How to get FMS approval for GPS

[skipnsb]

Assume a gps is installed as a minor alteration, ap signs log book, no 337 is filed. I fly it vfr for awhile and become satisfied that it is working properly. My ap fills in the blank FMS appropriate to my aircraft.

What do I now do to get the FMS approved?
Or is the blank FMS given by the manufacturer "already accepted" because the initial installation instructions on which the initial stc was based included the blank FMS? Thanks Skip

 

[peter-h]

This thread
http://www.pilotsofamerica.com/forum/showthread.php?t=29025

might be of interest.

 

[poadeleted20]

It's a bit more complicated than your post suggests. AC 20-130A spells out the process. See the section titled "Follow-On IFR Airworthiness Installation Approvals" starting on page 33, the steps in the process in Appendix 1, and the guidance on writing the AFM Supplement in Appendix 2. Also, unless your A&P has done this before (most IFR GPS installations/approvals are done by avionics shops with repair station certificates, not individual A&P's), s/he will need the supervision of one who has IAW 14 CFR 65.81(a).

 

[RotorAndWing]

Also, unless your A&P has done this before (most IFR GPS installations/approvals are done by avionics shops with repair station certificates, not individual A&P's), s/he will need the supervision of one who has IAW 14 CFR 65.81(a).

FAR 65.81

If he has not so performed that work at an earlier date, he may show his ability to do it by performing it to the satisfaction of the Administrator or under the direct supervision of a certificated and appropriately rated mechanic, or a certificated repairman, who has had previous experience in the specific operation concerned.

By having approved or accepted data (such as manufactures instruction and installation manual) or attending a Manufactures school meets the criteria of the first part of 65.81.

 

[John Collins]

Skip,

What GPS have you installed and what does it currently interface to?

 

[poadeleted20]

By having approved or accepted data (such as manufactures instruction and installation manual) ...meets the criteria of the first part of 65.81.

Is that written somewhere? It's not clear to me from the wording of 65.81(a). The way that reg is worded, it appears to me the FAA would have to inspect the actual work done, not just be doing it per the manual.

 

[RotorAndWing]

Is that written somewhere? It's not clear to me from the wording of 65.81(a). The way that reg is worded, it appears to me the FAA would have to inspect the actual work done, not just be doing it per the manual.

Look at it this way:

1) You fly a Cirrus into an airport and it has a problem with the fuel selector so you go over to the shop for a repair. The A&P has never seen a Cirrus before. Can he legally remove the fuel selector and replace it? The answer is yes if he gets a copy of the maintenance manual that gives instructions for the task. The maintenance manual is an FAA Approved document, approved by the Administrator.

2) You buy a STC for your Grumman to attach a device to the bottom that will make it fly faster. Since this is a new STC can your local A&P install it or does he have to have the STC designer come down and supervise him installing it? Your A&P can install it by using the approved instructions contained within the STC.

3) An airline has a plane land at a station that does not normally go there. The A&P's are not trained to that airplane type. Can they do a service check and sign it off? Sure, if the maintenance department sends them the documentation (maintenance manual) giving them instructions on how to perform the task.

When I got my A&P license the way it was presented to me and has been generally accepted everywhere I've been is "performing to the satisfaction of the administrator" means following all FAR's and approved/accepted data. The FAA does not have to oversee everything you do. The FAA's oversight is random field inspections of maintenance facilities.

At my last IA refresher course the FAA gave a presentation. In that they said all references to "the administrator" are being removed from FAA documentation and FAR's. The wording will change to "administration".

 

[poadeleted20]

The difference I see is that pretty much every A&P mechanic has changed a fuel selector or done the sort of maintenance actions you described. Doing it on a different airplane is still back to the basic skill/knowledge set any A&P should have, and the minor differences are covered in the maintenance manual for that airplane. OTOH, doing an IFR certification on a GPS (including the installation and testing) is not necessarily something that the average local A&P has ever done or seen done, and probably isn't covered in 43.13-1B or the A&P training course at most schools, and so I would think should not be done without supervision or approval of the finished work if the A&P has never done it or seen it done before. If that's a misunderstanding on my part, please chalk it up to unfamiliarity with the details of the rules covering A&P's.

