Field Approval or Minor Mod?

S

Scott MacKie

Pre-Flight
Joined
Oct 24, 2020
Messages
93
Location
Woodstock, GA
Display Name
Display name:
sbmackie
Nope. Their literature is pretty clear. NOT APPROVED FOR INSTALLATION ON CERTIFIED AIRCRAFT and Not FAA/PMA Approved.

You need an STC’d product.
 
Last edited:
Scott MacKie said:
Do these require a field approval, or can I or my A and P install them as a minor mod?
Click to expand...
It would depend on how your AP determines the install whether it is a minor or major alteration. Position/strobe/beacon lights have some additional guidance to work around depending on year of mfg vs say a landing light.
Scott MacKie said:
Really, really tired of strobe whine and power sucking incandescent bulbs in my oldie but goodie generator equipped Mighty Pacer.
Click to expand...
FYI: the strobe light whine can usually be corrected. But also keep in mind all LEDs are not created equal and can cause their own RF interference. However, I haven't heard of any issues with Aerolites when installed in aircraft with a serviceable electrical system
 
Bell206 said:
It would depend on how your AP determines the install whether it is a minor or major alteration. Position/strobe/beacon lights have some additional guidance to work around depending on year of mfg vs say a landing light.

FYI: the strobe light whine can usually be corrected. But also keep in mind all LEDs are not created equal and can cause their own RF interference. However, I haven't heard of any issues with Aerolites when installed in aircraft with a serviceable electrical system[/QUOTE
Click to expand...

Thanks. Loooked at part 43 definitions and appropriate appendices. It seems that, yes, an owner can do bulbs...but not mess with the electrical system. So, the A and P determines whether pulling out the heavy, noisy, 30 year old strobe system, and installing the Aero Lites using existing wireing and mounts is a major or minor alteration, and proceeds accordingly (major requireing FAA blessing, minor not?)

Does this also apply to radios? I.e, I can plug and play a non approved radio, but an A and P would determine if a new tray is required whether it's major or minor, and thus would/would not need an 'approved' radio?
Thanks
 
Scott MacKie said:
Does this also apply to radios? I.e, I can plug and play a non approved radio,
Click to expand...
Scott MacKie said:
but an A and P would determine if a new tray is required whether it's major or minor, and thus would/would not need an 'approved' radio?
Click to expand...
These are 2 separate maintenance tasks. What you can do as a pilot under prevent mx is listed in Part 43 Appx A(c). Paragraph 31 of that sub-section lists sliding out devices. But before you can slide the radio out, your APIAs would have to install the radio and complete the paperwork before you could legally slide the radio out under prevent mx. If that makes sense to you.
 
Clip4 said:
Nope. Their literature is pretty clear. NOT APPROVED FOR INSTALLATION ON CERTIFIED AIRCRAFT and Not FAA/PMA Approved.

You need an STC’d product.
Click to expand...

here we go again, WRONG. an STC is not required. however, in the case of nav lights they must MEET the requirements of TSO-C30B. MEET, not BE TSOed.

a manufacture can put what ever they want in there ads, does not make it law.

an interesting spin is that because of how the experimental op limits are written, even EAB aircraft lighting must meet the TSO. in the aeroled ad i cannot find any claim that they meet the TSO, so they really cannot even be installed on an EAB.
 
Is there a manufacturer of LED's that meet the requirments, but are not officially TSO'd, PMA'd, etc? The cost difference is astronomical.
 
Aeroflash Tip Strobe/nav lights and Flight Strobe FS4400? are units that were

PMA and were STC’d ONLY for certain Cessnas.

I did obtain FA’s for both units on Cherokees.

The Aeroflash units may now be STC’d based on that approval.

It seems fed policy on some type of installs varies with the season.

