Owner manufactured part

[stingray]

I think I have it right but I thought I might get some input from some, on owner manufactured parts.

I think an owner can manufacture a part if it is no longer avaliable.

I was hoping you can manufacture one even if the factory still supplies it.

The Taylorcraft BC12D has an AD on the struts. There are a few suppliers manufacturing them to get rid of the AD. If other suppliers are manufacturing them could an owner also manufacture them for his own plane?

Dan

 

[Let'sgoflying!]

wow, I can see going after a simpler part but a wing strut? Yikes!

 

[RotorAndWing]

[SIZE=+6]Owner Produced Parts[/SIZE]
​

by Don Dodge


The article was written to address the producing of parts by owner and operators. The article is not intended to imply that maintenance technicians or repair stations may not be able to manufacture parts in the course of accomplishing repairs or alterations. That in itself is another topic for another day.

The sun was setting on another hot August afternoon when the South Carolina Flight Standards District Office received the call from a local airport manager notifying the office that a Piper Cherokee had suffered a nose gear collapse during taxi operations. It was reported that the Cherokee suffered minor damage; the damage included a prop strike and lower cowling abrasion.
Early the next morning, the inspector assigned to investigate the incident picked up the preliminary information with one hand and his first cup of coffee with the other. As the aroma and warm flavor of his coffee cleared the night’s cobwebs from his mind, he eyeballed the incident information. As he read, he thought: "Let’s see, Cherokee 140, taxi, nose gear collapse, prop, cowling, etc., etc.—wait a minute, Cherokee 140? How can a 140’s nose gear collapse during taxi operations and cause this kind of damage? An Arrow, maybe, but a 140?"
Years of experience told the inspector there was a lot more to this story than had been reported. So on that hot, humid, August morning, he headed for the airport. His investigation uncovered a classic case of an aircraft owner making parts and doing everything wrong. The issues surrounding manufacturing approved parts, who can produce these parts, what makes a part approved or unapproved, all came up in the investigation.
Time and again aircraft owners and maintenance technicians are pressured into making parts. Why do we do it? Why do we take on that liability? Let’s look at the facts.
The average general aviation, piston single-engine aircraft is more than 32 years old; the average piston twin is more than 27 years old; and the average turbo prop is 19 years old. The GA aircraft fleet was never designed to last this long, and, when it comes to getting replacement parts to maintain these aircraft, here are a few of the problems we all face.

The aircraft has been out of production for years.
The aircraft is an orphan. No one even knows who owns the Type Certificate.
There is no technical support. If you ask for technical assistance, you are often told that no one really knows much about the aircraft anymore. The people who were around when the aircraft was built are all retired or dead.
Economy of scale forces aircraft manufacturers to build parts in quantities that make economic sense for the manufacturer. What this means is that parts are available, in about six or eight months!
The price of parts is a subject that we aren’t even going to talk about. Sitting in the middle, between a tired broken airplane, its owner, and all these parts problems, is the maintenance technician. Technicians, by their nature, are "can do" people. They live by the motto the difficult we do immediately; the impossible just takes a bit longer. But when it comes to making parts, this "can do" philosophy can really get them in trouble.
Let’s examine the rules governing the general privileges and limitations of a maintenance technician (or certificated mechanic as stated in FAR §65.81), and the rule governing a repair station’s privileges of certificates (FAR §145.51). Under both rules a technician or repair station may perform maintenance, preventative maintenance, and alterations on an aircraft, or appliances for which he is rated. Nowhere in either rule does it say that the maintenance technician or repair station can produce new parts! However, the maintenance regulations allow the manufacture of parts for repair (see number 11 in next question.
A maintenance tech or repair station can make patch plates, reinforcement splices, and incorporate them into the repair of a part. But again, a, a maintenance technician cannot make a brand new part for sale.
Here are some answers to those earlier questions.

Question: who can make a brand new part?

