvage yard, do i have to remove that panel?

don't think so, but I see no reference to back it up.
Click to expand...


In FAAlaska, no problem (at least in the old days.):yes:

WA.DC.FAA fuhgeddaboudit:nono:
 
It's my opinion that owner produced parts cannot be sold individually after use, as airworthy parts.

The FAA gets much of it's authority from the "elastic" interstate commerce clause. As such, you will probably notice that the FAA heavily regulates many commerce activities, yet is oddly relaxed with general, part 91 operations.

So, the owner produced part is OK in the aircraft, and is even OK when the aircraft is sold. But, it does not meet the commerce criteria of PMA or TSO and therefore cannot be sold as an airworthy part.
 
I could buy an antenna ,which is an airworthy part, it just happens to be attached to the owner produced fuselage panel.
Seems I remember that computer geeks selling Microsoftware had to sell me a hard drive for a dollar just to transfer the operating system.
?
 
Sleepingsquirrel said:
I could buy an antenna ,which is an airworthy part, it just happens to be attached to the owner produced fuselage panel.
Seems I remember that computer geeks selling Microsoftware had to sell me a hard drive for a dollar just to transfer the operating system.
?
Click to expand...

the problem isn't the sell, it's the installation on another plane and the airworthiness of it afterwards. IMHO it's a gray area and should remain there. Nobody needs to buy an old Cherokee and start building, replacing then selling "used" nose bowls for it, though every owner of a cherokee wants one. We would just get new regulation and it would have (un?)intended side effects.
 
bartmc said:
the problem isn't the sell, it's the installation on another plane and the airworthiness of it afterwards. IMHO it's a gray area and should remain there. Nobody needs to buy an old Cherokee and start building, replacing then selling "used" nose bowls for it, though every owner of a cherokee wants one. We would just get new regulation and it would have (un?)intended side effects.
Click to expand...

I agree with your assessment. I believe the ability to "owner produce "parts is to allow older aircraft to continue to fly safely, under the stewardship of the owner. No one needs to jeopardize this for commerce.
The sale of the occasional owner produced part is most likely treated as such . Just don't try to defeat the existing process,

"approved" aircraft parts, other than hardware, are parts that are approved by TSO, PMA, a type certificate, or a production certificate. To receive a TSO or PMA approval for a part, the manufacturer of the part must demonstrate to the FAA that the part will operate as intended in an aircraft environment and will be manufactured to FAA standards. The FAA regulations state it is the responsibility of the person installing the parts on an aircraft to insure the parts meet appropriate airworthiness standards."

"The FAA's one-time field approval procedure has been in place for decades, and has provided a proven method of enabling aircraft owners to improve the safety and utility of their aircraft at affordable cost. Because each installation must be individually approved by an FAA Airworthiness Inspector, and because the Airworthiness Inspector's Handbook provides detailed guidelines to ensure that the necessary testing and documentation be provided to ensure that the installation is safe, the procedure has been well accepted by both the FAA and the aviation community."
 
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When you review the procedure to return to service on any owner produced part, you will find it must be equal to the OEM parts made from the same material, and manufacturing process that the manufacturer used.

Look it up. the AC is 43-18..

Knowing that, How would you as a buyer from a salvage yard, know who made it?

And remember, properly made and returned to service owner produced parts are not a modification, and do not require a 337 field approval. simply because of the requirements of AC 43,18.
 
Sorry, what type of airplane is that?
If this is a home made airplane, you need a "repairman certificate" so you can approve/return to service the parts.
Just take a look at Part 65

As far as other types of airplanes, the part must be TSO'd or PMA.
 
WarriorPilot said:
As far as other types of airplanes, the part must be TSO'd or PMA.
Click to expand...

Not true.

Which do you have when you buy a used part from an aircraft salvage yard?


PMA ? TSO'd ?

Can I manufacture a Cessna Skin that has a part number?
 
Tom-D said:
Not true.

Can I manufacture a Cessna Skin that has a part number?
Click to expand...

