Firewall

Why would I need additional FAA appoval if we have already have proven it's the same part?



If we sent the original firewall to Joe Blows Sheet Metal repair station and he sent us back a hole-less firewall with that 90 degree bend and a C of C that said it was made of the same material and dimensions as the part they received, what more do you want? A field approval? Coordinate that with the FSDO of your choice. A DER? Same deal.
The FSDO will want proof that it was manufactured IAW manufacturers data. you will need to do that in some fashion, No mater what route you take. The DER/DAR will provide that info, that is what you pay them for.

For this repair, it will require a 337 for the major repair, and who ever signs the block 7 will also require proof the part meets the requirements of those who signed block 4
 
Brian, Ed,

Wrestling with a hog....

IOWs you resent me making the point that you can't simply make a part for your aircraft with out proving you made in the same manor the manufacturer did?
 
IOWs you resent me making the point that you can't simply make a part for your aircraft with out proving you made in the same manor the manufacturer did?

Pretty simple panel (firewall) cut to size, one bend, get holes in the right place and it's done. Sheet metal panels are fabricated in-house every day. BTDT with no questions from the feds.
 
IOWs you resent me making the point that you can't simply make a part for your aircraft with out proving you made in the same manor the manufacturer did?

No.

It's more about gluing on customers' oil filters...

Is that in the mx manual?

Some things a person doesn't forget and I haven't put much credibility in anything you've said since.
 
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Tom,
You might want to spend a lot of time talking to that KPTK fellow. He knows an awful lot about maintaining airplanes.
 
I suspect my plane will be fixed and in the air before you guys finish bickering about this. :wink2:
 
Quote:
Originally Posted by Tom-D View Post
What are you talking about?
Quote:
Originally Posted by Tom-D View Post
I once put a new filter on using contact cement and a long cheater bar..

the cheap skate owner never asked me to change his oil for free again.

Fact is, I haven't seen him in a while.

And that gives you rights to compare me to a hog?

Mechanics do get even for being used.
 
Here's progress at last. First, my poor girl with her nose wide open.
IMG_1916_zps2aff55c7.jpg


Because it's a view you don't get to see too often, here's a close-up of the stuff behind the center pedestal, mostly rudder trim linkage and one of the brake cylinders/
IMG_1919_zpsddb8e7d0.jpg


From the other side. There's a bit more footroom without the rudder pedals.
IMG_1922_zps9d14522a.jpg


Out with the old. The slightly bent firewall with most of the fittings removed.
IMG_1929_zpse949b799.jpg


And in with the new, we hope. This is a test fit of some of the structural pieces. Some of the holes don't quite line up. My mechanic is waiting to hear from Cessna on how to proceed with this. We're not real impressed with their quality control, seeing that it took nearly a year to make the part, but we may be able to get by with what they sent us.
IMG_1928_zps6af4b474.jpg
 
I suspect my plane will be fixed and in the air before you guys finish bickering about this. :wink2:

Seeing all the fun you're having, trying to get the factory part to fit properly, I'm not sure.

Unless your guy is a tin bender, I'd consider calling Mr. KPTK down for a consult. He's reasonably close by.
 
This is EXACTLY way alot of us are going the experimental route...You certified guys pay the big bucks, and wait a year for a part................... that does NOT fit...:mad2::mad2::mad2:....

Geico and I could have had the part fabricated and installed in one afternoon...... IMHO..
 
Why would I need additional FAA appoval if we have already have proven it's the same part?
Read AC 20-62D

there are requirements for approval of owner produced parts.

b. Acceptable Parts. The following parts may be found to be acceptable for installation on a type- certificated product:
(1) Standard parts (such as nuts and bolts) conforming to an established industry or U.S. specification.
(2) Parts produced by an owner or operator for maintaining or altering their own product and which are shown to conform with FAA-approved data.
 
Read AC 20-62D

there are requirements for approval of owner produced parts.

b. Acceptable Parts. The following parts may be found to be acceptable for installation on a type- certificated product:
(1) Standard parts (such as nuts and bolts) conforming to an established industry or U.S. specification.
(2) Parts produced by an owner or operator for maintaining or altering their own product and which are shown to conform with FAA-approved data.

Right, and if you build it from the same materials to the spec of what you removed, you meet the criteria.
 
Right, and if you build it from the same materials to the spec of what you removed, you meet the criteria.

Henning...haven't you figured out by now that Toms penis is bigger then anyone else's..... Good god man,,, get a grip..:yes:;)
 
Prove what? The material is easy, any lab can provide the data from the old part, measure vs measure on construction.

Read the AC.
k. Return to Service Inspection Records. The person approving or disapproving for return to service a type-certificated product must ensure that the required maintenance record entries comply with 14 CFR part 43, and therefore must include the following information:
(1) Type of inspection and a brief description of the extent of the inspection.
(2) Date.
(3) Product hours, cycles, or life limits as applicable.
(4) Signature, certificate number, and kind of certificate held by the person approving or disapproving
for return to service.
(5) The appropriate certifying statement that the product or part thereof, is approved or disapproved for return to service, as applicable.

