Data tag Dilemma

[Tom-D]

A 170 owner has a C-125 data tag on his 0-300-A. The 125 was never produced as an authorized engine for any 170.

This engine was overhauled many years ago, using a C-125 case, which has the data tag attached, and the original data tag for the 145 was not transferred to the 125 case.

this engine has under gone 3 overhauls since then, Aircraft Specialities reworked this case as a C-145 case and we have a 8030 tag saying it is a 145 case.

The overhaul manual for the 0-300- says in section 2 para 1.f says all cases can be used on all engines, they are the same casting and machining is the same.

Here's the kicker, TCM says we must have a letter from the FAA giving authorization to issue a new data tag, We got that, now they say they can not issue a 0-300-A data tag for a serial number of a C-125. they will issue a new tag for a 125.

How would you get a new 0-300-A data tag for this engine which by the way has 500+ hours since major.

43.A says :
(2) Powerplant major alterations. The following alterations of a powerplant when not listed in the engine specifications issued by the FAA, are powerplant major alterations.

(i) Conversion of an aircraft engine from one approved model to another, involving any changes in compression ratio, propeller reduction gear, impeller gear ratios or the substitution of major engine parts which requires extensive rework and testing of the engine.

But are we changing the designation ? we are replacing only one part, ( the case) which the OVHL manual says we can do.
I have a call into my PMI but he's out of town till Tuesday.

 

[Henning]

Interesting, I have a feeling that since TCM has been directly involved and you have current documentation of what the engine really is inside, that the issue will be cleared up through a 337. I'll be interested with what the PMI comes up with as a solution.

 

[Tom-D]

All because some one didn't know they can move data tags from one part to another.

 

[Henning]

All because some one didn't know they can move data tags from one part to another.

Yep, happens all the time, they think the tag belongs to that part, not the assembly. I've had this argument before changing out an empennage about swapping the data tags.

 

[tyndall]

The engine is the data tag. In this case it's a 125 with a bunch of incorrect parts and installed illegally in the wrong airframe. Either you have to claim a lost data tag for the original engine (and s/n) and then document replacing the case, or convert the 125. The argument of replacing one part doesn't fly. Not moving the tag means everything except the one part was replaced. Definately a major f-up on someone's part.

 

[Silvaire]

(i) Conversion of an aircraft engine from one approved model to another, involving any changes in compression ratio, propeller reduction gear, impeller gear ratios or the substitution of major engine parts which requires extensive rework and testing of the engine.

Ignore the part you highlighted in red and read the part I underlined. None of that was done, it's not a major alteration.

 

[Let'sgoflying!]

Scrap yard tag from wrecked case

 

[poadeleted20]

Unless you know the original engine serial number, I think the owner is going to have to buy another engine (either a C-145-2 or an O-300-A) or at least an engine case with a C-145-2/O-300-A data tag.

I - Model 170, 4 PCLM (Normal Category), Approved June 1, 1948; 2 PCLM (Utility Category), Approved July 12, 1948 ​

[FONT=FLJFOG+TimesNewRoman,Times New Roman][FONT=FLJFOG+TimesNewRoman,Times New Roman]Engine Continental C145-2 (See Item 112 for optional engine)
...
112. Continental 0-300-A engine (Same limits as for C-145-2 or-2H engine)
[/FONT][/FONT]

I just don't see any way TCM is going to send you a C-145-2/O-300-A data tag for an engine whose serial number identifies it as a C-125. The only possible alternative I see would be to tear down the engine and confirm part-by-part that all the parts match a C-145-2/O-300-A, and write it up as converting a C-125 to a C-145-2/O-300-A -- same as converting a C-85 to O-200 (which I know is done).

 

[Capt. Geoffrey Thorpe]

reason #1063.45 to never, ever, buy a type certificated aircraft.

 

[poadeleted20]

reason #1063.45 to never, ever, buy a type certificated aircraft.

You'd have much the same problem if you put this engine in an E-AB airplane whose paperwork said "C-145" unless you wanted to recertify the plane for a C-125 including doing all the Phase I testing again.

 

[Henning]

Please people, the FAA guys are not a bunch of retards, my bet is this gets a face palm from them and a reasonably simple paperwork fix.

 

[bnt83]

reason #1063.45 to never, ever, buy a type certificated aircraft.