I would rather do an unneeded 337 than be told later there should have been one.
 
unsafervguy said:
an interesting spin is that because of how the experimental op limits are written, even EAB aircraft lighting must meet the TSO. in the aeroled ad i cannot find any claim that they meet the TSO, so they really cannot even be installed on an EAB.
Click to expand...
They can be installed on an EAB, but only "to aid daytime visibility" (wink wink nudge); with them the aircraft legally can't fly at night.
 
unsafervguy said:
hey must MEET the requirements of TSO-C30B
Click to expand...
Curious. Do you have a reference for this? I don't recall this. As I mentioned above position/strobe requirements are a moving target depending on year of certification which usually was based on lumen/candela and field of view. And while 91.205 states “approved” or equivalent it is a rather broad statement that can have various meanings. Would be nice to get away from the current goat-rope and have a single reference for all aircraft.
unsafervguy said:
even EAB aircraft lighting must meet the TSO.
Click to expand...
I’m familiar with an LOI for the E/AB side but don’t recall it mentioning the TSO reference.
 
I “don’t” have these bulbs “installed” on my plane. I “did” replace my incandescent bulbs with a 4509 replacement that look remarkably “similar” and happen to draw less amps and are brighter.

OK you got me. My IA couldn’t care less that I am trying to be safer both at night and during the day. We now leave both NAV and taxi and landing lights on all the time since they will never burn out and are super bright. Have not done the beacon yet, however. Several hundred hours later, they are still working fine and we would have otherwise burned through many incandescent bulbs and maybe an alternator.
 
Scott MacKie said:
Do these require a field approval, or can I or my A and P install them as a minor mod?

https://www.aero-lites.com/evolution-wingtip-nav-strobe-assemb

https://www.aero-lites.com/navmax-product-info

https://www.aero-lites.com/par36-plus

Really, really tired of strobe whine and power sucking incandescent bulbs in my oldie but goodie generator equipped Mighty Pacer.

View attachment 101806
Click to expand...

There are at least three 337’s approved by the FAA for the Aero-Lites. All FSDO dependent of course. Everyone seems to have a different FAR interpretation with these lights.

Some believe that position lights fall under the “Standard Part” definition. https://www.faa.gov/aircraft/safety/programs/sups/standard_parts/media/standard_parts.pdf

I’ve never seen a Sylvana or GE PAR bulb that said FAA PME approved. This is because they’re a standard part. They don’t sell the light in my original IP for my plane. The replacement is a GE light, but it’s a Sylvana listed in the IPC. The GE is somehow some magical replacement.

It’s my understanding that the Aero-light has to be plug and play without any alteration required. I showed a DAR the lights and data of the other 337’s. He said he would not have a problem replacing them as pilot preventative mtx using the “standard part” definition and then make a logbook entry with the light replacement details such as the make and model of the Aero-LED light.

He said there must be data on the light in your plane to determine no interference or draw issues. A volt/amp meter can provide this data.

There is also plenty of data on the Aero-Lites with the three 337’s already approved by the Great Lakes FSDO and Phoenix FSDO. The 337’s used to be under”Resources” on the Aero-Lites website.


Sent from my iPhone using Tapatalk
 
From FAA order 8300.16:

10. Commercial Off-the-Shelf (COTS) and Other Articles Not Produced Under § 21.9.
a. COTS Articles. COTS refers to articles that have been developed for sale to the general public. For the purposes of this order, both COTS and articles not produced under § 21.9 are addressed in the same manner. Installation of such articles can be approved but requires an evaluation based on their intended functions and failure modes and effects. In addition, such articles installed for “situational awareness” or as a supplemental system may be acceptable provided they do not interfere with or displace required equipment, or otherwise interfere with the safe operation and airworthiness of the aircraft.
 
unsafervguy said:
here we go again, WRONG. an STC is not required. however, in the case of nav lights they must MEET the requirements of TSO-C30B. MEET, not BE TSOed.

a manufacture can put what ever they want in there ads, does not make it law.

an interesting spin is that because of how the experimental op limits are written, even EAB aircraft lighting must meet the TSO. in the aeroled ad i cannot find any claim that they meet the TSO, so they really cannot even be installed on an EAB.
Click to expand...

Whole lot easier with a TSO.
 
Bell206 said:
Curious. Do you have a reference for this? I don't recall this. As I mentioned above position/strobe requirements are a moving target depending on year of certification which usually was based on lumen/candela and field of view. And while 91.205 states “approved” or equivalent it is a rather broad statement that can have various meanings. Would be nice to get away from the current goat-rope and have a single reference for all aircraft.