You can duplicate the part with a part number but you alone cannot duplicate the bureaucracy behind the part number!:D
 
WarriorPilot said:
If this is a home made airplane, you need a "repairman certificate" so you can approve/return to service the parts.
Just take a look at Part 65
Click to expand...
Nonsense. Anybody can work on a homebuilt. The repairman certificate only confers the ability to do the annual condition inspection.
As far as other types of airplanes, the part must be TSO'd or PMA.
Click to expand...
There are two requirements for an aircraft part:

1. Authority to manufacture.
2. Authority to install on a particular aircraft.

TSO and PMA are not necessarily required nor sufficient to accomplish both.
 
flyingron said:
There are two requirements for an aircraft part:

1. Authority to manufacture.
2. Authority to install on a particular aircraft.
Click to expand...

1. Where do you gain the authority to manufacture parts, and when do you need it?

2. where do you gain authority to install these parts?

Show your reference
 
Tom-D said:
Not true.

Which do you have when you buy a used part from an aircraft salvage yard?


PMA ? TSO'd ?

Can I manufacture a Cessna Skin that has a part number?
Click to expand...

An A&P mechanic can manufacture the skin as long as he has the current Manual and tools, and file a Form 337, which needs a field approval from the local FSDO. (Major Repair and Alterations)
But he can not manufacture the skin and re-sell it to other airplanes.
And why are you buying parts from a salvage yard? if they do not have an FAA 8130-3 tag, they should not be installed.
I guess if the part has not been involved in an accident or fire, you can send it to a Repair Station so they can return it to service. Other than that, you can not install the part right from the salvage yard to your airplane.
:nono:
 
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WarriorPilot said:
An A&P mechanic can manufacture the skin as long as he has the current Manual and tools, and file a Form 337, which needs a field approval from the local FSDO. (Major Repair and Alterations)

All skin repairs are not major repairs, only flight controls are mandatory 337 repairs.

But he can not manufacture the skin and re-sell it to other airplanes.

true, you can manufacture any part for a repair, as long as you comply with the rules set fourth in AC 43-18. and 43,13

And why are you buying parts from a salvage yard? if they do not have an FAA 8130-3 tag, they should not be installed.

This is not true, I buy a lot of flight controls from the salvage yards, they are cheaper and a replacement part manufactured by the manufacturer is a simple log book replacement part and no 337 or 8130 tag required The installer declares airworthiness.

I guess if the part has not been involved in an accident or fire, you can send it to a Repair Station so they can return it to service. Other than that, you can not install the part right from the salvage yard to your airplane.
:nono:
Click to expand...

A CRS is not needed in any repair, to declare airworthiness.

"" Removed and replaced elevator, IAW the Cessna maintenance manual. ""

Thats a lot easier than a repair to a flight control, and admitting the aircraft has a major damage in its history.

I have totally disassembled an aircraft and replaced the fuselage, changed the data tag from one to the other, had the FSDO Airworthiness inspector inspect it and re-issue the AWC and there was no 337 involved.
 
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Tom-D said:
A CRS is not needed in any repair, to declare airworthiness.

"" Removed and replaced elevator, IAW the Cessna maintenance manual. ""

Thats a lot easier than a repair to a flight control, and admitting the aircraft has a major damage in its history.

I have totally disassembled an aircraft and replaced the fuselage, changed the data tag from one to the other, had the FSDO Airworthiness inspector inspect it and re-issue the AWC and there was no 337 involved.
Click to expand...
You are risking your license
:yikes:
 
WarriorPilot said:
You are risking your license
:yikes:
Click to expand...
hardly. i doubt he's worried.

BTW my non-homebuilt airplane has parts on it that I fabricated on my own lathe and end mill, with no PMA. And said parts were installed and signed off as a simple logbook entry with no 337. Oh the horror. Yet 100% legal and appropriate.
 
Some thing tells me that WarriorPilot doesn't know:

the proper use of the 337 form.
the difference between a major or minor repair.
the proper documentation of the use of the Original manufacturer's replacement parts.
the proper documentation of owner produced parts.
the rules of return to service or who can do it.
 
