Any MX here sign off an owner produced part?

pfarber

pfarber

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pfarber
Did you require drawings/material sheets etc ?

What was your process to be convinced that its good enough to sign off the repair? Is there a limit you would put on the number of owner produced parts installed on a single airframe?
 
pfarber said:
Did you require drawings/material sheets etc ?
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Depends on how and under what data the owner used to produce the part. In some cases, yes.

pfarber said:
What was your process to be convinced that its good enough to sign off the repair?
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The owner part is a separate issue from the repair. You need to ensure the owner part conforms to its approved data first, then with that completed, you would sign the repair or alteration off as any other repair/alteration.

pfarber said:
Is there a limit you would put on the number of owner produced parts installed on a single airframe?
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No.
 
Bell206 said:
Depends on how and under what data the owner used to produce the part. In some cases, yes.


The owner part is a separate issue from the repair. You need to ensure the owner part conforms to its approved data first, then with that completed, you would sign the repair or alteration off as any other repair/alteration.


No.
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this is a gray area I'm trying to flesh out. what is approved data if they don't have a manufacturer drawing.? just a metallurgical report? My understanding is that they need to replicate the part exactly as the certificated part was made.
I believe the FAA uses phrases like comparable and airworthiness and construction, but that to me isn't the same thing as a duplicate of the part
 
I’ve done this as an owner and had one A&P sign off on the production, and another on the install/repair. In my case it was a complex shaped baffle (multiple curves and bends). From what I learned, it’s very case by case specific - the cases being the part, the monkey (me), and the A&P.

You might have some additional input and help from POA A&Ps if you can explain what you’re trying to replicate - they should be able to tell you if it’s 9 out of 10 A&Ps or 1 out of 10 that would agree to sign off.

Good luck. It’s fun and rewarding to be able to do this under the rules.
 
pfarber said:
this is a gray area I'm trying to flesh out.
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Its not really as gray as you think. Get yourself a copy of FAA Bill O'brien's article on owner parts along with the 1993 FAA memo that detailed the owner part process. Review both together and you'll find the process is more black and white than gray.

pfarber said:
what is approved data if they don't have a manufacturer drawing.?
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If the OEM approved data is not available, you can duplicate that part and get that process approved via a field approval or DER 8110-3. I've used both but tended to use the 8110 route as I knew a number of DERs who gave me a good rate. The bottom line is when that part is installed the aircraft conforms to its type design (ie, approved data).
 
My logbook shows that I fabricated the bracket under FAR 21.303(b) and I signed my logbook as such. Then one of my mechanics signed off that they inspected and installed it. Just to clarify and admit that my memory failed me.

And thank you to one of our esteemed POA A&P/IAs for pointing this out to me:

An A&P cannot produce a part nor sign off its approval under Part 21.9(a)(5).

However, they can fabricate a part for consumption in a repair or alteration under Part 43 per Part 21.9(a)(6).

I was coached that details matter as they are two separate and very distinct tasks each with their own separate guidance.

Sorry for the confusion.
 
455 Bravo Uniform said:
I’ve done this as an owner and had one A&P sign off on the production, and another on the install/repair. In my case it was a complex shaped baffle (multiple curves and bends). From what I learned, it’s very case by case specific - the cases being the part, the monkey (me), and the A&P.

You might have some additional input and help from POA A&Ps if you can explain what you’re trying to replicate - they should be able to tell you if it’s 9 out of 10 A&Ps or 1 out of 10 that would agree to sign off.

Good luck. It’s fun and rewarding to be able to do this under the rules.
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I am the MX (it seems that most of the replies are not from certificated mechanics) and I have been approached regarding a 150 wing. Seems that there are some brackets that need replacement and owner has asked me to install and sign off the O.P.P.

My first reaction was to tell them to buy them or get them from salvage but they already made them and want me to install and sign off. I can do the installation quite easily but not sure about the OPP being the same as the original. He had a
rotted out original and made it from 2024T3 but other than that has no other data.
 
pfarber said:
He had a
rotted out original and made it from 2024T3 but other than that has no other data.
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With sheetmetal repairs, a mechanic can fabricate certain parts for consumption in a repair per 21.9(a)(6). Most mechanics to include myself will use that vs an owner part as it gives more flexibility and keeps everything under the mechanics control. There is an AC which gives details.
 
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