FAA shut down my 3M aircraft graphic film.

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

  1. kyleb

    kyleb Final Approach PoA Supporter

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    Owners are allowed to do cosmetic maintenance, such as paint. Vinyl lettering falls under the same rules.

    Whoever gave the guidance was mistaken. As another poster noted, the prohibition is intended to prevent you from recovering your Cub with shrink wrap.

    The IA needs to be re-educated.
     
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  2. schmookeeg

    schmookeeg Pattern Altitude

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    I sympathize with the IA. His daily bread can be threatened by the same government-tenured moron who gave the original absurd guidance. In addition to common sense being absent, the incentives are horribly mis-aligned. Both against the IA for exercising common sense and outing a FSDO dum-dum, and against the dum-dum who has zero incentive to say "yes" to any query, lest it make work for him, or cause him to lift a braincell incorrectly and threaten his fat pension.

    "Ask forgiveness, not permission" seems to be the remedy here. Let them officially ramp-check the vinyl if they dare. I'd print the email from the FSDO critter if you have one, affix a vinyl sticker of a giant middle finger, staple your own highlighted interpretation letter, add it to the growing box-o-docs for the plane, and fly on. :D

    $0.02
     
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  3. Capt. Geoffrey Thorpe

    Capt. Geoffrey Thorpe Touchdown! Greaser!

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    "The following are safety concerns with the installation of paint coverings that must be evaluated. by the applicant for any TC/ATC/STC application:

    1. Without proper engineering evaluation and/or tests, paint cannot be placed on any control surface or control surface tab:

    a. without consideration of the effect on the flutter characteristics (whether the surface is mass balanced or not) and

    b. where that installation would change the existing clearance between adjacent surfaces with and without loading.

    2. Scoring the skin of aircraft when cutting masking tape /sheets to fit, which can start cracks, particularly in pressurized aircraft.

    3. Blocking of fuel vents, static ports, hinges, drain holes etc., making them inoperative or changing the airflow over static po1ts.

    4. Use of aggressive solvents to apply the material. This is a concern around fuel tanks and vents, sensitive antennas, and especially on composite parts, which are susceptible to damage from solvents.

    5. Covering required exterior aircraft markings and emergency exits.

    6. Paint losing adhesion on the surface or on rotating parts and jamming control surfaces or compromising engines.

    7. Static build-up causing electrical discharges in or around fuel tanks and causing radio/navigation interference.

    8. Tinting of windows and windshields with transparent tints, which compromises the view of pilots.

    9. The impact on removal of ice build-up on critical surfaces.

    10. Flammability of the material, including lightning strikes, and especially near engine exhausts and around engine nacelles. Flammability test specimens should be built-up from the cowling/nacelle with the paint applied.

    11. Peeling of the paint from rain or hail.

    12. Masking of cracks and corrosion in structure and skin.

    13. Lifetime of a paint application. How long before mandatory removal.

    14. Effects of de-ice fluids on the paint film."
     
  4. kyleb

    kyleb Final Approach PoA Supporter

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    Nobody is applying for an STC. This is applying vinyl trim over the existing finish.
     
  5. rpadula

    rpadula En-Route

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    Maybe this is why?

     
  6. MauleSkinner

    MauleSkinner Final Approach

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    Authorized Inspector.
     
  7. C-1 PILOT

    C-1 PILOT Pre-takeoff checklist

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    Your “Guy” (Mechanic) has his Aircraft & Power-plant certificate, with Inspection Authority. He is an A&P/IA.
     
  8. John Richardson

    John Richardson Pre-Flight

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    I need to find an IA who will sign-off on the change without a field approval. My existing IA will not.
     
  9. John Richardson

    John Richardson Pre-Flight

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    I’ll be shopping for a new IA because of this.
     
  10. kyleb

    kyleb Final Approach PoA Supporter

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    I'm not an IA or A&P, but this IMO is minor maintenance that is under the purview of the owner. You don't need an IA's approval. See the "protective coatings" reference in this FAA document. In this case, protective coatings include paint and/or vinyl.

    https://www.faasafety.gov/files/gslac/library/documents/2011/Aug/56398/FAA P-8740-15 Maintenance Aspects of Owning Your Own Aircraft [hi-res] branded.pdf

    Here's AOPA's take:

    https://www.aopa.org/news-and-media/all-news/2012/june/01/answers-for-pilots-preventive-maintenance
     
  11. John Richardson

    John Richardson Pre-Flight

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    And if my decal were some random “sticker” I would tend to agree. But, it’s a 3M product specifically designed for this use and it’s used by lots of the major air carriers. It doesn’t just blow off. It’s permanent (or nearly so).
     