Tom-D said:
Some thing tells me that WarriorPilot doesn't know:

the proper use of the 337 form.
the difference between a major or minor repair.
the proper documentation of the use of the Original manufacturer's replacement parts.
the proper documentation of owner produced parts.
the rules of return to service or who can do it.
Click to expand...

Really?
So, you go to the junkyard, purchase an used aileron from a wrecked airplane, and if it "looks" good, you can go ahead and install it on an airworthy airplane? because you think your A&P gives you the ability to "determine" airworthiness on a part?
Really?
What are the FAA Repair Stations for? what about NDT testing? what documentation do you have from the part you purchased from the junkyard?
I am pretty sure the FAA 8130-3 tag is the only document around that can give you "airworthiness" on a part. Old yellow tags (Maintenance Release) are not longer used.
So you go to the junkyard again, and purchase an used alternator from another wrecked airplane and if it looks good, you as an A&P can go ahead and install it?
Rolling eyes here!
:rolleyes2:
 
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WarriorPilot said:
Really?
So, you go to the junkyard, purchase an used aileron from a wrecked airplane, and if it "looks" good, you can go ahead and install it on an airworthy airplane? because you think your A&P gives you the ability to "determine" airworthiness on a part?
Really?
What are the FAA Repair Stations for? what about NDT testing? what documentation do you have from the part you purchased from the junkyard?
I am pretty sure the FAA 8130-3 tag is the only document around that can give you "airworthiness" on a part. Old yellow tags (Maintenance Release) are not longer used.
So you go to the junkyard again, and purchase an used alternator from another wrecked airplane and if it looks good, you as an A&P go ahead and install it?
Rolling eyes here!
:rolleyes2:
Click to expand...
ayep. You're finally getting it.
 
WarriorPilot said:
And why are you buying parts from a salvage yard? if they do not have an FAA 8130-3 tag, they should not be installed.
Click to expand...

That may be your opinion, but that is not fact. An A&P is allowed to determine airworthiness of an item and install it accordingly. Certain shops can't (example: a number of avionics shops do not have A&Ps, and operate under a repair station certificate). At least, they've told me they need a yellow-tag since they aren't A&Ps. Maybe they just don't want to deal with parts that aren't yellow-tagged, I don't know. But it isn't a requirement.

WarriorPilot said:
Really?
So, you go to the junkyard, purchase an used aileron from a wrecked airplane, and if it "looks" good, you can go ahead and install it on an airworthy airplane? because you think your A&P gives you the ability to "determine" airworthiness on a part?
Really?
What are the FAA Repair Stations for? what about NDT testing? what documentation do you have from the part you purchased from the junkyard?
I am pretty sure the FAA 8130-3 tag is the only document around that can give you "airworthiness" on a part. Old yellow tags (Maintenance Release) are not longer used.
So you go to the junkyard again, and purchase an used alternator from another wrecked airplane and if it looks good, you as an A&P can go ahead and install it?
Rolling eyes here!
:rolleyes2:
Click to expand...

That is not how the regs are written.

We, too, have owner-produced parts. Oh, the horror. And yet, legal.
 
It's my understanding that a part 145 FAA repair station has about as much applicability to my personally-owned, operated-under-part 91 aircraft as the authorized Honda dealer shop does to my Honda CRV. They are there if I want them but why the heck would I subject myself to that abuse unnecessarily? Any IA can take a used part from another aircraft or some dusty shelf somewhere, inspect it for suitability, install it and return my aircraft to service, part 145 notwithstanding, and for most issues even the inspector authorization isn't needed.
 
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Certified Repair Stations are the only place a 8030 tag is used.

Show me any regulation that requires a part to have one to be legal to use to repair any aircraft.

I wonder why Wentworth Aircraft Salvage, Dodson, and many others are so successful in this business?

I can buy a horizontal stab, for a 172 from Wentworth pay shipping and be cheaper than paying to have it repaired after hail damage.
 
WarriorPilot said:
Really?
So, you go to the junkyard, purchase an used aileron from a wrecked airplane, and if it "looks" good, you can go ahead and install it on an airworthy airplane? because you think your A&P gives you the ability to "determine" airworthiness on a part?

