Zip tied rudder pedal covers...

CharlieD3

CharlieD3

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CharlieD3
A serious question from a non owner/non A&P.

Apparently, Piper rudder pedal covers on the brake portion of the pedal lose the adhesive over time (and heat).

Apparently it is common practice to zip tie the covers in place.

Personally, I see no harm-no foul in this. So, it must be highly illegal... Though some suggested it's okay if you use aviation zip ties... (But not big box zip ties).

So... Is it legal? Even with non pma or other approved zip ties?
 
CharlieD3 said:
There are such things. I seed 'em. Looking for reference.
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And... I was wrong. No FAA approved zip ties... Mil spec yes... FAA approvals. None.

But... then, Is this repair "legal?"
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CharlieD3 said:
Mil spec yes... FAA approvals. None.
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FYI: Ty-Raps are considered standard parts and don't need individual "approvals" just like bolts, nuts, wire, bulbs, etc. Any industry standard works like MIL-SPEC or SAE.
CharlieD3 said:
then, Is this repair "legal?"
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If there's not a log entry on them, then no. Better to re-glue them or remove them. Have also applied non-skid paint in place of pads.
 
I've heard that the rubber pedal covers are very similar (like identical) to a Harley Davidson part for foot pegs. You might try the aviation aisle at your local Harley dealer.
 
I replaced mine years ago as the left side, right rudder pedal was worn smooth. I glued them on with 3M 1300L as the zip tied route not only looks bad, but in my opinion, is a lazy repair. Harley Davidson sold a perfect replacement with the same mold marks. So I have Harley foot pads, a Studebaker trim handle and Volkswagen door handles.

Edit: Just looked up the price for new ones. $156.20 apiece from Air Parts West. The ones from HD were less than $3 apiece.
 
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Bell206 said:
FYI: Ty-Raps are considered standard parts and don't need individual "approvals" just like bolts, nuts, wire, bulbs, etc. Any industry standard works like MIL-SPEC or SAE.

If there's not a log entry on them, then no. Better to re-glue them or remove them. Have also applied non-skid paint in place of pads.
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Why is it not legal without log entry? Can log entry be done by owner? Is it a cosmetic thing or is it a function thing?
 
I don't think that is what he meant Charlie. You can fly the plane without the rubber pads so it is a cosmetic thing.
 
Hang 4 said:
I've heard that the rubber pedal covers are very similar (like identical) to a Harley Davidson part for foot pegs. You might try the aviation aisle at your local Harley dealer.
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Timbeck2 said:
I replaced mine years ago as the left side, right rudder pedal was worn smooth. I glued them on with 3M 1300L as the zip tied route not only looks bad, but in my opinion, is a lazy repair. Harley Davidson sold a perfect replacement with the same mold marks. So I have Harley foot pads, a Studebaker trim handle and Volkswagen door handles.
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I agree it looks tacky... I agree it should just be re-glued. I don't care, don't own or rent the plane... Don't care that harley pegs are the same...

My curiosity is the nuance of the regs.
 
I'm not trying to argue, I'm looking for an answer that explains why it's illegal, if it's a cosmetic thing...

It could be a safety thing if it slipped off during heavy braking, I suppose.

But, I wonder if it slipped off, or was starting to, and you applied this zip tie cure, and didn't get around to doing it properly for a week a month a year... And didn't log it... What would be the ramifications from a regulation standpoint be?
 
CharlieD3 said:
Why is it not legal without log entry?
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Any work performed on a TC’d aircraft that is not part of a normal preflight requires an entry in the aircraft records per Part 43.9. So regardless of the type of work performed, in this case the Ty-Raps, it is not legal without a write-up. Full stop. With a write up to install the TY-Raps, it now falls to a performance issue per Part 43.13 which provides for a more subjective/creative path to the person performing the work and puts the burden on the FAA to show why the Ty-Raps are not acceptable. Without a write-up you go straight to jail without passing “GO.”
CharlieD3 said:
Can log entry be done by owner?
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You tell me. Can you make that work "fit" into the Preventative Maintenance list in Part 43 Appx A?
CharlieD3 said:
My curiosity is the nuance of the regs.
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Most aviators don’t take the time to try and learn the FARs outside of Part 91. So good on you for making the effort. The FARs are a lot more flexible than people give them credit for.;)
 
You do not need zip ties. I have glued mine on with the 3m Yellow weather stripping adhesive and tape over them with masking tape. Remove the tape after the glue has dried.
 
