Completing kits for others.

GlennAB1 said:
And you are required to certify it to a standard annually.
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When you sign off the conditional inspection you are stating that the aircraft meets its letter of limitations or its properly altered condition.
 
Tom-D said:
FTFY because I am not considered a Commercial aircraft building facility. I do not manufacture parts for kits. I can add professional assistance, just as any other person.
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You can be a Pro, an amateur, a Commercial aircraft building facility or a man from Mars. You can add professional assistance, crummy amateur assistance or just plain assistance. If you're paid, it doesn't count as part of the 51% required to be an E/AB. If you're not paid, compensated, or any synonym you might choose, it does. This is not hard and no, I don't care to continue to quote the AC or any other source that has been listed numerous times in this thread.

Cheers
 
X3 Skier said:
You can be a Pro, an amateur, a Commercial aircraft building facility or a man from Mars. You can add professional assistance, crummy amateur assistance or just plain assistance. If you're paid, it doesn't count as part of the 51% required to be an E/AB. If you're not paid, compensated, or any synonym you might choose, it does. This is not hard and no, I don't care to continue to quote the AC or any other source that has been listed numerous times in this thread.

Cheers
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I still believe you misread the rule. because the FAA inspectors and the DARs don't treat X/ABs in field that way.
 
Tom-D said:
I still believe you misread the rule. because the FAA inspectors and the DARs don't treat X/ABs in field that way.
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It's hard to misread black and white type. If you can provide clear example(s) of FAA Inspectors and DAR's not following the rule, it doesn't change the rule. If you want to run a business based on the "rule enforcers" not following the rules, be my guest. I wouldn't be a customer, just like I wouldn't buy a TV "that fell off a truck" but that's just me.

Cheer
 
Tom-D said:
When you sign off the conditional inspection you are stating that the aircraft meets its letter of limitations or its properly altered condition.
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According to the EAA: "Condition inspections shall be recorded in the aircraft maintenance records showing the following or a similarly worded statement: "I certify that this aircraft has been inspected on (insert date) in accordance with the scope and detail of appendix D to part 43 and found to be in a condition for safe operation."
 
Tom-D said:
When you sign off the conditional inspection you are stating that the aircraft meets its letter of limitations or its properly altered condition.
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GlennAB1 said:
Do you not reference part 43 in the annual condition inspection sign off? And did the FAA not refer to part 43 as standard?
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This is the exact standard OPLIM wording out of 8130 and is what my own OPLIMs state:
(22) No person must operate this aircraft unless within the preceding 12 calendar
months it has had a condition inspection performed in accordance with the scope and detail of
14 CFR part 43, appendix D, or other FAA-approved programs, and was found to be in a
condition for safe operation. As part of the condition inspection, cockpit instruments must be
appropriately marked and needed placards installed in accordance with 14 CFR § 91.9. In
addition, system-essential controls must be in good condition, securely mounted, clearly marked,
and provide for ease of operation. This inspection will be recorded in the aircraft logbook and
maintenance records.
(23) Condition inspections must be recorded in the aircraft logbook and maintenance
records showing the following, or a similarly worded, statement: “I certify that this aircraft
has been inspected on [insert date] in accordance with the scope and detail of
14 CFR part 43, appendix D, and was found to be in a condition for safe operation.” The
entry will include the aircraft’s total time-in-service (cycles if appropriate), and the name,
signature, certificate number, and type of certificate held by the person performing the
inspection.

Again the inspection is conducted with scope and detail of part 43, but not under part 43 or verbatim IAW part 43. That gives some leeway in how and what is inspected. The only other 2 paragraphs out of 28 total that impact maintance/inspections are these:

(8) After completion of phase I flight testing, unless appropriately equipped for night
and/or instrument flight in accordance with 14 CFR § 91.205, this aircraft is to be operated under
VFR, day only.
(9) Aircraft instruments and equipment installed and used under 14 CFR § 91.205 must
be inspected and maintained in accordance with the requirements of 14 CFR part 91. Any
maintenance or inspection of this equipment must be recorded in the aircraft logbook and
maintenance records.

And of course this one on who can do the inspections:
(26) An experimental aircraft builder certificated as a repairman for this aircraft under
14 CFR § 65.104 or an appropriately rated FAA-certificated mechanic may perform the
condition inspection required by these operating limitations.

So conforming to the OPLIMS can be as easy or complex as you want to make it.
 
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tsts4 said:
This is the exact standard OPLIM wording out of 8130 and is what my own OPLIMs state:
So conforming to the OPLIMS can be as easy or complex as you want to make it.
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Care to tell us when your letter was issued?
 
Tom-D said:
Care to tell us when your letter was issued?
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2015, but IIRC the wording hasn't changed much if at all since the late 1990s. Now what I haven't seen is a copy of the newest OPLIMS issued under the latest change to 8130.2H, but after reading the change, I think the OPLIM wording should be roughly the same.
 