  12. MauleSkinner

    MauleSkinner Final Approach

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    I guess that makes me an LOA.
     
  13. Bell206

    Bell206 En-Route

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    It's a matter of opinion and I respect your IA's opinion as should you. However, getting another opinion is also equally valid. Just remember, as the aircraft owner, you are the one that bears the final regulatory authority on what happens to your aircraft. Never stop asking questions.
     
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  14. Gary Austin

    Gary Austin Pre-Flight

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    Well stated, I am an Authorized Inspector, but I hold an Inspection Authorization.
     
  15. Gary Austin

    Gary Austin Pre-Flight

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    And be cause a person can't hold an Inspection Authorization with out both the A and the P license, loose either of them and the IA goes away at the same time as the certificate that was taken, so it's redundant to say A&P/IA
     
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  16. John Richardson

    John Richardson Pre-Flight

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    Agreed. I like my IA. He’s my hangar neighbor, and has taught me a lot. I just think he missed the mark on this one. He’s in his 70s. I’ll try to persuade him. If not, time for a new IA.
     
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  17. weirdjim

    weirdjim En-Route

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    Tell that $+up!d $0n 0f @ b1+c# IA to keep his MOUTH SHUT and proceed on the authority the FAA has given him/her. Or find another IA. Quickly.

    There is NO reason for this kind of bureaucratic cr@p.

    Jim
     
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  18. James331

    James331 Ejection Handle Pulled

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    In that case you get what you deserve.

    He just straight tried to burn you, and while completely in the wrong, you’re nuts if you don’t drop this idiot like a bad habit, most folks in the industry would go scorched earth on him.

    I don’t think you fully appreciate what he knowingly just tried to do to you
     
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  19. John Richardson

    John Richardson Pre-Flight

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    May I don’t know. Please, tell me more.
     
  20. James331

    James331 Ejection Handle Pulled

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    He does not know what’s he’s taking about

    From his ignorance his reaction was to call the government and try to have them set their sights on you, this could put your certificate and plane in jeopardy.

    You really want to trust dangerous and unknowledgeable people with a plane you strap yourself and family and friends into.

    [​IMG]
     
  21. JAWS

    JAWS Cleared for Takeoff

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    So who was going to certify the work at the end of the day?

    If this is truly just adding accent stripes to a fuselage, it doesn't need formal approval other than a RTS.
     
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  22. John Richardson

    John Richardson Pre-Flight

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    I assumed my IA. Had no reason to think he wouldn’t. Should have discussed in hindsight.
     
  23. JAWS

    JAWS Cleared for Takeoff

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    So the owner decided to do something, hiring outside help, with the assumption that the IA would just sign it off no questions asked and no involvement until the end, when the signature is wanted. :rolleyes:

    You reap what you sow.
     
  24. John Richardson

    John Richardson Pre-Flight

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    I’m the owner, and yes I made a stupid assumption. But, I have several other IAs who would sign it off no problem. So I’ll be using them.
     
  25. JAWS

    JAWS Cleared for Takeoff

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    Hopefully you treat the next one with a bit more professional respect. Get the IA to accept what you want to do BEFORE you do it! His licence is his livelihood.
     
  26. John Richardson

    John Richardson Pre-Flight

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    He wouldn’t have signed off even I had spoken to him beforehand. So, I’d be IA shopping either way.
     
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  27. kyleb

    kyleb Final Approach PoA Supporter

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    You don't need the IA to sign off of applying vinyl stripes or lettering. As owner, you can do that and sign it off. The IA need not enter the equation.
     
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  28. James331

    James331 Ejection Handle Pulled

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    Sometimes it’s hard to get humor from just text, is this a joke?



    Yup, in fact most people wouldn’t even bother with a log book entry, TONS of 135s with logos and stuff that have no entry.

    It’s a sticker, calm down and carry on. Damn! Lol
     
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  29. Checkout_my_Six

    Checkout_my_Six Touchdown! Greaser!

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    Agreed....the only caveat I'd put with that....is I'd have an issue if I saw stickers or vinyl on control surfaces during an annual inspection.
     
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  30. JAWS

    JAWS Cleared for Takeoff

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    Nope, not a joke. The food on my family's table comes from my licence. The power, heat, mortgage.