Dan Thomas said:
A mechanic who can't be bothered to spend a few minutes with some contact cement is just lazy.
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That, and an owner with about zero standards. It perplexes me why so many people in aviation accept things like this.
 
Those that have modified their rudder peddles should review FAR 43-A knowing that the rudder is a flight control.

JSYK
 
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mondtster said:
It perplexes me why so many people in aviation accept things like this.
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I've found that the 50% who do things like that are out to prove something whether being cheap or feeling like an outlaw. However, it can be entertaining when the sheriff catches up to them though. The other 50% tend to do that type of work just out of ignorance of the rules. I always got a kick out of the look on an owners/pilots face once you show them how simple it can be to do things proper and legal. Back when those Staples "Easy" buttons were the rage, I'd pick one up for those owners who were moved the most... that was easy.:eek:
 
Half Fast said:
That list is to be interpreted only as examples.
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FWIW: depends on the application. For a private individual operating a private aircraft under Part 91 this LOI won't give you much relief due to subject matter. In my experience, attempts to use this LOI and others, in the 91 world, have not expanded their ability. Same goes for the AC on prevent mx. However, just as the LOI references the exemption route to an air carrier, a private owner has that same option which would probably be a better route. While I don't know if still possible today, in the past, I've helped several owners get exemption letters from the FSDO for various tasks like remove seats under prevent mx to include the EWB corrections. Regardless, the current Appx A prevent-mx list can be rather flexible depending on how you read it.;)
 
Archer Jack said:
Methinks the correct word may be "Preventive". Just saying.:fingerwag:
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ok, but my dictionary has Preventative as an adjective...

but, I'm a retired engineer, so English isn't my strongest language.
 
Bob Noel said:
ok, but my dictionary has Preventative as an adjective...

but, I'm a retired engineer, so English isn't my strongest language.
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Are you saying it does not require strong language skills to drive a train? :p
 
Bell206 said:
FWIW: depends on the application. For a private individual operating a private aircraft under Part 91 this LOI won't give you much relief due to subject matter. In my experience, attempts to use this LOI and others, in the 91 world, have not expanded their ability. Same goes for the AC on prevent mx. However, just as the LOI references the exemption route to an air carrier, a private owner has that same option which would probably be a better route. While I don't know if still possible today, in the past, I've helped several owners get exemption letters from the FSDO for various tasks like remove seats under prevent mx to include the EWB corrections. Regardless, the current Appx A prevent-mx list can be rather flexible depending on how you read it.;)
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I think the LOI is quite clear that the list of preventive maintenance items is just a set of examples. It doesn't differentiate between "private" aircraft and air carriers in terms of what the list in Appendix A means (now who can use it is another matter under 43.3(g)). Nothing in the LOI indicates that Part 91 operators are still stuck with only the items in Appendix A, and it certainly does expand their abilities (whether one is comfortable using those expanded abilities being another issue).
 
smv said:
Are you saying it does not require strong language skills to drive a train? :p
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Close. What he really meant is the letters "P E" after his name stand for "Poor English". ;)
 
Skyrys62 said:
Even lazier not to at least use black zip-ties. ;)
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Which was my response to the original poster (elsewhere). While noting that the black zip ties are UV resistant, so he could fly closer to the sun.
 
GRG55 said:
Close. What he really meant is the letters "P E" after his name stand for "Poor English". ;)
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ah, but the reality is that PE doesn't comprise the entirety of the engineering world.
 
Skyrys62 said:
Even lazier not to at least use black zip-ties. ;)
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Well that now raises the question "Is it illegal if both contact cement and black zip-ties are used, and nobody can find a pen to sign the logbook?"
Just askin'
 
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