Plus

n. Owner/Operator Produced Part. Parts that were produced by an owner/operator for installation on their own aircraft (e.g., by a certificated air carrier). An owner/operator is considered a producer of a part, if the owner participated in controlling the design, manufacture, or quality of the part. Participating in the design of the part can include supervising the manufacture of the part or providing the manufacturer with the following: the design data, the materials with which to make the part, the fabrication processes, assembly methods, or the quality control procedures.
5. RELATED READING MATERIALS.
a. Copies of current editions of the following publications may be obtained free of charge from the U.S. Department of Transportation, Subsequent Distribution Office, Ardmore East Business Center, 3341 Q 75th Avenue, Landover, MD 20785.
(1) AC 21-13, Standard Airworthiness Certification of Surplus Military Aircraft and Aircraft Built from Spare and Surplus Parts.
(2) AC 21-20, Supplier Surveillance Procedures.
(3) AC 21-23, Airworthiness Certification of Civil Aircraft, Engines, Propellers, and Related Prod-
ucts Imported to the United States
(4) AC 21-29, Detecting and Reporting Suspected Unapproved Parts.
(5) AC 21-38, Disposition of Unsalvageable Aircraft Parts and Materials.
(6) AC 43-9, Maintenance Records.
(7) FAA Order 8000.50, Repair Station Production of Replacement or Modification Parts.
(8) FAA Order 8130.21, Procedures for Completion and Use of FAA Form 8130-3 Airworthiness
Approval Tag.
(9) FAA Order 8120.10, Suspected Unapproved Part Program.
(10) FAA Order 8120.2, Production Approval And Surveillance Procedures.
b. Copies of current editions of the following AC’s may be purchased from the Superintendent of Documents. Make check or money order payable to the Superintendent of Documents.
(1) AC 21-2, Export Airworthiness Approval Procedures.
(2) AC 21-6, Production Under Type Certificate Only.
(3) AC 21-18, Bilateral Airworthiness Agreements.
(4) AC 43.13-1, Acceptable Methods, Techniques and Practices--Aircraft Inspection and Repair. (5) AC 43.13-2, Acceptable Methods, Techniques and Practices--Aircraft Alterations.
6. DISCUSSION. The FAA continues to receive reports of replacement parts being offered for sale as aircraft quality when the quality and origin of the parts are unknown or questionable. Such parts may be advertised or presented as ‘‘unused,’’ ‘‘like new,’’ or ‘‘remanufactured.’’ These imply that the quality of the parts is equal to an acceptable part. Purchasers of these parts may not be aware of the potential hazards involved with replacement parts for which acceptability for installation on a type-certificated product has not been established.
 
Providing the old unit as a template provides what one needs to know.
 
n. Owner/Operator Produced Part. Parts that were produced by an owner/operator for installation on their own aircraft (e.g., by a certificated air carrier). An owner/operator is considered a producer of a part, if the owner participated in controlling the design, manufacture, or quality of the part. Participating in the design of the part can include supervising the manufacture of the part or providing the manufacturer with the following: the design data, the materials with which to make the part, the fabrication processes, assembly methods, or the quality control procedures.

Problem with what you posted here is you ignored the words which preceded your emphasized fragment, particularly "Participating in the design of the part can include supervising the manufacture of the part..." the 'or' where you began your emphasis and everything that follows it is moot if you actually produce or supervise production of the part in question.

When I supervised the material analysis of both parts and oversaw the milling of one, and then actually built the other part with my own hands using the same material(s) and reverse engineered data from the original parts I absolutely met the test of owner produced part.

BTDT, I have two owner produced parts on my certified airplane, and both seem to have passed the acceptable data test when the plane was inspected by an A/W inspector prior to a CFI check ride. IA stated it was best to have everything I documented just in case, but when asked about how the owner produced parts were built the simple statement of "reverse engineered the originals using measurements and fabricated new parts using same material as original, I can provide both the original parts and the documentation regarding materials used and material makeup of original if you'd like to see them." Question asked, question answered, inspector signed off said thanks having the information available and being able to actually articulate what was done then he signed off and away we went.

Admittedly, neither part is a firewall, one is a rod used as part of the flap indicator and the other is a seat track, but owner produced non the less and two IAs and an FAA A/W inspector all agree that the plane is still airworthy, so it's only as difficult as you want to make it apparently.

Steve
 
Henning...haven't you figured out by now that Toms penis is bigger then anyone else's..... Good god man,,, get a grip..:yes:;)

Trying to belittle the messenger again Ben?

There are several methods to insure the parts are manufactured IAW with the FAA approved methods.
When the FSDO starts asking questions your A&P returning to service better have the proper records or their certificate is gone.
 