Answer: FAA Advisory Circular 21-29, Detecting And Reporting Suspected Unapproved Parts, states that there are eleven ways that a new part can be made. They are:
1. Parts Manufacturer Approval (PMA)
2. Technical Standard Order (TSO)
3. Type Certificate (TC) or Supplemental Type Certificate (STC)
4. TC with an Approved Production Inspection System (APIS)
5. Production Certificate (PC)
6. Bilateral Agreement
7. Any method acceptable to the Administrator.
8. Standard Parts (nuts and bolts)
9. Owner Produced Parts
10. Parts produced per STC instructions as part of an STC modification.
11. Fabricated by a qualified person in the course of a repair for the purpose of returning a TC product to service (which is not for sale as a separate part) under part 43.
All this sounds like bureaucratic alphabet soup, but, of all the ways listed, "Owner Produced Parts" is the one most misunderstood. FAR §21.303(b)2 makes a provision for an aircraft owner or operator to produce parts for maintaining or altering his or her own product. Under this provision, the Owner Produced Part can only be installed in an aircraft owned or operated by that person and the Owner Produced Part cannot be produced for sale to others.

Question: How is it that an aircraft owner can produce a part, but a skilled maintenance technician can’t?

Answer: The responsibility follows the money. Most rules are written so the responsibility for an action is placed with the person who has the economic authority to make it happen. (The Golden Rule)

Question: How does this owner-produced rule work? Does the owner have to make the part himself?

Answer: The answers can be found in a FAA Memorandum dated August 5, 1993, in which the assistant Chief Counsel for Regulation makes the following interpretation:

A part does not have to be solely produced by the owner to be considered an Owner Produced Part.
The aircraft owner must participate in the manufacture of the part in at least one of five
ways for it to be considered an Owner Produced Part. 1. The owner provides the manufacturer of the part with the design or performance data.
2. The owner provides the manufacturer of the part with the materials.
3. The owner provides the manufacturer with fabrication processes or assembly methods.
4. The owner provides the manufacturer of the part with quality control procedures.
5. The owner personally supervises the manufacture of the new part.

As anyone can see, the discriminators for determining owner participation in a new part’s manufacture are very specific in the interpretation. Attachment (A) to the 1993 Memorandum clearly stipulates that the FAA would not construe the ordering of a part as participating in controlling the design, manufacture, or quality of a part. The key point is that the aircraft owner must participate in the part’s manufacture.

Question: If the part is owner produced, is it also a FAA approved part? Can I install it in the owner’s aircraft?

Answer: If the Owner Produced Part has all the characteristics of an approved part, is only installed on the owner’s aircraft, and is not for sale, it would be considered a FAA approved part.
There are eleven ways (as listed earlier) to produce an FAA approved part. It doesn’t matter if a part is produced under the authority of a PMA, TC, or owner produced, it must have all the characteristics of an approved part. The four characteristics of an approved part are:
1. The part must be properly designed. A properly designed part means that the part’s design is FAA approved. Depending on the complexity of the part, a FAA approved design will have the following elements:

Drawings, specifications to define the part’s configuration and design features.
Information on dimensions, materials, and processes necessary to define the structural strength of the product.
Airworthiness limitations and instructions for continued airworthiness.
Any other data necessary to allow by comparison, the determination of airworthiness of later products of the same type. 2. The part must be produced to conform to the design. A properly produced part means the part conforms to the FAA approved design. Usually a properly produced part will have the following characteristics:

The part complies with all applicable structural requirements of its design.
The materials and products conform to the specifications in the design.
The part conforms to the drawings in the design.
The manufacturing processes, construction, and assembly of the part conform to those specified in the design. 3. The part’s production should be properly documented. A properly documented part provides evidence that the part was produced under an FAA approval and memorializes the production of the part.
4. The part must be properly maintained. A properly maintained part means that the part is maintained in accordance with the rules prescribed under FAR Part 43.

