FAA shut down my 3M aircraft graphic film.

Discussion in 'Maintenance Bay' started by John Richardson, Sep 12, 2019.

  1. John Richardson

    John Richardson Filing Flight Plan

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    I tried to use 3M aircraft graphic film on my certificated airplane to replace the stripes on the fuselage. The FAA shut me down and referred me to a memorandum from 2012 which prohibits field approval of “Vinyl Shrink Wrap”, and requires an STC. (Easy to find via Google search)

    Has anyone else had this experience?
     
  2. James331

    James331 Touchdown! Greaser!

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    lol. its the FAA, welcome to clown world

    Guess like 75% of the vinyl N numbers all the planes have should have a STC on file too eh?
     
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  3. DaleB

    DaleB En-Route

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    Point out that the film does in fact not shrink, therefore it is not “vinyl shrink wrap”.
     
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  4. John Richardson

    John Richardson Filing Flight Plan

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    Yep, I plan to argue that very point, thx.
     
  5. SCCutler

    SCCutler Administrator Management Council Member PoA Supporter

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    What were the circumstances? Did an FAA guy or gal actually initiate a contact for the purpose of telling you your film was verboten?
     
  6. John Richardson

    John Richardson Filing Flight Plan

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    My AI saw the installers applying the film and called the regional FAA office to inquire about its use. They wouldn’t approve it and arbitrarily considered it “heat shrink vinyl wrap”, whatever that is.
     
  7. Capt. Geoffrey Thorpe

    Capt. Geoffrey Thorpe Touchdown! Greaser! PoA Supporter

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    Time for a new AI.

    "We have met the enemy and he is us." Pogo
     
  8. SCCutler

    SCCutler Administrator Management Council Member PoA Supporter

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    That is... disappointing.

    Did you ask the IA’s opinion?
     
  9. frfly172

    frfly172 Touchdown! Greaser! PoA Supporter

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    And who is your new AI ? Vinyl heat shrink is used to shrink wrap boats and other toys for storage.
     
  10. bnt83

    bnt83 Final Approach PoA Supporter

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    LOL! That basically what the product knows as Prop Guard is. Not only that but it is STCed and the STC certificate says right on it "minor alteration"
     
  11. flyingron

    flyingron Touchdown! Greaser!

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    There's also the 3M leading edge tape. I've used that as 200MPH tape in a number of places (water leaks on the windows mostly).
     
  12. Jim K

    Jim K Pre-Flight

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    So if wrapping an airplane is prohibited, how does the mzeroa guy get away with it? He openly says it's a "wrap".
    download.jpeg
     
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  13. James331

    James331 Touchdown! Greaser!

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    Wow!
    I’d fire his ass and make sure EVERYONE knows that he was not only wrong about your stripes, but falsely rats out his own customers to the FAA.
     
  14. EppyGA

    EppyGA Touchdown! Greaser!

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    Minor nit pick, it's IA
     
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  15. EppyGA

    EppyGA Touchdown! Greaser!

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    BTW, who's your new IA.
     
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  16. Ravioli

    Ravioli Final Approach

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    Maybe he really meant Artificial Intelligence? ;)
     
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  17. EppyGA

    EppyGA Touchdown! Greaser!

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    He was talking about the FAA
     
  18. Bell206

    Bell206 Pattern Altitude

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    Sounds like a communication problem between your IA and the ASI. There are "certified shrink wrap aircraft systems" out there but they replace an entire aircraft fabric covering not accent stripes. They've been using vinyl decals for N numbers and accent striping/graphics on aircraft for years all with the FAA's blessing. I believe there is an AC that mentions decals for N numbers. Some decal installs actually fall under Part 43 preventative maintenance which allows a pilot to legally install them on a certified aircraft. Good luck.
     
  19. bradg33

    bradg33 Cleared for Takeoff

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    So people can actually read it for themselves, the referenced memo is located on Page 67 of the PDF linked below. A careful read reveals that it only purports to apply to "Part 23" airplanes. Many of our aircraft, including for example the Bonanza, are CAR3 airplanes. Read into that what you will.

    http://fsims.faa.gov/wdocs/Other/Major_Repair_Alteration_Job-Aid R5.pdf
     
  20. Salty

    Salty En-Route PoA Supporter

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    I don't know if this is true, but since a lot of the more senior guys I hang with say AI, I have been going under the assumption that it changed at some point in the past.
     
  21. Bell206

    Bell206 Pattern Altitude

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    FYI: the key part of the memo:
    Summary
    This memorandum replaces the July 26, 2012 memorandum of the same title and provides a means of approving by Federal Aviation Administration (FAA) Type Certificate (TC), Amended Type Certificate (ATC), and Supplemental Type Certificate (STC) for the installation of vinyl covering shrink wraps on the exteriors of parl 23 airplanes, gliders, and airships. Installation of only decals and logos in limited areas of the fuselage or empennage is not subject to this memorandum.
     