    Is it fair for owners to think they can do whatever they want and expect me to sign off on it after the fact? Not the way I work. Come to me beforehand and explain what is going to happen, let me ask questions and get it straight in my mind, then let me inspect it afterwards. I would be OK with it, depending on the person I am dealing with.

    Oh yeah, and you will be billed for it.
     
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  31. JAWS

    JAWS Cleared for Takeoff

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    Yep, or covering the static ports, fuel vents, air vents, drains, etc.
     
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  32. James331

    James331 Ejection Handle Pulled

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    If a AP, let alone a IA had a temper tantrum over a sticker on the side of the fuselage or the middle of the wing, I don’t think it’s stickers that are causing issues with putting food on their table, rather their self induced drama and lack of knowledge spawning from such.
     
    Last edited: Sep 14, 2019
  33. kyleb

    kyleb Final Approach PoA Supporter

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    The owner in question was applying vinyl stripes. That is expressly permitted work by an owner. It isn't the IA or A&P's responsibility to sign it off.

    Don't create a problem where there isn't one.
     
  34. JAWS

    JAWS Cleared for Takeoff

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    I agree, it is permitted as preventative maintenance. I also agree that work done by the owner is not the IA's responsibility until annual time.

    But the OP wrote that he expected his IA to certify the work that he did without the IA's knowledge. If the OP wants to certify it using his own licence, go for it. Or not put anything in the log, also his choice.
     
  35. MuseChaser

    MuseChaser Cleared for Takeoff

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    I've read this thread a few times, just to make sure I'm not missing something. If I understand correctly, the hangar-neighbor IA in question was NOT asked to sign off on the stickers, nor was a sign-off required by him nor any other IA. Yet, this neighborly IA happened to observe the work being done and took it upon himself to insert himself into the OP's business, making inquiries to the FSDO, and creating problems where there aren't any?

    Doesn't sound very neighborly. It is MORE than fair to "allow owners to do whatever they want" as long as what they want to do is within the regs. Pretending it isn't or not knowing it is (not sure which is worse) and then possibly billing for an unneeded signature seems to be the height of unethicality ... if that's a word.
     
  36. Bell206

    Bell206 En-Route

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    I believe the OP intended to ask him (post 62) as his neighbor was also his mechanic that worked on the aircraft (post 27). However, it appears his mechanic saw the stripes being applied prior to the OP inquiring with him. So in the process of checking his mechanic contacted the FSDO for some guidance. Unfortunately, the ASI sent the mechanic down the wrong path for whatever reason. But without the mechanic here to get both sides of the conversation we'll never know all the facts were discussed.
     
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  37. Doc Holliday

    Doc Holliday Cleared for Takeoff

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    But this is PoA, so no need in having all of the facts. ;)
     
  38. JAWS

    JAWS Cleared for Takeoff

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    "Butwithout the mechanic here to get both sides ofthe conversation we'll never know all the factswere discussed."

    Pretty much. But let's start banging away on the mechanic anyway! :mad:
     
  39. JAWS

    JAWS Cleared for Takeoff

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    As I wrote above, if the OP wants to sign off on it with his licence, he is more than welcome.

    But, he has stated that he assumed his neighbour IA would. Two very different things.

    If I am asked to perform maintenance, I do expect something in return for using my credentials. An oil change, is maintenance. It is also in the owner preventative list and can be certified by the owner, if he so chooses. Have at it, I say.

    If he chooses to change his own oil and then chooses to have me certify the work, I take on the full responsibility of the work. In this case, I do expect to be compensated for my time and (more importantly) the liability I am taking on.
     
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  40. MuseChaser

    MuseChaser Cleared for Takeoff

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    Understood. I guess I'd like to think that the way an ethical, kind IA would approach such a request would be to inform the owner that the IA's signature was not required in that instance, but that he"d be happy to inspect and sign off on it for a fee if the owner insists. Anything else would seem to be preying off the ignorance of the owner. Virtually all of the A&P/IA folks I've used and befriended have operated like that, most going so far as to NOT wanting to do and charge me for work that they knew I could do or that they could teach me to do. In return, I always pay them more than they bill me. If one of them had ever knowingly charged me for an unneeded service or signoff, I would have been justifiably miffed. The situation the original poster described, assuming we have the full description, does not put his IA neighbor in a very pleasing light.
     
    Last edited: Sep 15, 2019
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