Try to do a little research by reading these articles.

http://www.aviationpros.com/article/10387511/owner-produced-parts-how-they-affect-maintenance

I didn't write this, my suggestion would be you best have proper documentation for any and every thing you do. speciality manufacturing parts for a repair.

From the article above

" "Reality check
Maintenance technicians must face a cold hard fact. Aircraft owners can make parts, but they cannot install them. Installing owner produced parts is a maintenance function and only technicians can do that. That makes technicians the "gatekeepers" for parts and guardians against the introduction of substandard and unapproved parts into the fleet. Under this rule the responsibility is the technician's to determine airworthiness before returning the product to service. There is no one else to shift the burden of blame to. The technician's name is on the blame line. " "
 
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...my suggestion would be you best have proper documentation for any and every thing you do. speciality manufacturing parts for a repair.

Because if you don't they will take your children away from you...oh wait, the youngest is 35, go ahead they're yours.
 
Out with the old. The slightly bent firewall with most of the fittings removed.
IMG_1929_zpse949b799.jpg

Holy Cow - I guess I should have replaced my firewall about 30 years ago. You're not seriously telling us this was all because of that little crease there are you?
 
Because if you don't they will take your children away from you...oh wait, the youngest is 35, go ahead they're yours.

No, simply it's a failure on my part, to do the required home work that my job requires.

Want to build parts? I'm good with that, I do my share of them. but you better have the proper data to support the build.

For example, I build a lot of skin sheets for cessna, in the IPC it will give the P/N and then say build from .025" 2024-T3 That is my authorization to build the part, no paper required, I'd have no problem from the FSDO in building that skin.

But many aircraft manufacturers do not allow that to happen, and the skin must be manufactured IAW the structural repair manual, or the blue print they company used or other approved data such as the 43.13-2b, and the repair documented on a major repair form(337)
 
Holy Cow - I guess I should have replaced my firewall about 30 years ago. You're not seriously telling us this was all because of that little crease there are you?
do you know what the term " out of column" means ?
 
Or what Tom? For heaven sakes it's a privately owned single engine Cessna, it ain't a 300 passenger commercial airliner.

Lighten up.
 
do you know what the term " out of column" means ?

I own a '58 Champ that probably went "out of column" after the first time they wrecked it back in '61.

Hasn't killed anybody yet.
 
I own a '58 Champ that probably went "out of column" after the first time they wrecked it back in '61.

Hasn't killed anybody yet.

If they repaired it properly it will be in column.
 
Or what Tom? For heaven sakes it's a privately owned single engine Cessna, it ain't a 300 passenger commercial airliner.

Lighten up.

Lighten up?? WTF? for giving you guys the right methods?

Just because every one thinks owner produced part can simply be placed in service and no one cares doesn't make it right.

read the article see if the FAA can't stuff your ticket where the sun don't shine.
 
...read the article see if the FAA can't stuff your ticket where the sun don't shine.

You're kidding me right? That's AMT, it's like a Car Magazine for aircraft mechanics. They write articles because that's what they do. They don't do anything else, they just write articles.

You gotta stop reading so much. It's like prescription medications, if you were to read the sheet that comes with them you'd never take a single dose.
 
You're kidding me right? That's AMT, it's like a Car Magazine for aircraft mechanics. They write articles because that's what they do. They don't do anything else, they just write articles.

You gotta stop reading so much. It's like prescription medications, if you were to read the sheet that comes with them you'd never take a single dose.

Yeah right, what ever, you probably don't know who Don Dodge is. read the last line .


Don Dodge is the airworthiness safety program manager at the South Carolina FSDO.
 
Problem with what you posted here is you ignored the words which preceded your emphasized fragment, particularly "Participating in the design of the part can include supervising the manufacture of the part..." the 'or' where you began your emphasis and everything that follows it is moot if you actually produce or supervise production of the part in question.

Exactly.

When I supervised the material analysis of both parts and oversaw the milling of one, and then actually built the other part with my own hands using the same material(s) and reverse engineered data from the original parts I absolutely met the test of owner produced part.

BTDT, I have two owner produced parts on my certified airplane, and both seem to have passed the acceptable data test when the plane was inspected by an A/W inspector prior to a CFI check ride. IA stated it was best to have everything I documented just in case, but when asked about how the owner produced parts were built the simple statement of "reverse engineered the originals using measurements and fabricated new parts using same material as original, I can provide both the original parts and the documentation regarding materials used and material makeup of original if you'd like to see them." Question asked, question answered, inspector signed off said thanks having the information available and being able to actually articulate what was done then he signed off and away we went.

Admittedly, neither part is a firewall, one is a rod used as part of the flap indicator and the other is a seat track, but owner produced non the less and two IAs and an FAA A/W inspector all agree that the plane is still airworthy, so it's only as difficult as you want to make it apparently.

Steve

Yep, it's not rocket science.
 
Yeah right, what ever, you probably don't know who Don Dodge is. read the last line ...

Wait a minute, you know Don? How's he been? Hows his kid doin'
 
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