It is relatively easy for a part to meet the requirements of the August 5, 1993, Memorandum and qualify as an Owner Produced Part. The four characteristics of an approved part are like the four legs of a table with all four legs "equally sharing" the burden of an approved part. If one leg is missing, the table will fall over. In the same way, if any of the four characteristics of an approved part is missing, then the part may not be FAA approved.
A good example is the case of the Cherokee 140 with the collapsed nose gear, mentioned and shown in the beginning of this article. The investigation determined the following:


The original factory nose strut lower tube was pitted.
The aircraft owner had a strut tube locally manufactured.
A technician who knew of the part’s origin installed the strut tube.
The strut tube failed during the first operation, resulting in $7,000+ in damages.
Question: Was the strut-tube an Owner Produced Part?

Answer: Yes, legally it was an Owner Produced Part. The aircraft owner did participate in the manufacture of the part. The owner supplied the manufacturer a design for the part. He did this by giving the manufacturer the old lower strut tube and told him to duplicate it. (Reverse engineer)

Question: Was this a FAA approved part?

Answer: No, the part was not approved because the owner did not provide the manufacturer with an approved design or its equivalent. The part was not approved because it did not conform to the material specifications prescribed in the approved design. The part failed during its first operation and didn’t last long enough for maintenance to be a factor.

Question: Did the part producer (aircraft owner) or the maintenance technician who installed the strut-tube violate the FAR? Who should be held accountable?
Answer: The answer is both! The maintenance technician violated the rule the moment that he signed the maintenance records and approved the aircraft to return to service with the knowledge the part he installed was unapproved, that is he apparently understood that the part was produced by the owner. The question he should have asked the owner was "how the part was produced so as to meet the performance rules of part 43.13 of the Federal Aviation Regulations." The aircraft owner violated the rule when he knowingly operated the aircraft with an unapproved and undocumented part installed.

Question: This incident with the Cherokee 140 was wasteful, tragic, and dangerous. If the aircraft owner wanted to make an Owner Produced Part, what should he have done?

Answer:

The owner should have used the original manufacture’s prints and specifications (FAA approved design). It would have saved him time, money, and maybe his life.
Reverse engineer to develop a design if you must, but do your research and submit the resulting design to the FAA for approval. Depending on the complexity of the part, reverse engineering may result in a new design. This design is the aircraft owner’s, not the original manufacturer’s, and is not automatically FAA approved. The finished part must still meet the requirements of the performance rules of section 43.13. Always contact your local FSDO for guidance.
Produce the new part to conform to the approved design. Nothing more, nothing less. Stronger is not always better.
The aircraft owner (part’s producer) or the technician who installs the part should document or memorialize the production of the part in the aircraft records. It would be wise if the installing technician requires the part producer (aircraft owner) to memorialize the parts production in the aircraft records with a statement worded in a similar form as the one below, on this page.
After the part producer memorializes its production. The installing technician must make a maintenance record entry indicating that he or she installed the part. After all, installing the Owner Produced Part is a maintenance function. Aircraft owners can perform preventative maintenance, but not maintenance.

Eliminating the Confusion

A maintenance technician can repair a part, but sometimes the distinction between repairing a part and producing a brand new part is hard to determine. The circumstances surrounding the repair, the part’s complexity, availability of manufacturer’s data, and industry practices all are determining factors. For a lack of a better term I call making this determination the "Test of Reasonableness."

Example Scenario: An aircraft wing is damaged. The damaged parts include a wing rib, a 24-inch stringer, and wing skin. The aircraft Structural Repair Manual provides material specifications for the skin and stringer. A new wing rib is purchased from the aircraft manufacturer and the technician fabricates a stringer and wing skin using the damaged parts as a template. The technician installs these parts and repairs the wing in accordance with the manufacturer’s instructions.
Is this a repair or did the technician produce a new part? The stringer and wing skin do have a part number in the parts catalog for that aircraft, so let’s consider the following facts:

The material specifications were published and readily available.
The parts were simple and the fabrication processes for the parts involved common tools, skills, and standard industry practices.
Templates for the reliable reproduction of the parts were available (Design).
The parts were incorporated into a repair in accordance with the manufacturer’s instructions.
In this case, the "Test of Reasonableness" would determine this to be considered a repair, even though the technician did fabricate a stringer and skin.