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tsts4 said:
2015, but IIRC the wording hasn't changed much if at all since the late 1990s. Now what I haven't seen is a copy of the newest OPLIMS issued under the latest change to 8130.2H, but after reading the change, I think the OPLIM wording should be roughly the same.
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The sheet I'm looking at says 1981, no mention of the FAR 43-D
 
tsts4 said:
Again the inspection is conducted with scope and detail of part 43, but not under part 43 or verbatim IAW part 43. That gives some leeway in how and what is inspected.
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Bologna!

"inspected on [insert date] in accordance with the scope and detail of part 43, appendix D" ... leaves no leeway.
 
GlennAB1 said:
Bologna!

"inspected on [insert date] in accordance with the scope and detail of part 43, appendix D" ... leaves no leeway.
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FAR 43-D starts with the statement :

Appendix D to Part 43—Scope and Detail of Items (as Applicable to the Particular Aircraft) To Be Included in Annual and 100-Hour Inspections

So I believe -D does give quite a bit of leeway.
Plus the FAA believes this list is a minimum for a annual/ 100 hour/conditional inspection
 
Tom-D said:
(as Applicable to the Particular Aircraft)
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That doesn't give leeway.

Leeway means: Freedom, flexibility, liberty, latitude.

"As applicable to the particular aircraft" is still well defined.

And the -D list being a "minimum" (as you said) requirement, there really is no leeway.
Thank you, Tom.
 
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GlennAB1 said:
That doesn't give leeway.

Leeway means: Freedom, flexibility, liberty, latitude.

"As applicable to the particular aircraft" is still well defined.

And the -D list being a "minimum" (as you said) requirement, there really is no leeway.
Thank you, Tom.
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Again, Part 43 doesn't apply to E-AB aircraft. The OPLIMs make it a guide by saying conduct the condition inspection in scope and detail of annex D but it doesn't say follow Annex D verbatim. In fact the latest version of 8130.2H adds even more flexibility by addiing "manufacturer or other FAA-approved programs" to the condition inspection verbiage. That means if the kit manufacturer has an inspection checklist/program you can use that in lieu of part 43 Annex D and change the wording on the log entry to state you did the inspection IAW the scope and detail of the checklist and found the aircraft in a safe condition for operation vs scope and detail of part 43 Annex D.
 
Re: manufacturer condition inspection lists. With respect to my plane I am the manufacturer. The condition inspection list will be based from standard practices (duh!) but will include other items that I'll add based upon what I've seen and dealt with during construction. I'll likely get my repairman cert for the plane but will also hire a pro for some parts of my inspections. I believe that's a common approach.
 
tsts4 said:
Again, Part 43 doesn't apply to E-AB aircraft. The OPLIMs make it a guide by saying conduct the condition inspection in scope and detail of annex D but it doesn't say follow Annex D verbatim. In fact the latest version of 8130.2H adds even more flexibility by addiing "manufacturer or other FAA-approved programs" to the condition inspection verbiage. That means if the kit manufacturer has an inspection checklist/program you can use that in lieu of part 43 Annex D and change the wording on the log entry to state you did the inspection IAW the scope and detail of the checklist and found the aircraft in a safe condition for operation vs scope and detail of part 43 Annex D.
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I'd agree when the kit's manufacturer added the appropriate items from the list given in -D.
Other than that, I don't believe you read the rule in the same light as the FAA.

Just My Opinion.
 
Stewartb said:
Re: manufacturer condition inspection lists. With respect to my plane I am the manufacturer. The condition inspection list will be based from standard practices (duh!) but will include other items that I'll add based upon what I've seen and dealt with during construction. I'll likely get my repairman cert for the plane but will also hire a pro for some parts of my inspections. I believe that's a common approach.
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This may be true, but when you want a airworthiness certificate you will accept the requirements of the FAA. Those requirements and conditions are included in the OPLIMs.
 
Tom-D said:
I'd agree when the kit's manufacturer added the appropriate items from the list given in -D.
Other than that, I don't believe you read the rule in the same light as the FAA.

Just My Opinion.
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The Kit manufacturer has nothing to do with it. only the faa and the aircraft manufacture, which is the listed builder, has anything to do with it. The kit manufacture cannot REQUIRE anything.

Bob
 
unsafervguy said:
The Kit manufacturer has nothing to do with it. only the faa and the aircraft manufacture, which is the listed builder, has anything to do with it. The kit manufacture cannot REQUIRE anything.

Bob
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My advice would be, to read the Operation limitation letter from the FAA, the kit manufacturer suggested list, your common shop practices, then decide what is regulatory in nature.
 
So how is this different from me acting as the general contractor to build a custom home for my family and hiring sub contractors to do all the work? For the record, i work in IT not construction. Is my new home amateur built?
 
sferguson524 said:
So how is this different from me acting as the general contractor to build a custom home for my family and hiring sub contractors to do all the work? For the record, i work in IT not construction. Is my new home amateur built?
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The difference is you are not dealing with the FAA :)
 
sferguson524 said:
True that.. Forgot the tongue in cheek smiley on my post :)
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To be true, the theory is the same, but the FAA has rules apparently no one follows. as where your building inspector will enforce the building codes.
 
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