Chinese Gauges

PilotAlan said:
Tell it to Bob Hoover.
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What does Bob Hover's clash with the FAA have to do with maintenance rules?

His episode had a lot to do with today's FAA's attitude.

The FAA got a lot of bad press over that, and they did not like the way it all turned out. that is why we now have inspectors acting way different than before.
 
Tom-D said:
What does Bob Hover's clash with the FAA have to do with maintenance rules?
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It has to do with rules, period, and the manner in which the FAA writes, interprets, and enforces them.

They still have the ability to write, enforce, and interpret them arbitrarily, capriciously, and in a fashion that makes it impossible to know what is and is not allowed in most cases.
These interpretations often fly directly in the face of the plain text of the regulation, and the structure and rules of legal interpretation.

Funny, it seems that FAA and NTSB interpretations never seem to go in the favor of the pilot/mechanic.
 
PilotAlan said:
It has to do with rules, period, and the manner in which the FAA writes, interprets, and enforces them.

How many times have you commented on a notice to rule changes?

They still have the ability to write, enforce, and interpret them arbitrarily, capriciously, and in a fashion that makes it impossible to know what is and is not allowed in most cases.

No not quite, you do have a NTSB hearings

These interpretations often fly directly in the face of the plain text of the regulation, and the structure and rules of legal interpretation.

show me one.


Funny, it seems that FAA and NTSB interpretations never seem to go in the favor of the pilot/mechanic.
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mostly because the FAA doesn't go on witch hunts, but they do prosecute the ones that hurt people and they now give you plenty chances to protect your self.

I do not know any A&P that was hit that wasn't at fault.

A few years ago, the three A&P-IAs that were working the Navy flying club were notified that they had missed an AD on a club aircraft that was sold to another club, each was told to send in their A&P certificate, two did, and sat out for 90 days, the third simply said send me the letter and be ready to prosecute, he never saw a letter and kept working.
 
Tom-D said:
A few years ago, the three A&P-IAs that were working the Navy flying club were notified that they had missed an AD on a club aircraft that was sold to another club, each was told to send in their A&P certificate, two did, and sat out for 90 days, the third simply said send me the letter and be ready to prosecute, he never saw a letter and kept working.
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Sounds like their inconsistency pushed his contempt button to the point where he said, "try me". He could have easily easily lost that game of chicken.
 
Tom-D said:
No not quite, you do have a NTSB hearings
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And until the very recent bill passed by congress, the NTSB was bound by the FAA's interpretation of their regulations.
An appeal means nothing if the appellate body is bound by the interpretation of the organization being appealed against.
show me one.
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How about the airworthiness regulations that say the owner or operator of the aircraft is required to ensure the aircraft is maintained in airworthy condition?

The "owner or operator" was put in because many airlines do not own their aircraft, but as the operator of the aircraft, they are required to maintain them in an airworthy condition.

Some portions of airworthiness regulation place responsibility on the operator AND pilot to ensure some portions of the aircraft's airworthiness, but others place the requirement on the OWNER or OPERATOR only.
The intent of the regulation was that a pilot flying in an air carrier or fleet cannot know everything about the aircraft's maintenance and history.

The FAA went after a pilot for an airworthiness issue, but the reg didn't say the pilot was responsible for it. The FAA interpreted the term "operator" to be synonymous with "pilot", and has hammered pilots for operating an unairworthy aircraft.
The legal and structural rules of regulatory interpretation are that if different terms are used, they cannot have the same meaning. If they were intended to have the same meaning, then the regulator would use the same term.

This is just one example of language that would not survive an independent review of regulatory interpretation under the normal standard of review. But because the ALJs and NTSB have been forced to accept the FAA's interpretations of the regulations, they got away with it.

Another tenet of law is that a person must have reasonable notice that an act is prohibited or required. The FAA's regs clearly do not meet that standard.
 
PilotAlan said:
And until the very recent bill passed by congress, the NTSB was bound by the FAA's interpretation of their regulations.
An appeal means nothing if the appellate body is bound by the interpretation of the organization being appealed against.