You don't like to throw money and man hours away chasing nonsense discrepancies?

My Dad is interested in a 1968 cardinal that is in storage for 15 yearsish, flew once an overhauled engine 15 years ago that ate itself and the owner (A&P IA) then rebuilt the engine himself and never signed it off or flew it again.

I'm not sure where to start on that one.

 

[Checkout_my_Six]

Tom....have a new 0-300A data plate manufactured with the "original" information and replace it. Ignore the C-125 or C-145 stuff.....

You are confusing the issue with way too much information. Sometimes information control is needed in these situations.

 

[poadeleted20]

Please people, the FAA guys are not a bunch of retards, my bet is this gets a face palm from them and a reasonably simple paperwork fix.

Please tell us how you think the FAA can fix this with mere paperwork. Do you really think they'd accept that this really is a C-145-2/O-300-A without first checking every part in it that could be a C-125 part? The operative word is "conformity".

 

[Henning]

Please tell us how you think the FAA can fix this with mere paperwork. Do you really think they'd accept that this really is a C-145-2/O-300-A without first checking every part in it that could be a C-125 part? The operative word is "conformity".

Because the engine has documentation from TCM as to what it really is in construction.

 

[poadeleted20]

Tom....have a new 0-300A data plate manufactured with the "original" information and replace it. Ignore the C-125 or C-145 stuff.....

Who is going to make that data plate? Not TCM, it would seem. So who else is authorized to do that, and what documentation will they require before making one? I'm just not seeing any provision in 14 CFR 45.13, AC 45-3A, and AC 45-2D which would allow one to "a new 0-300A data plate manufactured with the 'original' information. In particular, I see the following in AC 45-3A:

10. Control of Engine Components.

a. The FAA is concerned that some aircraft operators and repair stations may not remove the engine​

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ID plate from the module containing it when the particular module is damaged and must be replaced or when the module must be removed for maintenance and will not be reinstalled on the engine from which it was removed.​

b. Similarly, the FAA is concerned that some aircraft operators and repair stations may install replacement modules containing an engine ID plate belonging to another engine assembly. Such an exchange of engine lD plates results in a loss of identity (historical/rnodification data) for both engines and does not comply with § 45.13(c) and/or (e). In addition, an exchange of engine ID plates (including serial numbers) from engine to engine, or failure to remove and reinstall an engine ID plate when the module containing it must be removed for maintenance, inhibits positive control of both modular and non-modular components.

...and that's what appears to have happened here. It sounds to me like to the FAA, this engine no longer exists as a certified product. And from AC 45-2D:

i. Acquiring an Identification Plate from Somewhere Other Than the Manufacturer.​

(1)​

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[FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]You are required to have the FAA’s approval to remove, change information on, or install an identification plate for other than maintenance. ​

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(2)​

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[FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]You are required not to use an identification plate from a scrapped or destroyed aircraft or aircraft engine. ​

[/FONT][/FONT]

(3)​

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[FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]You are required to buy identification plates from an approved source after going through the process described in paragraph 6g. ​

[/FONT][/FONT] (4) [FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]If you install an identification plate without the FAA’s approval, you are in violation of § 45.13(b), (c), and/or (e).
[/FONT][/FONT]

 

[poadeleted20]

Because the engine has documentation from TCM as to what it really is in construction.

No, it doesn't -- the logbooks are for an engine with one s/n, and the engine has a data plate with another s/n. To the FAA, those are two different engines.

 

[Checkout_my_Six]

Please tell us how you think the FAA can fix this with mere paperwork. Do you really think they'd accept that this really is a C-145-2/O-300-A without first checking every part in it that could be a C-125 part? The operative word is "conformity".

The IA signs off conformity to the TCDS.....at each annual inspection. Tom can do that.

 

[Henning]

No, it doesn't -- the logbooks are for an engine with one s/n, and the engine has a data plate with another s/n. To the FAA, those are two different engines.

It has been overhauled with that data tag on record if I read this right.