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.

Owner Produced Parts can be summarized as follows:

Under the Federal aviation regulations, aircraft owners can produce a brand new part for their aircraft; technicians and repair stations can’t.
For a part to be considered "owner produced," the owner must have participated in its manufacture in at least one of the five ways prescribed in the 1993, Memorandum.
An Owner Produced Part must have all four characteristics of an approved part before it is considered a FAA approved part and eligible for installation.
Sometimes the distinction between producing a new part and making a repair is hard to determine. When in doubt call the local FSDO and ask for guidance.
Maintenance technicians are the gatekeepers for parts entering service in the fleet. Technicians bear the lion’s share of the responsibility. The technician’s name is on the blame line.
The availability of parts is a constant problem with our aging general aviation fleet. As time passes, Owner Produced Parts may be the only alternative available for maintaining some of it. With the passage of time, technicians are going to be increasingly forced to face the challenge of determining the airworthiness of Owner Produced Parts. There are five points summarized here. Remember the five and stay alive!

Don Dodge is the Airworthiness Safety Program Manager at the South Carolina FSDO.

 

[gismo]

This article and others I've seen on the same subject seem to assume that the only reason for an owner produced part is for a "repair" yet I don't see anything in the quoted FARs which indicates that repairing a damaged or worn part is the only circumstance where an owner produced part is acceptable. Specifically, I'm wondering if I as an owner can't "produce" a part for my airplane that isn't a replacement for an existing part. One example would be that I'd like to install a holder for a battery to power the lights in my taildragger. Another instance would be making my own circuit for interfacing the marker beacon lamp driver in my audio panel with the indicator in my Baron (a direct connection makes the lamps too dim in the daytime).

[SIZE=+6]Owner Produced Parts[/SIZE]
​

by Don Dodge


The article was written to address the producing of parts by owner and operators. The article is not intended to imply that maintenance technicians or repair stations may not be able to manufacture parts in the course of accomplishing repairs or alterations. That in itself is another topic for another day.

 

[stingray]

Wow that was a good read. I have no trouble going to my FSDO I just like to have all the facts first. And facts I have now.

Hundreds of struts are made by home builders every year. They are not that difficult to make. They are even easier if you have a pattern and the same parts that the manufacturer uses.

It will be fun to see what the FSDO says when I call.

Dan

 

[stingray]

This article and others I've seen on the same subject seem to assume that the only reason for an owner produced part is for a "repair" yet I don't see anything in the quoted FARs which indicates that repairing a damaged or worn part is the only circumstance where an owner produced part is acceptable. Specifically, I'm wondering if I as an owner can't "produce" a part for my airplane that isn't a replacement for an existing part. One example would be that I'd like to install a holder for a battery to power the lights in my taildragger. Another instance would be making my own circuit for interfacing the marker beacon lamp driver in my audio panel with the indicator in my Baron (a direct connection makes the lamps too dim in the daytime).

Battery box no problem, log book entry is all that is needed. Circuit for interfacing is going to need some DAR work I think and then approval through the FSDO.

Dan

 

[RotorAndWing]

Specifically, I'm wondering if I as an owner can't "produce" a part for my airplane that isn't a replacement for an existing part. One example would be that I'd like to install a holder for a battery to power the lights in my taildragger. Another instance would be making my own circuit for interfacing the marker beacon lamp driver in my audio panel with the indicator in my Baron (a direct connection makes the lamps too dim in the daytime).

For the battery box it should only require a log book sign-off, but then again it's up to the A&P installing. He may have you seek a field approval and do a 337.