How about the airworthiness regulations that say the owner or operator of the aircraft is required to ensure the aircraft is maintained in airworthy condition?

The "owner or operator" was put in because many airlines do not own their aircraft, but as the operator of the aircraft, they are required to maintain them in an airworthy condition.

Some portions of airworthiness regulation place responsibility on the operator AND pilot to ensure some portions of the aircraft's airworthiness, but others place the requirement on the OWNER or OPERATOR only.
The intent of the regulation was that a pilot flying in an air carrier or fleet cannot know everything about the aircraft's maintenance and history.

The FAA went after a pilot for an airworthiness issue, but the reg didn't say the pilot was responsible for it. The FAA interpreted the term "operator" to be synonymous with "pilot", and has hammered pilots for operating an unairworthy aircraft.
The legal and structural rules of regulatory interpretation are that if different terms are used, they cannot have the same meaning. If they were intended to have the same meaning, then the regulator would use the same term.

This is just one example of language that would not survive an independent review of regulatory interpretation under the normal standard of review. But because the ALJs and NTSB have been forced to accept the FAA's interpretations of the regulations, they got away with it.

Another tenet of law is that a person must have reasonable notice that an act is prohibited or required. The FAA's regs clearly do not meet that standard.
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If you do not want to be violated, don't fly an unairworthy aircraft. I don't care who you work for.
 
Tom-D said:
If you do not want to be violated, don't fly an unairworthy aircraft. I don't care who you work for.
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You asked for an example of a regulatory interpretation that didn't meet basic rules of legal construction and rules of interpretation. I gave one to you.

The issue is not whether or not the aircraft is airworthy, it's whether the rules can be understood before they are used against you.
And by the way, do you think it's possible for an airline pilot to know whether the aircraft meets all airworthiness requirements prior to taking off? Really? That the AD from 2003 on the wiring bundle behind interior panel 236A was completed IAW the AMOC?

Clearly you have no interest in actually discussing the standards for regulations. I'm done here.
 
PilotAlan said:
You asked for an example of a regulatory interpretation that didn't meet basic rules of legal construction and rules of interpretation. I gave one to you.

The issue is not whether or not the aircraft is airworthy, it's whether the rules can be understood before they are used against you.
And by the way, do you think it's possible for an airline pilot to know whether the aircraft meets all airworthiness requirements prior to taking off? Really? That the AD from 2003 on the wiring bundle behind interior panel 236A was completed IAW the AMOC?

Clearly you have no interest in actually discussing the standards for regulations. I'm done here.
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Why do you think the rules for 135,121,125 are different than 91?

They place the maintenance compliance on the operator, which is the company, not the pilot.

The rules are clear, wither you like to believe it or not.
 
Tom-D said:
They place the maintenance compliance on the operator, which is the company, not the pilot.
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As I said in my previous post, the FAA has defined the term OPERATOR to include the PILOT, and that interpretation was upheld by the ALJ and the NTSB (as they were required to). That is the point.
 
So Tom, in one post you say all the rules are clear and in another you mention that you can call the FSDO with questions and they won't answer.

So which is it?
 
Tom-D said:
If you do not want to be violated, don't fly an unairworthy aircraft. I don't care who you work for.
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Don't worry Tom, as A&P we won't let this happen. At least I will never install an unairworthy part (Non-Tso'd) and sign the logbook.
Aircraft owners can go to Toys-R-Us or AutoZone and buy anything they want and install it, that is their responsibility and license at risk.
:rofl:
 
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denverpilot said:
So Tom, in one post you say all the rules are clear and in another you mention that you can call the FSDO with questions and they won't answer.

So which is it?
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well to some the writings are never clear, But you can always call FSDO, they will tell you where to find the info. but they will will seldom commit to a answer.

When you work with the FARs and FSDO almost every day you come to understand why the FARs are written the way they are.
 