 

[Checkout_my_Six]

Who is going to make that data plate? Not TCM, it would seem. So who else is authorized to do that, and what documentation will they require before making one? I'm just not seeing any provision in 14 CFR 45.13, AC 45-3A, and AC 45-2D which would allow one to "a new 0-300A data plate manufactured with the 'original' information. In particular, I see the following in AC 45-3A:
...and that's what appears to have happened here. It sounds to me like to the FAA, this engine no longer exists as a certified product. And from AC 45-2D:

My initial request woulda been for a destroyed data plate on the 0-300A tag. Just replace the tag as was on the original 0-300A.

The problem with this is that the story got too complicated....and folks now can't get their head around it.

I wonder if the old case can be located....and retrieve the old tag?....and transfer that tag?

Next question....ask TCM how to perform this?

....
The overhaul manual for the 0-300- says in section 2 para 1.f says all cases can be used on all engines, they are the same casting and machining is the same.
.......

 

[Henning]

My initial request woulda been for a destroyed data plate on the 0-300A tag. Just replace the tag as was on the original 0-300A.

The problem with this is that the story got too complicated....and folks now can't get their head around it.

I wonder if the old case can be located....and retrieve the old tag?....and transfer that tag?

That would be like trying to find a corn cob you threw into a pig pen 15 years ago, most likely it was eaten. Scarp parts usually get sold for recycling weight.

 

[timwinters]

This and so many other threads around here remind me of a saying that we used to have in high school:

It doesn't matter, and what if it did.

 

[Tom-D]

The IA signs off conformity to the TCDS.....at each annual inspection. Tom can do that.

Which type certificate do I say it conforms to? the 125? It doesn't.

The 145? it doesn't, because it has the wrong data tag?

 

[Checkout_my_Six]

Which type certificate do I say it conforms to? the 125? It doesn't.

The 145? it doesn't, because it has the wrong data tag?

When you get the correct tag....you sign it off. Currently it doesn't conform to the markings.

 

[Tom-D]

My initial request woulda been for a destroyed data plate on the 0-300A tag. Just replace the tag as was on the original 0-300A.

This is what I believe needs to happen. The request for a new tag was requested for the wrong S/N.

now we have an engine that is 500 hours old after overhaul, who is going to declare it is in compliance to the 145 configuration?
For me, it is too much trust in another's work.

 

[Tom-D]

When you get the correct tag...

That's what I'd like to know how to do, How do I prove what S/N the engine is? It certainly isn't a 125.

 

[Tom-D]

Unless you know the original engine serial number, I think the owner is going to have to buy another engine (either a C-145-2 or an O-300-A) or at least an engine case with a C-145-2/O-300-A data tag.I just don't see any way TCM is going to send you a C-145-2/O-300-A data tag for an engine whose serial number identifies it as a C-125. The only possible alternative I see would be to tear down the engine and confirm part-by-part that all the parts match a C-145-2/O-300-A, and write it up as converting a C-125 to a C-145-2/O-300-A -- same as converting a C-85 to O-200 (which I know is done).

We have the 8030 tags for the last overhaul.

 

[Checkout_my_Six]

That's what I'd like to know how to do, How do I prove what S/N the engine is? It certainly isn't a 125.

I'd take the info from the 0-300 log books and use that.

My conversation with TCM would have been .....hey, I have a destroyed data tag for this 0-300 could I get a replacement?....then provide the info from the logs.

btw....by signing this off your inspection "is" the conformity validation.

 

[Tom-D]

Who is going to make that data plate? Not TCM, it would seem. So who else is authorized to do that, and what documentation will they require before making one? I'm just not seeing any provision in 14 CFR 45.13, AC 45-3A, and AC 45-2D which would allow one to "a new 0-300A data plate manufactured with the 'original' information. In particular, I see the following in AC 45-3A:
...and that's what appears to have happened here. It sounds to me like to the FAA, this engine no longer exists as a certified product. And from AC 45-2D:

Do not confuse this with modular engine tracking. where each section/module has its own record.

But you are right about the rest of this problem, the FAA thinks this aircraft has the wrong engine installed.
I hope they don't push this, because there will be IA's that will be required to explain why this was not caught before. Specially the 3 who have overhauled it.
I have never seen this aircraft or engine, I was simply asked how to fix the problem.

 

[Tom-D]

I'd take the info from the 0-300 log books and use that.

My conversation with TCM would have been .....hey, I have a destroyed data tag for this 0-300 could I get a replacement?....then provide the info from the logs.

btw....by signing this off your inspection "is" the conformity validation.

