FAA Order 8100.19 "Destroyed and Scrapped Aircraft"

FAA needs to stay in their own lane.
 
Eric Stoltz said:
Basically, (imho) does it seems like the FAA is looking for a solution that might not really be a problem?
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This guidance has been out in various forms and formats for years. There have been requests to put it in one place for just as many years. The damaged/destroyed definition came to a head back in the late 80s when several aircraft part sellers got caught selling parts from a destroyed aircraft on the open market and the OEMs got involved.

Several lawsuits later the Feds got involved. After that if you built a TC'd aircraft from salvage you needed a letter from the current TC holder to get a Standard AWC plus various OEMs started a "destroyed" aircraft databases. Unfortunately there are some very dishonest individuals in aviation.
 
James331 said:
FAA needs to stay in their own lane.
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Since an aircraft requiring major repair has always been in their lane, they are just clarifying a few things for those who think their britches are bigger than the FAA’s.
 
Bell206 said:
This guidance has been out in various forms and formats for years. There have been requests to put it in one place for just as many years. The damaged/destroyed definition came to a head back in the late 80s when several aircraft part sellers got caught selling parts from a destroyed aircraft on the open market and the OEMs got involved.

Several lawsuits later the Feds got involved. After that if you built a TC'd aircraft from salvage you needed a letter from the current TC holder to get a Standard AWC plus various OEMs started a "destroyed" aircraft databases. Unfortunately there are some very dishonest individuals in aviation.
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This is not to say you can't use Salvage yard parts to rebuild your aircraft.
The only time I have encountered a problem was when the insurance company declared the aircraft destroyed, sent the FAA the airworthiness certificate and the data tag.
I am now involved to gaining a new registration for a supercub that is being restored that the insurance company declared destroyed, but never sent the FAA any of the paper work. We have the airworthiness certificate, data tag, and all logs.
The FAA wants 4 pictures showing the aircraft as airworthy, all pictures must show N number applied. and a new application for registration.
What surprised me was the fact the FAA data base already shows the proper owner. ( the guy doing the restoration)
 
Tom-D said:
This is not to say you can't use Salvage yard parts to rebuild your aircraft.
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Agree 100%. There's really nothing new here. The Order simply clarified existing guidance and put it in a more useful document. Hopefully, this will give notice to those who caused the problems in the first place. But I doubt it as long as there is a buck to made.
 
Clip4 said:
Since an aircraft requiring major repair has always been in their lane, they are just clarifying a few things for those who think their britches are bigger than the FAA’s.
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Keeping things safe is, they are now overstepping.

If the plane can be rebuilt to a safe and airworthy spec, it shouldn’t matter.
 
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Bell206 said:
Agree 100%. There's really nothing new here. The Order simply clarified existing guidance and put it in a more useful document. Hopefully, this will give notice to those who caused the problems in the first place. But I doubt it as long as there is a buck to made.
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It does say something that might be new, but I'm not an expert on this.

The order says if all primary structures of the aircraft need to be replaced, it's not repairable. Let's say, for example, a Super Cub goes down in treed terrain, and it's a mess. A replacement PMA fuselage can be bought, and new wings and empennage can be built. The order says that airplane is destroyed and cannot be repaired.

The primary structure must be identifiable and traceable to the particular aircraft. For example, maintenance personnel can repair a heavily damaged aircraft by performing many major repairs on its fuselage and replacing all other primary structures that may be destroyed such as the wings and the empennage.

In this case, the aircraft would not be considered destroyed because the fuselage is repairable. However, if the fuselage of that aircraft also needed to be replaced, then the aircraft would no longer be considered repairable as all of its primary structures were beyond repair and hence destroyed.

e. The following examples can be used as guidelines to determine if an aircraft is destroyed:

(1) All primary structures of an airplane or glider, including the fuselage, all wings, and empennage are beyond repair.

(2) The fuselage and tail boom of a rotorcraft are beyond repair.

(3) Only the aircraft identification plate is reusable.
 
I’d wager the only outcome will be less reported accidents
 
3393RP said:
It does say something that might be new
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No. It restates existing guidance.
3393RP said:
The order says if all primary structures of the aircraft need to be replaced, it's not repairable
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Define "primary structures." You can repair/rebuild a wing with the original wing root rib/attach fittings. You can repair/rebuild a Bell 47 helicopter with an original center frame tube cluster provided the data tag and AWC are intact to that cluster.
3393RP said:
(3) Only the aircraft identification plate is reusable.
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This basically sums up a "destroyed" aircraft. When you don't have a single primary structure to repair, i.e., only a data plate, then it is considered "manufacturing" an aircraft which is the regulatory power behind the violation.

The main issue that led to this is some people have sold parts or sold data tags with no traceability from aircraft like this:
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Versus aircraft like this:
aircraft_accident_investigation_01.jpg
 
James331 said:
I’d wager the only outcome will be less reported accidents
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Doubtful. This topic is over 40 years old. Hopefully the only outcome will be those who still feel it's more important to make a buck over airworthiness will be shot at the point of sale.
 
Bell206 said:
Doubtful. This topic is over 40 years old. Hopefully the only outcome will be those who still feel it's more important to make a buck over airworthiness will be shot at the point of sale.
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So all those PA18 and warbird, DHC2 etc major rebuilds are not airworthy?

That’s going to be news to lots of folks
 
I believe the more pertinent question is this.
we all know structure can be repaired, but how much can you call structure?
Can you take the little tube that the data tag for a supercub is attached to and use It?
Are you required to use the door post of the Cessna?

The Fairchild 24 over the years and a multitude of restorations has the data tag attached to many places, so what part is structure? The data tag was never attached to the tubular frame.
 
Tom-D said:
I believe the more pertinent question is this.
we all know structure can be repaired, but how much can you call structure?
Can you take the little tube that the data tag for a supercub is attached to and use It?
Are you required to use the door post of the Cessna?

The Fairchild 24 over the years and a multitude of restorations has the data tag attached to many places, so what part is structure? The data tag was never attached to the tubular frame.
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The proof of the pudding and all
 
I think it will be a cold day in hell when the FAA can tell how much of the basic aircraft was used in the repair of the aircraft.
Speciality with EA/B
 

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Read the document. There's nothing to fear. Except internet rhetoric from a bunch of guys who get excited and start responding to things that aren't there.
 
Tom-D said:
I think it will be a cold day in hell when the FAA can tell how much of the basic aircraft was used in the repair of the aircraft.
Speciality with EA/B
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I think the more relevant point for this thread is that those repairs might never be done because an FAA employee determined a damaged aircraft was "destroyed" and it was forcefully de-registered.

I'm not an excited internet guy. My original post was an inquiry, asking if the verbiage about damage to "primary structures" was something new. Bell206 says it's not, and based on his position in the industry, I presume he is correct.
 
Well, this part needs to be changed.
I rebuilt a damaged aircraft (a ground-looped C140) and during the process, a previous owner managed to convince the FAA it was destroyed, long after he owned it. He was not the immediately previous owner, but the one before that - ie two owners ago!
I found out when I applied for a new airworthiness certificate (it was tattered). This was 20 years ago so maybe things have changed.
I think he was hoping to avoid liability, which is silly.
The FAA could easily have looked me up and asked about the airplane.
(their dispute system worked but I should not have had to go through that)

c. 14 CFR § 47.41(b)(2) does not specify who makes the determination that an aircraft is destroyed or scrapped. Typically, a knowledgeable party makes such a determination with the concurrence of the registered owner.
 
Thing is, with a data plate and airworthiness certificate no airplane is truly destroyed if someone wants to throw a lot of money at it.
 
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