WarriorPilot said:
Don't worry Tom, as A&P we won't let this happen. At least I will never install an unairworthy part (Non-Tso'd) and sign the logbook.
Aircraft owners can go to Toys-R-Us or AutoZone and buy anything they want and install it, that is their responsibility and license at risk.
:rofl:
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That means you will never apply for a field approval.
or
overhaul any engine.
or
recover any fabric flight control.
or
Apply any STC.
or
change gyro to a different brand that didn't come from the factory.
 
WarriorPilot said:
Don't worry Tom, as A&P we won't let this happen. At least I will never install an unairworthy part (Non-Tso'd) and sign the logbook.
Aircraft owners can go to Toys-R-Us or AutoZone and buy anything they want and install it, that is their responsibility and license at risk.
:rofl:
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As an a&p you ought to know that TSO is neither necessary nor sufficient for installing a a part. The only thing I'm aware of where a specific TSO is required are for GPSes to be used for IFR operations.
 
WarriorPilot said:
PilotAlan, some Narco, King radios were produced NON-TSO just because they are the "export" version of the product, some countries do not require FAA approval.
As far as any "N" aircraft, you have to stick to our regulations. I don't think an avionics shop or an A&P will install a non-tso'd part in your airplane anyway.
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thanks for the explanation. For years I've wondered why no US-registered plane has ever had a KX170 or 170B nav/com installed.
 
JHW said:
thanks for the explanation. For years I've wondered why no US-registered plane has ever had a KX170 or 170B nav/com installed.
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HUH... I have seen ALOT of N number planes with those radios installed in them.. From the factory too..
 
N801BH said:
HUH... I have seen ALOT of N number planes with those radios installed in them.. From the factory too..
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You must be mistaken. We've just been informed that those radios are for export only.

Or could it be that someone doesn't have a clue what they're talking about again? Surely not.
 
bartmc said:
As an a&p you ought to know that TSO is neither necessary nor sufficient for installing a a part. The only thing I'm aware of where a specific TSO is required are for GPSes to be used for IFR operations.
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I believe a transponder also has to meet the applicable TSO but those are the only two I know of for Part 91.
 
JHW said:
thanks for the explanation. For years I've wondered why no US-registered plane has ever had a KX170 or 170B nav/com installed.
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Or a KX155, or a KY97, or an ICOM A200, or a KNS80, a KI208, or a KMA12, or .....
 
PilotAlan said:
Or a KX155, or a KY97, or an ICOM A200, or a KNS80, a KI208, or a KMA12, or .....
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I'm in real trouble, i've flown with most of those radios and evel filed IFR! Somebody stop me before I offend again.
 
JHW said:
I'm in real trouble, i've flown with most of those radios and evel filed IFR! Somebody stop me before I offend again.
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Heck, I have three of those in my plane!
(OK, the KMA12 got replaced last year)
 
I wonder if all the repairs I have done with out TSO/PMA,or 8030- tags, on the paint, sheet metal, tubing, wire, rivets, nuts and bolts, gauges, radios, and other stuff, will be unairworthy repairs.

I wonder what paper work Warriorpilot uses o a new part? because you get nothing with a new part that says it is airworthy.

I can order a set of main bearings, rod bearings, a complete set of hydraulic lifters, cylinder kits, and a set of new gears for an overhaul and not get a single 8030-3 tag for any of them.

I wonder why they were airworthy?
 
Witmo said:
I believe a transponder also has to meet the applicable TSO but those are the only two I know of for Part 91.
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ELTs are TSO required, see FAR 91-207 on which ones you can't install.
91.207
(2) For operations other than those specified in paragraph (a)(1) of this section, there must be attached to the airplane an approved personal type or an approved automatic type emergency locator transmitter that is in operable condition, except that after June 21, 1995, an emergency locator transmitter that meets the requirements of TSO-C91 may not be used for new installations.
 
PilotAlan said:
Neither are the KX-155 and KY-97.
The KX-175 and the KX-165 are the TSOd versions.