I believe you are correct on trying to back out the paper that says anything about the 125 S/N. then re-submit the request for a new tag for the Original 145 S/N.

Simply because TCM is not going to change the designation of the 125 S/N. I don't know if they are even authorized to do that.

 

[Checkout_my_Six]

no....the sn is from the original 0-300....not the 145 sn.

 

[Tom-D]

no....the sn is from the original 0-300....not the 145 sn.

The 0-300-A and the C-145-A are the exact same engine designation.

It is the C-125 that is different. and that is the data tag installed.

I just sent the owner the E-Mail to resubmit for a new tag under the original 170's engine serial. we have that in the A/C log. we will see what happens

Thanks for the help.

 

[Silvaire]

Question: Why are you requesting a new data tag with the C-125 S/N? Why don't you request it for the original C-145 S/N? You've cited the TCM reference that the cases are interchangeable. This is not a major alteration. The only "error" is that the original data tag was not transferred when the case was replaced. Now it is a simple matter of replacing the lost tag.

Don't dig too deep because mostly you will find yourself talking to someone who spends most of his time on a computer in a cubicle and has never even seen an O-300 let alone overhauled one. This is a prime example of a big fuss being made over nothing.

 

[RotorAndWing]

This is a prime example of a big fuss being made over nothing.

Why is anyone surprised about this?

 

[Tom-D]

Question: Why are you requesting a new data tag with the C-125 S/N?

I didn't, I was asked to help unfu-k this

Why don't you request it for the original C-145 S/N? You've cited the TCM reference that the cases are interchangeable. This is not a major alteration. The only "error" is that the original data tag was not transferred when the case was replaced. Now it is a simple matter of replacing the lost tag.

And that is exactly what we are going to do

Don't dig too deep because mostly you will find yourself talking to someone who spends most of his time on a computer in a cubicle and has never even seen an O-300 let alone overhauled one. This is a prime example of a big fuss being made over nothing.

Actually my new PMI owns one. And he is a pretty nice guy, who while on Vacation answered my phone call on his time.
And he is in agreement, just simply ask for the correct data tag for the original C-145-A / 0-300-A the problem with that is, TCM wants the old data tag that they are replacing.

The letter went out today to request the FAA's authorization for TCM to replace the missing data tag.

it was explained to TCM the tag is missing, we will now see what happens.

 

[bnt83]

I got a new plate years ago for an O-200. It took like three days total to get a shiny new data plate. The letter Continental sent with the new tag said "you sent us a tag with serial # ABC, which is an invalid number. The serial # of that engine is now DEF. See provided installation instructions for installing the new tag with provided drive screws"

I added that letter to the logbook.

 

[poadeleted20]

My initial request woulda been for a destroyed data plate on the 0-300A tag. Just replace the tag as was on the original 0-300A.

How would you explain that the s/n on the engine doesn't match the s/n on its purported records?

I wonder if the old case can be located....and retrieve the old tag?....and transfer that tag?

Now that would work. Only problem would be getting someone to backdate the entry transferring the dataplate from the old case to the 125 case.

 

[tyndall]

How would you explain that the s/n on the engine doesn't match the s/n on its purported records?]

The case was replaced supposedly with proper documentation and the logs show the old s/n. The case serial number doesn't always match the engine serial number. Only the data tag was lost. Cases get replaced all the time, but the engine s/n stays the same. Your options are to document the case change properly or file off the case s/n and restamp with the old case s/n, which is kinda frowned upon.

The problem is proving to some pencil pusher with a superiority complex that the tag was in fact lost and not currently flying on some engine somewhere.

 

[Henning]

How would you explain that the s/n on the engine doesn't match the s/n on its purported records?

Now that would work. Only problem would be getting someone to backdate the entry transferring the dataplate from the old case to the 125 case.

Repair documentation and original engine documentation. This isn't tough really.

 

[poadeleted20]

The case was replaced supposedly with proper documentation and the logs show the old s/n.

If the case was replaced with proper documentation, the original data tag would have been moved to the new case and the C-125 data tag destroyed with proper procedure and the documentation would show that. Since the C-125 data tag remains on the case and the original C-145 (or O-300) data tag is gone, then the documentation cannot possibly be proper because either it doesn't show the tag swap which actually happened or it does show a tag swap that didn't happen.