Personally, I would want this done by a certified avionics shop with experience in the process, and that's how I've done it on the three airplanes which I've had equipped with IFR GPS's. I also did the flight tests for that certification with a shop technician who'd flown lots of these before riding shotgun -- they even had a canned flight test profile set up in cooperation with the Airworthiness folks at the local FSDO which monitors their shop. All in all, the intricacies of the process seem to me to demand a specialist, but that's a personal decision about which others may choose differently.

 

[Tom-D]

The difference I see is that pretty much every A&P mechanic has changed a fuel selector or done the sort of maintenance actions you described. Doing it on a different airplane is still back to the basic skill/knowledge set any A&P should have, and the minor differences are covered in the maintenance manual for that airplane. OTOH, doing an IFR certification on a GPS (including the installation and testing) is not necessarily something that the average local A&P has ever done or seen done, and probably isn't covered in 43.13-1B or the A&P training course at most schools, and so I would think should not be done without supervision or approval of the finished work if the A&P has never done it or seen it done before. If that's a misunderstanding on my part, please chalk it up to unfamiliarity with the details of the rules covering A&P's.

Personally, I would want this done by a certified avionics shop with experience in the process, and that's how I've done it on the three airplanes which I've had equipped with IFR GPS's. I also did the flight tests for that certification with a shop technician who'd flown lots of these before riding shotgun -- they even had a canned flight test profile set up in cooperation with the Airworthiness folks at the local FSDO which monitors their shop. All in all, the intricacies of the process seem to me to demand a specialist, but that's a personal decision about which others may choose differently.

Electrical wiring, and avionix installations are part of the A&P training and are part of the knowledge requirement to gain the A&P certificate, and excepted by the FAA to meet the prior experiance requirements.

just because the radio is a GPS does not make it a new skill. just like your fuel valve example.

That said.

Avonix upgrades, I will not do them, simply because the blue smoke gets out too easy and it costs too much to put back. A&P's can't work on transmitters, so I would be required to send it out for repair because I don't have the equipment to repair, (most A&Ps don't) or the equipment to test. plus most manufacturers will not publish the internal schematics.

 

[Tom-D]

Everyone must remember, the A&P ticket is only good for aircraft that weigh under 12,500 pounds and not on a 121/125 maintenance programe.

 

[RotorAndWing]

Everyone must remember, the A&P ticket is only good for aircraft that weigh under 12,500 pounds and not on a 121/125 maintenance programe.

Really? How so? How does a Gulfstream 5 operating under Part 91 have maintenance performed and signed off? Or perhaps a King Air 350?

So you are saying an A&P cannot perform a phase inspection, or remove and replace a part of an aircraft weighing over 12,500 pounds?

 

[Tom-D]

Really? How so? How does a Gulfstream 5 operating under Part 91 have maintenance performed and signed off? Or perhaps a King Air 350?

So you are saying an A&P cannot perform a phase inspection, or remove and replace a part of an aircraft weighing over 12,500 pounds?

Large turbin aircraft are maintained on approved programs, in that approval it will state who can return to service. in most cases that will be the DOM of the repair station

See FAR 1.1

"Large aircraft means aircraft of more than 12,500 pounds, maximum certificated takeoff weight."

 

[wabower]

That is not true. Three shops within 200 yards of my office routinely service and maintain a number of turboprops and jets over 12.5k including 350's CE-650's, big Lears, Hawkers, Falcons, Gulfstreams and others. Not a single repair station or factory service center in the bunch. Not to say many airplanes are not serviced by repair stations, but I'll send you photocopies of logs from 10 airplanes by noon tomorrow that are signed off by the same guys who sign off singles and twins as well. Including a Gulfstream III that I appraised 2 weeks ago, and a Citation III that I'm starting tomorrow.

Large turbin aircraft are maintained on approved programs, in that approval it will state who can return to service. in most cases that will be the DOM of the repair station

See FAR 1.1

"Large aircraft means aircraft of more than 12,500 pounds, maximum certificated takeoff weight."

 

[RotorAndWing]

Large turbin aircraft are maintained on approved programs, in that approval it will state who can return to service. in most cases that will be the DOM of the repair station

See FAR 1.1

"Large aircraft means aircraft of more than 12,500 pounds, maximum certificated takeoff weight."

But your original quote was:

Everyone must remember, the A&P ticket is only good for aircraft that weigh under 12,500 pounds and not on a 121/125 maintenance programe.

I have yet to see a FAR Part 145 Repair Station employ anyone as a DOM without an Airframe and Powerplant Certificate as well as a DOM at a Part 121 or 125 operation.