I’m familiar with an LOI for the E/AB side but don’t recall it mentioning the TSO reference.
Click to expand...
It’s in the op specs issued for the aircraft, they states that for night ops lt must be equipped and maintained as per 91.205.
 
I am still going with the "standard part" replacement. If the GE bulb is not TSO, then neither does a modern replacement bulb have to be TSO. One lasts longer, draws many fewer amps, protects the wiring, alternator, and battery from being overloaded, can be left on all the time during the day, will not burn out just as you get on short final, etc. Seems like a clear case that the LED is safer and therefore should fall under the FAA's (supposed) policy of actually trying to make flying safer. Let them throw the book at a pilot for making his plane safer.
Go ahead and argue, just like you can argue about my experimental GTR-200 in my Cessna (which is also much safer than having the old and sometime faulty Narco - which is apparently 100% OK even if the ATC folks couldn't hear me well during an emergency).
 
Clip4 said:
Whole lot easier with a TSO.
Click to expand...
Not really. A TSO doesn't provide an installation approval so the installer is still held accountable for the installation same as with a non-TSO part when installed as a minor alteration. Adding the Aero-Lites to the mix simply requires the installer to determine they meet or exceed the original items under Part 43. Even if the light install is a major alteration a TSO light will still require the same field approval process as a non-TSO item.
 
Bell206 said:
Curious. Do you have a reference for this? I don't recall this. As I mentioned above position/strobe requirements are a moving target depending on year of certification which usually was based on lumen/candela and field of view. And while 91.205 states “approved” or equivalent it is a rather broad statement that can have various meanings. Would be nice to get away from the current goat-rope and have a single reference for all aircraft.

I’m familiar with an LOI for the E/AB side but don’t recall it mentioning the TSO reference.
Click to expand...
As with everything faa, nothing is really defined. As you have pointed out many times a tso is not an instillation approval. It’s a design approval, and not the only way to “approve” something. I know you know these regs but for those that have not read them, it starts with 91.205. That requires an approved lighting system and references far 23. That leads to 23.1385, which leads to 23.1387 - 23.1397. Everybody lost so far. Good.

so, the tso proves you meet the requirements of those regs.which everyone agrees that makes it an approved part, but does not approve the instillation.

The problem the faa has never defined “approved” your quote from 91.205 muddies it up more, “or equivalent” the manufacturer stating it meets the tso can arguably be defined as “equivalent” look at the dynon gps2020 as an example. It’s stated as meets tso and is approved by the faa.

Doesn’t the government make this fun.
 
unsafervguy said:
The problem the faa has never defined “approved” your quote from 91.205
Click to expand...
unsafervguy said:
Doesn’t the government make this fun.
Click to expand...
Yes it does. But because of that lack of definition, one can in certain circumstances, install a non-TSO position light as a minor alteration, which is then made whole once the installer signs the approval for return to service entry. And believe me I didn't come up with this one on my own. It would definitely simplify things if 91.205 used the same "meet the TSO" references that are used for other FAR required equipment.
 
Bell206 said:
Not really. A TSO doesn't provide an installation approval so the installer is still held accountable for the installation same as with a non-TSO part when installed as a minor alteration. Adding the Aero-Lites to the mix simply requires the installer to determine they meet or exceed the original items under Part 43. Even if the light install is a major alteration a TSO light will still require the same field approval process as a non-TSO item.
Click to expand...

I misspoke and should have said STC, but even without a TSO or PMA, the installer has a substantiate the quality of the part and good luck with that.
 
Clip4 said:
the installer has a substantiate the quality of the part and good luck with that.
Click to expand...
FYI: that happens with every item installed on an aircraft which is a subjective determination made by the installer. And whether or not a part has a STC, PMA, or TSO does not relieve the installer to "substantiate the quality of the part" per Part 43. Vendors are bound by FAR to produce approved parts for TC'd aircraft. And where vendors wish to produce unapproved parts they are bound by FAR to ensure those parts are advertised as such. APIAs are not bound by FAR to install approved parts in all circumstances. It is what it is.;)
 
And around and around we go. Signature shopping.