As far as the circuit you mentioned, it's going to require a field approval. (good luck on that one)

 

[gismo]

Battery box no problem, log book entry is all that is needed. Circuit for interfacing is going to need some DAR work I think and then approval through the FSDO.

Dan

Why would a DAR be required for an owner produced part? In any case what I'm really asking is whether the rules for owner produced parts can be applied to something other than a repair.

 

[RotorAndWing]

Why would a DAR be required for an owner produced part? In any case what I'm really asking is whether the rules for owner produced parts can be applied to something other than a repair.

The simple answer is no. In any event if you produce something to install in your aircraft you will need approved or accepted data.

You will need a field approval to install.

 

[stingray]

Why would a DAR be required for an owner produced part? In any case what I'm really asking is whether the rules for owner produced parts can be applied to something other than a repair.

If the plane had a part as original equipment then all data has been applied for and approved. Nothing other than manufacture is needed.

If you are manufacturing a new part that has no data then data and approval is needed. The battery box is not a crucial part and does not tie into a crucial part. The wiring is and does so data and approval is needed.

Dan

 

[Tom-D]

The simple answer is no. In any event if you produce something to install in your aircraft you will need approved or accepted data.

You will need a field approval to install.

Nope.. for example, Cessna places the words "Made from 2024-T3" on many items in the IPB even though it has a part number listed.

Also read FAR 21.303

§ 21.303 Replacement and modification parts.
(a) Except as provided in paragraph (b) of this section, no person may produce a modification or replacement part for sale for installation on a type certificated product unless it is produced pursuant to a Parts Manufacturer Approval issued under this subpart.

(b) This section does not apply to the following:
(1) Parts produced under a type or production certificate.

(2) Parts produced by an owner or operator for maintaining or altering his own product.
(3) Parts produced under an FAA Technical Standard Order.

(4) Standard parts (such as bolts and nuts) conforming to established

you can manufacture a part you just can't sell it. I manufactured many parts of my F-24 using the blue prints , and installed using the AC 43,13 as return to service refference.

 

[RotorAndWing]

Nope.. for example, Cessna places the words "Made from 2024-T3" on many items in the IPB even though it has a part number listed.

Also read FAR 21.303

§ 21.303 Replacement and modification parts.
(a) Except as provided in paragraph (b) of this section, no person may produce a modification or replacement part for sale for installation on a type certificated product unless it is produced pursuant to a Parts Manufacturer Approval issued under this subpart.

(b) This section does not apply to the following:
(1) Parts produced under a type or production certificate.

(2) Parts produced by an owner or operator for maintaining or altering his own product.
(3) Parts produced under an FAA Technical Standard Order.

(4) Standard parts (such as bolts and nuts) conforming to established

you can manufacture a part you just can't sell it. I manufactured many parts of my F-24 using the blue prints , and installed using the AC 43,13 as return to service refference.

My answer was for a part that is not approved nor included in any STC or IPB. An owner cannot just produce a part, like the instance an electronic item and install it as "owner produced". This requires approved data.

 

[Tom-D]

My answer was for a part that is not approved nor included in any STC or IPB. An owner cannot just produce a part, like the instance an electronic item and install it as "owner produced". This requires approved data.

Blue prints, procedures in AC 43,13, procedures given in manufacturers manuals, ICAs are all approved data and do not require a FSDO or DER approval to be manufactured, or approved to return to service.

I can manufacture a complete wiring harness IAW the Cessna wire schematic, and replace the existing harness and nothing is required but a log book entry.

I can reproduce a complete gear leg for my F-24 as per the Fairchild blue print, using procedures given in the AC 43,13 and return it to service as a log book entry.

I can completely recover any aircraft using OEM material, and methods given in the maintenance manual, and return it to service on a 337 as a major repair, with out any DER/FSDO approval.

When a part is produced as a duplicate to OEM it is nether a modification or change to the TCDS. but you can not manufacturer these parts and sell them.