  22. Bell206

    Bell206 Pattern Altitude

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    It's my understanding back in the CAA days when aircraft required a true annual inspection and new AWC issue, the non-CAA people authorized to do that inspection where "designated aircraft inspectors" or something similar. I believe it was common to call them "authorized inspectors" or AIs. Due to some liability issues, sometime prior to the formation of the FAA in 1957 the original annual inspection/AWC issuance was dropped as were the AIs. In their place came Inspection Authorizations (IA) and the old "periodic inspection" became what is now known as an "annual inspection." There's a FAA booklet somewhere that gives this history but I could not find it.
     
    Last edited: Sep 13, 2019
  23. donjohnston

    donjohnston Line Up and Wait

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    It's possible that the IA did this on his own. Or it could be that the owner asked the IA to look into it.
     
  24. hindsight2020

    hindsight2020 En-Route

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    This is why we can't have nice things. Oh, and the road to hell is paved with good intentions. I can't wait to downgrade to an RV. These anecdotes just continue to sour my appeal for continued participation in the certified ownership game, especially as a pro pilot that sees how the sausage is made and understands the full economic and technological distinction between a revenue service airliner and a 1,700 lb direct link control kite for recreation. The CAR3/Part23 FAA pantomime is getting insufferable.
     
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  25. JOhnH

    JOhnH Touchdown! Greaser! PoA Supporter

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    If those "more senior guys" are my age or older, they are probably just getting senile.
     
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  26. John Richardson

    John Richardson Filing Flight Plan

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    You are correct sir! I'm a new pilot just learning all the acronyms.
     
  27. John Richardson

    John Richardson Filing Flight Plan

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    I'm the owner. I had already looked into it before hiring a graphics shop and didn't see a problem in the FARs. (The memo is well-hidden, so I was going by FARs only). Plus, I saw that the practice is very common, even on commercial aircraft. My IA/AI is also my hangar neighbor, so he saw the work going on and started inquiring. He called regional to get a "field approval", but the "field approval" guy referred us to the memo. Sigh.
     
  28. John Richardson

    John Richardson Filing Flight Plan

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    Very well said.
     
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  29. Bell206

    Bell206 Pattern Altitude

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    As an A&P, perhaps have your IA look at the last sentence in the memo summary paragraph again. It pretty much states what you are doing is exempt from the memo as highlighted in post 22. I've signed off a number of vinyl decal installs with no issues.
     
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  30. MauleSkinner

    MauleSkinner Final Approach

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    So the guy who signs my logbooks is known as an Inspection Authorization? :rolleyes:

    I would say he’s an A&P who has an IA. He could also be called an AI, but calling him an IA would be grammatically incorrect.
     
  31. denverpilot

    denverpilot Tied Down

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    When one or the other has their head squarely up and locked it either muffled what’s being said or blocks the ears. LOL.

    Because FAA consistency and “safety”! LOL

    Is there some special magic that makes it worthy of the memo on one Skyhawk and not another?

    LOL.
     
  32. JOhnH

    JOhnH Touchdown! Greaser! PoA Supporter

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    So you would call him an "Authorization Inspection"? Sounds pretty grammatically challenged to me.
     
  33. John Richardson

    John Richardson Filing Flight Plan

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    Are you saying this 3M product is STCed? If so, where do you find that information?
     
  34. John Richardson

    John Richardson Filing Flight Plan

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    I did point this out to him. His response is that his hands are tied since the FSDO won't do a field approval.
     
  35. JAWS

    JAWS Line Up and Wait

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    If all the OP is doing is adding stripes on the fuselage, have at it. The memo is explicit in that. Don't cover static openings, use it on a flight control, make sure all required placards are still there, etc. The M0A 172 is fine.

    If you want to fully wrap a wing or fuselage, that is very different.
     
  36. Kenny Phillips

    Kenny Phillips Pattern Altitude

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    Hey, it's no stupider than PIN number or HIV virus. There really is no term for A&Ps with inspection authorization, but they've been called "IA" for the decades that I've been flying.
     
  37. Kenny Phillips

    Kenny Phillips Pattern Altitude

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    And I'm pretty sure that the FAA was thinking about wing and fuselage coverings over a bare framework, not over existing aluminium. But whomever wrote the regulation was a civil servant, so there ya go.
     
  38. Bell206

    Bell206 Pattern Altitude

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    FWIW: No field approval needed. Only a simple logbook entry. But it's his certificate, his decision. However, just for reference, provided you don't need to disassemble any items on your aircraft to install these stripes and the total weight of these striping decals is less than 1lb, you could actually install them yourself as a pilot/owner per Part 43 Appendix A(c)(9) as preventative maintenance. And legally sign it off in the logbook. Unfortunately, if this is the IA who also performs your annuals then he may not be willing to sign your next annual.
     
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  39. Tarheelpilot

    Tarheelpilot En-Route

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    Why is a field approval required?
     
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  40. schmookeeg

    schmookeeg Cleared for Takeoff

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    Thank ye, O administrator, for saving us from the scourge of the vinyl sticker