For MOST operations, TSO'd components are only required or Part 135 operations (depending on op specs). Hence why almost everyone (including headset makers) have TSO and non-TSO versions of their equipment.

I have yet to see anyone point to the regulation that requires TSO for most instruments and avionics in Part 91 operations (with the exception of IFR GPS's which have specific TSOs for IFR operations).
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Where can these be located?
What FAR specifically requires that a GPS be certified? (google-fu is not good this morning).
 
PilotAlan said:
Or a KX155, or a KY97, or an ICOM A200, or a KNS80, a KI208, or a KMA12, or .....
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Are you sure they are NON-TSO'd?......I have installed many of them, and they are TSO.
As I said before, you could find one or two that are NON-TSO'd, but they are for export only.
Have you ever seen an FAA 8130-3 tag "FOR EXPORT ONLY"?
But again, we have A&Ps around and pilots installing non-tso'd parts in their airplanes. Just wait for an FAA audit. :yikes:
 
WarriorPilot said:
Are you sure they are NON-TSO'd?......I have installed many of them, and they are TSO.
As I said before, you could find one or two that are NON-TSO'd, but they are for export only.
Have you ever seen an FAA 8130-3 tag "FOR EXPORT ONLY"?
But again, we have A&Ps around and pilots installing non-tso'd parts in their airplanes. Just wait for an FAA audit. :yikes:
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I have been thru probably 20 or more FAA audits, during imports of aircraft with full inspection of the maintenance records by the FSDO- Airworthiness Inspectors. Never was there any mention of a TSO requirement for any equipment.
I really believe you do not understand what TSO is or why we have it.

OBTW, you do not need a 8030-3 sheet to export any part.

Do you know who are the only maintenance facilities that require a 8030-3 sheet?
 
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Tom-D said:
I wonder if all the repairs I have done with out TSO/PMA,or 8030- tags, on the paint, sheet metal, tubing, wire, rivets, nuts and bolts, gauges, radios, and other stuff, will be unairworthy repairs.

I wonder what paper work Warriorpilot uses o a new part? because you get nothing with a new part that says it is airworthy.

I can order a set of main bearings, rod bearings, a complete set of hydraulic lifters, cylinder kits, and a set of new gears for an overhaul and not get a single 8030-3 tag for any of them.

I wonder why they were airworthy?
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Tom, if you are buying directly from an "FAA Approved" manufacturer, you don't need anything, just the Invoice and the "Certificate of Conformance" which is usually at the bottom of the Invoice.
I can buy a brand new altimeter from United Instruments, and the only paperwork they have is the Invoice and the C of C. You don't need an FAA 8130-3 tag from them.
If you are buying rod bearings, as you mentioned above, make sure they came from an "FAA approved source".
I buy gaskets from Wencor, and they come with a Certificate of Conformance, because Wencor is an FAA AC-0056, I don't need any other document.
Should I need to buy parts from "sporty's" or "aircraft spruce", they better supply a copy of the FAA 8130-3 tag, Material Certificate or Certificate of Conformance.
Would you go to Home Depot and buy screws from them? :yikes:
 
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WarriorPilot said:
Tom, if you are buying directly from an "FAA Approved" manufacturer, you don't need anything, just the Invoice and the "Certificate of Conformance" which is usually at the bottom of the Invoice.
I can buy a brand new altimeter from United Instruments, and the only paperwork they have is the Invoice and the C of C. You don't need an FAA 8130-3 tag from them.
If you are buying rod bearings, as you mentioned above, make sure they came from an "FAA approved source".
I buy gaskets from Wencor, and they come with a Certificate of Conformance, because Wencor is an FAA AC65, I don't need any other document.
Should I need to buy parts from "sporty's" or "aircraft spruce", they should supply a copy of the FAA 8130-3 tag, Material Certificate or Certificate of Conformance.
Would you go to Home Depot and buy screws from them? :yikes:
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Wrong again, learn the rules.

I can buy and use parts bought any where, and legally use them.

I am the one returning the aircraft to service and am the who determines the airworthiness of any part I use.