Yes because it is a factory part built under a production certificate by the original manufacturer of the aircraft. You can use it exactly as you would a new part from Cessna pr Piper.

Really? Yes REALLY

What are the FAA Repair Stations for?

They are for repairing aircraft or appliances certified under different rules than the A&Ps working the field.

what about NDT testing?

Non Destructive testing has nothing to do with the topic we are talking about.


what documentation do you have from the part you purchased from the junkyard?

If you do not know what the part should like before you install it, you should not be an A&P.


I am pretty sure the FAA 8130-3 tag is the only document around that can give you "airworthiness" on a part.

Show me the regulation for you to believe that.


Old yellow tags (Maintenance Release) are not longer used.
So you go to the junkyard again, and purchase an used alternator from another wrecked airplane and if it looks good, you as an A&P can go ahead and install it?
Rolling eyes here!
:rolleyes2:
Click to expand...

Used parts are legal as it gets, and probably better than a repaired one. Simply because the used part has not been repaired or modified.

All aircraft in the salvage yards are not wrecks, some may have had a prop strike, and the engine re-build was more than the aircraft was insured for.

A question for you, If I pull a elevator off your aircraft can I put it back on? What's the difference in your used part than the one I can buy from the salvage yards?

Your's had damage, the one I bought from the Salvage yard doesn't.

Your way of thinking every time a paint shop disassembles any aircraft for painting they couldn't replace any of the parts with out a 8030- tag. simply is not the way it is done.
 
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Tom-D said:
and the sale of them..

can I as an owner, produce a part for my aircraft, and approve it under 21.9?


and then remove it and sell it as a "as removed" part?

If you buy used parts, How do you know who made them?
Click to expand...

When I've gone down this road as part of an airline project, the rule was they had to be marked so they couldn't be mistaken for an OEM part.
 
kontiki said:
When I've gone down this road as part of an airline project, the rule was they had to be marked so they couldn't be mistaken for an OEM part.
Click to expand...

Show me the rule????
 
Tom-D said:
and the sale of them..

can I as an owner, produce a part for my aircraft, and approve it under 21.9?


and then remove it and sell it as a "as removed" part?

If you buy used parts, How do you know who made them?
Click to expand...

You can produce it for your aircraft, as long as you meet the criteria, and a log book entry by the owner saying they made an owner produced part iaw AC23-27 section 13.

You most likely could pull it off an sell it, and even find someone to buy it. Although to maintain compliance with the FAR's you would have to do this with each piece you sold, and when the first plane crashed with a part on it from your airplane with a Paypal/ eBay receipt in the logs, the FAA just might come take a look at your log books and see that 10 were installed and replaced and have a few more questions for you.



-VanDy
 
Can one owner make an owner-produced part and then give it to another owner (free of charge) for installation by that owner?
 
peter-h said:
Can one owner make an owner-produced part and then give it to another owner (free of charge) for installation by that owner?
Click to expand...

"Thanks for the part, Peter! That really helps me out!"

*walks into shop*

"Hey, Ted the Mechanic, here's this owner-produced part I just made!"

Bonus points for anyone who gets the Deep Purple reference.

Note: not saying I'd do this, of course.
 
peter-h said:
Can one owner make an owner-produced part and then give it to another owner (free of charge) for installation by that owner?
Click to expand...
yes, as long as owner 2 materially participates in the fabrication of the part. That participation could be something such as providing the original part to be duplicated, providing some of the materials to make the part, or providing some requirements for making the part.

For example, you don't have a lathe but your Fred hangar neighbor does. You stop by and giver him a bushing from your landing gear and say "Hey Fred, I need a bushing to replace this one, and here's the service manual with the dimensions". You have just materially participated in making the part. Fred examines the part, determines what material it's made from, and makes you another one per your requirements. You give it to your A&P and he determines airworthiness (perhaps he measures per the manual and/or asks you what stock you used, or maybe he just asks "Fred do this for you?") and he installs it.
 
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