But I still don't see where you can assert that an A&P certificate is only good for aircraft under 12,500.

91.407 Operation after maintenance, preventive maintenance, rebuilding, or alteration.
(a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration unless—

(1) It has been approved for return to service by a person authorized under §43.7 of this chapter; and

(2) The maintenance record entry required by §43.9 or §43.11, as applicable, of this chapter has been made.

43.7 Persons authorized to approve aircraft, airframes, aircraft engines, propellers, appliances, or component parts for return to service after maintenance, preventive maintenance, rebuilding, or alteration.
(a) Except as provided in this section and §43.17, no person, other than the Administrator, may approve an aircraft, airframe, aircraft engine, propeller, appliance, or component part for return to service after it has undergone maintenance, preventive maintenance, rebuilding, or alteration.

(b) The holder of a mechanic certificate or an inspection authorization may approve an aircraft, airframe, aircraft engine, propeller, appliance, or component part for return to service as provided in Part 65 of this chapter.

(c) The holder of a repair station certificate may approve an aircraft, airframe, aircraft engine, propeller, appliance, or component part for return to service as provided in Part 145 of this chapter.

(d) A manufacturer may approve for return to service any aircraft, airframe, aircraft engine, propeller, appliance, or component part which that manufacturer has worked on under §43.3(j). However, except for minor alterations, the work must have been done in accordance with technical data approved by the Administrator.

(e) The holder of an air carrier operating certificate or an operating certificate issued under Part 121 or 135, may approve an aircraft, airframe, aircraft engine, propeller, appliance, or component part for return to service as provided in Part 121 or 135 of this chapter, as applicable.


So let's look at the requirement for a holder of a Part 121 certificate and the requirement to return an aircraft to service under their program.


121.378 Certificate requirements.

(a) Except for maintenance, preventive maintenance, alterations, and required inspections performed by a certificated repair station that is located outside the United States, each person who is directly in charge of maintenance, preventive maintenance, or alterations, and each person performing required inspections must hold an appropriate airman certificate.

(b) For the purposes of this section, a person directly in charge is each person assigned to a position in which he is responsible for the work of a shop or station that performs maintenance, preventive maintenance, alterations, or other functions affecting aircraft airworthiness. A person who is directly in charge need not physically observe and direct each worker constantly but must be available for consultation and decision on matters requiring instruction or decision from higher authority than that of the persons performing the work.


And under FAR part 125:


125.251 Required inspection personnel.

(a) No person may use any person to perform required inspections unless the person performing the inspection is appropriately certificated, properly trained, qualified, and authorized to do so.

125.247 Inspection programs and maintenance.

(a) No person may operate an airplane subject to this part unless

(1) The replacement times for life-limited parts specified in the aircraft type certificate data sheets, or other documents approved by the Administrator, are complied with;

(2) Defects disclosed between inspections, or as a result of inspection, have been corrected in accordance with part 43 of this chapter; and

(3) The airplane, including airframe, aircraft engines, propellers, appliances, and survival and emergency equipment, and their component parts, is inspected in accordance with an inspection program approved by the Administrator.

(b) The inspection program specified in paragraph (a)(3) of this section must include at least the following:

(1) Instructions, procedures, and standards for the conduct of inspections for the particular make and model of airplane, including necessary tests and checks. The instructions and procedures must set forth in detail the parts and areas of the airframe, aircraft engines, propellers, appliances, and survival and emergency equipment required to be inspected.

(2) A schedule for the performance of inspections that must be performed under the program, expressed in terms of the time in service, calendar time, number of system operations, or any combination of these.

(c) No person may be used to perform the inspections required by this part unless that person is authorized to perform maintenance under part 43 of chapter.

 

[skipnsb]

I am working on a simple Garmin 300 install in a SE Cessna, direct wired to a King202 cdi, with a homemade indicator light panel and 2 switches, no other interface yet as I don't have an autopilot. I am also building a kit, put lots of 8 tracks in cars, dad was military electronic troubleshooter, I have the appropriate crimpers/wire/supplies/etc. and like doing this, ap has done some avionics/wiring and is ok with supervising me. When I called my FSDO about it being a minor alteration by my ap she said "as long as he has the right tools/materials and knows what he is doing" nothing about having it done before. If it smokes I will not be able to fix it. Safety first, then legal. Skip