Tell me what paper work I need to use a NEW part. Because when you open the box there is no paper work in there.

So how can you use it, if there is no paper work to go with it.??
 
Tom-D said:
Wrong again, learn the rules.

I can buy and use parts bought any where, and legally use them.

I am the one returning the aircraft to service and am the who determines the airworthiness of any part I use.

Tell me what paper work I need to use a NEW part. Because when you open the box there is no paper work in there.

So how can you use it, if there is no paper work to go with it.??
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The rule is very simple, if there is NOT paperwork, just throw it away !
I just purchased a can of Aeroshell 33MS from Aviall, it came with the Invoice, Certificate of Conformance, Trace to Birth, and Expiration Date.
 
AC21-29c contains a list of approved parts.. To big to copy and paste.


-VanDy
 
WarriorPilot said:
Are you sure they are NON-TSO'd?......I have installed many of them, and they are TSO.
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The KX-170 is non-TSO
The KX-175 is TSO

The KNS-80 is non-TSO
The KNS-81 is TSO

KN-62 is TSO
KN-64 is non-TSO

The KI-208 is non-TSO
The KI-209 is TSO

The KMA-12 is non-TSO
The KMA-20 is TSO.

The ICOM A200 and A210 are available TSO or non-TSO.

The MAC-1700 is non-TSO.

Flightcom FL-760 (used in lots of aerobatic aircraft) - Non-TSO

I was mistaken on the KY96/97, the 96 is a 28v version of the 27, both are TSO.
The KX165 is a higher power version of the 155, both are TSO.

TSO radios are not required for non-commercial Part91 operations.
Otherwise FAA inspectors would not have been doing CFI checkrides on planes with KX-170s for the last 40 years, ramp checks would have violated thousands of pilots, and avionics shops wouldn't be installing them.
 
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WarriorPilot said:
The rule is very simple, if there is NOT paperwork, just throw it away !

Wrong again,, when you buy new parts for Continental or Lycoming, they come off the shelf, and to you with nothing but the purchase receipt. there is nothing that says any thing about airworthiness.


I just purchased a can of Aeroshell 33MS from Aviall, it came with the Invoice, Certificate of Conformance, Trace to Birth, and Expiration Date.
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What does oil have to do with airworthiness?

Show me the airworthiness paper work on a new ECI cylinder kit.
 
Tom-D said:
What does oil have to do with airworthiness?

Show me the airworthiness paper work on a new ECI cylinder kit.
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You should have a quality control system in place, even if you are working alone and for yourself. Stop buying at the local hardware store, E-Bay, the junkyard and Home Depot.
I have some gaskets for Pratt and Whitney (PT6 engines) and they have FAA 8130-3 tag. Why your cylinders from Contiental or Lycoming do not have an 8130-3?
:yikes:
 
WarriorPilot said:
You should have a quality control system in place, even if you are working alone and for yourself. Stop buying at the local hardware store, E-Bay, the junkyard and Home Depot.
I have some gaskets for Pratt and Whitney (PT6 engines) and they have FAA 8130-3 tag. Why your cylinders from Contiental or Lycoming do not have an 8130-3?
:yikes:
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Because they were build on a production certificate.

read the FARs 21.303 to start.
 
WarriorPilot said:
You should have a quality control system in place, even if you are working alone and for yourself. Stop buying at the local hardware store, E-Bay, the junkyard and Home Depot.
I have some gaskets for Pratt and Whitney (PT6 engines) and they have FAA 8130-3 tag. Why your cylinders from Contiental or Lycoming do not have an 8130-3?
:yikes:
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Show me an approved quality control system in part 91, quote the FAR.

8130-3 forms are for used parts, that you believe can't be used.

CRS facilities are the only ones that used a 8030-3. Just because a part has one, does not mean it is airworthy.
 
Tom-D said:
Because they were build on a production certificate.

read the FARs 21.303 to start.
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And what paperwork are you going to attach to your log book entry?
You have to proof to the FAA they came from a production certificate.
 
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