If you alter the manufacturing process or use materials other than the OEM you have altered the part, then you must gain approval for the change.

I've been thru this loop many many times. only modifications require new data.

 

[RotorAndWing]

Blue prints, procedures in AC 43,13, procedures given in manufacturers manuals, ICAs are all approved data and do not require a FSDO or DER approval to be manufactured, or approved to return to service.

I can manufacture a complete wiring harness IAW the Cessna wire schematic, and replace the existing harness and nothing is required but a log book entry.

I can reproduce a complete gear leg for my F-24 as per the Fairchild blue print, using procedures given in the AC 43,13 and return it to service as a log book entry.

I can completely recover any aircraft using OEM material, and methods given in the maintenance manual, and return it to service on a 337 as a major repair, with out any DER/FSDO approval.

When a part is produced as a duplicate to OEM it is nether a modification or change to the TCDS. but you can not manufacturer these parts and sell them.

If you alter the manufacturing process or use materials other than the OEM you have altered the part, then you must gain approval for the change.

I've been thru this loop many many times. only modifications require new data.

If you read what I've been writing that's exactly what I've been saying.

 

[Tom-D]

If you read what I've been writing that's exactly what I've been saying.

I read this and responded

"" My answer was for a part that is not approved nor included in any STC or IPB. An owner cannot just produce a part, like the instance an electronic item and install it as "owner produced". This requires approved data.""

 

[Tom-D]

IF Heath produced a Aviation radio kit, Could an owner assemble the kit and install it in a certified aircraft

 

[RotorAndWing]

I read this and responded

"" My answer was for a part that is not approved nor included in any STC or IPB. An owner cannot just produce a part, like the instance an electronic item and install it as "owner produced". This requires approved data.""

This was in response to:

Another instance would be making my own circuit for interfacing the marker beacon lamp driver in my audio panel with the indicator in my Baron (a direct connection makes the lamps too dim in the daytime).

 

[stingray]

If you read what I've been writing that's exactly what I've been saying.

Rotor&Wing you have it right.

I just got word back from the FSDO, they were very helpful and correct. No problem installing an owner manufactured part no paperwork needs to be sent to the FSDO only a log book entry. Also in my case I was replacing an AD strut from a Taylorcraft. Even if I build it to the new specs I still need to send in to the Office, Alternative Method of Compliance for approval to get rid of the AD. This also means that I may not even need to make a new part just find a procedure for approval to get rid of the AD.

Dan

 

[Let'sgoflying!]

Hundreds of struts are made by home builders every year. They are not that difficult to make. They are even easier if you have a pattern and the same parts that the manufacturer uses.

Yes, I realize anyone could make them, but my post was more in ref to the liability that follows that part. I would assume someone could name a part-producer even 30 years later. Even if a part you made did not cause the accident we have plenty of cases of lawsuits where the part maker was named following a "pilot-error crash". Perhaps they had deeper pockets but I would not be willing to even take that chance.

 

[stingray]

Yes, I realize anyone could make them, but my post was more in ref to the liability that follows that part. I would assume someone could name a part-producer even 30 years later. Even if a part you made did not cause the accident we have plenty of cases of lawsuits where the part maker was named following a "pilot-error crash". Perhaps they had deeper pockets but I would not be willing to even take that chance.

I am not letting lawyers run my life.

They could name you as previous owner of the plane that took it to the A&P that did the work, that installed a factory part. Just naming you is not good enough. They still have to prove that the part failed and failed within the scope of its design and manufacture. One thing I have learned about lawyers, they go after the money. They are not going to waste their time on a pilot that is so broke he has to make his own parts. If I manufactured a part and it failed within the scope of its design I deserve to be named. I plan to do my homework and make sure that it is designed to withstand twice what it has to. I do this not so much to not get named but so that I know I am flying the safest plane I can. You can at the time of sale, reinstall the old part. All of this is really a moot point because I found out today that I only have to come up with an Alternative Method of Compliance. (Fill with oil drain and seal) to eliminate the AD.