If this issue is so simple and easy, then let Mr Owner do it and certify it with his licence and be done. If he can't or won't, then he can buy the PMA/STC parts and get it done and move on.
 
The problem the faa has never defined “approved”..

14 CFR § 1.1 - General definitions.

Approved, unless used with reference to another person, means approved by the FAA or any person to whom the FAAhas delegated its authority in the matter concerned, or approved under the provisions of a bilateral agreement between the United States and a foreign country or jurisdiction.
 
Bell206 said:
FYI: that happens with every item installed on an aircraft which is a subjective determination made by the installer. And whether or not a part has a STC, PMA, or TSO does not relieve the installer to "substantiate the quality of the part" per Part 43. Vendors are bound by FAR to produce approved parts for TC'd aircraft. And where vendors wish to produce unapproved parts they are bound by FAR to ensure those parts are advertised as such. APIAs are not bound by FAR to install approved parts in all circumstances. It is what it is.;)
Click to expand...

I believe a parts supplier notation, “NOT APPROVED FOR INSTALLATION ON CERTIFIED AIRCRAFT” takes care of the substantiate part.
 
Clip4 said:
I believe a parts supplier notation, “NOT APPROVED FOR INSTALLATION ON CERTIFIED AIRCRAFT” takes care of the substantiate part.
Click to expand...
FYI: as I've mentioned, parts vendors have zero authority to dictate where or how their parts are installed on any aircraft. None. It all falls to the installer per Part 43. The reason most vendors state that is to not violate Part 3.
 
Clip4 said:
I believe a parts supplier notation, “NOT APPROVED FOR INSTALLATION ON CERTIFIED AIRCRAFT” takes care of the substantiate part.
Click to expand...
A parts vendor could write "Not for installation on any aircraft owned by Clip4, but everyone else can install this item". Would you have to abide by that? When put in those terms, it seems more obvious.
 
Matthew Rogers said:
A parts vendor could write "Not for installation on any aircraft owned by Clip4, but everyone else can install this item". Would you have to abide by that? When put in those terms, it seems more obvious.
Click to expand...
But that not what we are discussing here.
 
Clip4 said:
But that not what we are discussing here.
Click to expand...
How not? You were talking about what the parts supplier notates on the part and how binding that notation is to the installer of the part. If the part supplier decides to write something on a part package, what is the regulation preventing them from or requiring them to write those notations? If there is no regulation about what they write, then they could write anything they want, right or wrong. If I, myself without any PMA or STC, make a completely bogus part out of styrofoam and write "Suitable for all Certified Aircraft" (other than perhaps being fraudulent), would that absolve an A&P from checking the part for suitability?
 
Matthew Rogers said:
How not? You were talking about what the parts supplier notates on the part and how binding that notation is to the installer of the part. If the part supplier decides to write something on a part package, what is the regulation preventing them from or requiring them to write those notations? If there is no regulation about what they write, then they could write anything they want, right or wrong. If I, myself without any PMA or STC, make a completely bogus part out of styrofoam and write "Suitable for all Certified Aircraft" (other than perhaps being fraudulent), would that absolve an A&P from checking the part for suitability?
Click to expand...

We are talking about a parts supplier that is telling you they don’t want to part of the post crash lawsuit. Any AP that wants to join that lawsuit with that warning in place has a screw loose.
 
Clip4 said:
We are talking about a parts supplier that is telling you they don’t want to part of the post crash lawsuit. Any AP that wants to join that lawsuit with that warning in place has a screw loose.
Click to expand...
But they could write anything they want. Even if their part is 100% above board, they could still write that. Does it instantly make the part worthless and un-airworthy?
 
Clip4 said:
We are talking about a parts supplier that is telling you they don’t want to part of the post crash lawsuit.
Click to expand...
No. What you have is a parts suppliers telling you they are not in violation of Part 3. Sub-section (d) and Part 43 allow me as an installer to use the part regardless what the vendor states. It's nothing more than different vendors using different methods. Simple. No lawsuits required.;)





upload_2021-11-30_16-57-7.png
 
You must log in or register to reply here.
Back
Top