Dan

 

[Let'sgoflying!]

Sounds to me like you have it well-thought out, Dan.

 

[docmirror]

I am not letting lawyers run my life.

I plan to do my homework and make sure that it is designed to withstand twice what it has to. I do this not so much to not get named but so that I know I am flying the safest plane I can.

Dan

I agree completely with the lawyer comment. However, be careful about the design stress. Some parts on aircraft have designed in limits, such that they are sacrificial in case of a failure in another area. Not that this is likely with the strut, but an example would be the clevis pin in the retracting step on a Bonanza. The pin is designed to break if there is too much tension on the gear retract mechanism from the step. Other parts in aircraft are designed similarly. You also are fighting a weight handicap.

Soon, I'll be manufacturing a part for my plane. I'm not looking forward to it. The prints for most aircraft are locked in the mfgs vault and there is NO WAY they are going to let any Joe look at them, much less make a copy. That leads to reverse engineering from a part that is already out of spec, much like the strut on the 140 in the above article. We're caught in a catch-22. The mfg won't supply the part, nor will they supply the specs we need to make a part ourselves. So, we do the best we can with the leftovers from the plane.

All I can say is that I'm going to document the heck out of it, and keep everything I print so that if something fails down the road, I did my diligence.

 

[stingray]

All I can say is that I'm going to document the heck out of it, and keep everything I print so that if something fails down the road, I did my diligence.

Rather or along with reverse engineering it just engineer it from scratch. Get a good understanding what it needs to do and go from there. Match this with the reengineered data.

I have a head start because there are three companies making replacement struts along with the fact that there is nothing wrong with my struts. Failed strut was on a trainer seaplane, my strut has not seen the light of day for 20 years. EAA is a great place to start they have a wealth of info on designing parts.

Dan

 

[weirdjim]

IF Heath produced a Aviation radio kit, Could an owner assemble the kit and install it in a certified aircraft

Heath, before they went out of business, produced a clock and a strobe for aircraft.

RST Engineering (nee Radio Systems Technology) has been producing aircraft electronic devices for over 35 years in "kit" format including audio panels, intercoms, marker receivers, 6 channel transceivers, 360 channel transceivers, 720 channel transceivers, and more antennas than you can shake a stick at.

We've had folks install them as logbook entries (our recommended method) as well as 337 field approvals. In 1973 (our first year in business) we had a visit from the Friendly Aviation folks and the upshot was that if we ever had a real problem with our products they'd be back to see us with a padlock. THat was 35 years ago and so far, so good.

Jim

 

[Tom-D]

Heath, before they went out of business, produced a clock and a strobe for aircraft.

RST Engineering (nee Radio Systems Technology) has been producing aircraft electronic devices for over 35 years in "kit" format including audio panels, intercoms, marker receivers, 6 channel transceivers, 360 channel transceivers, 720 channel transceivers, and more antennas than you can shake a stick at.

We've had folks install them as logbook entries (our recommended method) as well as 337 field approvals. In 1973 (our first year in business) we had a visit from the Friendly Aviation folks and the upshot was that if we ever had a real problem with our products they'd be back to see us with a padlock. THat was 35 years ago and so far, so good.

Jim

I've bult 6 of your head sets all worked well, and 1 intercom, which didn't.

All the head sets are in the back seats of aircraft I fly, all still work, but I've used my Bose heads sets since 1993, and the intercom has been trashed.

 

[docmirror]

Rather or along with reverse engineering it just engineer it from scratch. Get a good understanding what it needs to do and go from there. Match this with the reengineered data.

I have a head start because there are three companies making replacement struts along with the fact that there is nothing wrong with my struts. Failed strut was on a trainer seaplane, my strut has not seen the light of day for 20 years. EAA is a great place to start they have a wealth of info on designing parts.

Dan

Sounds good to me. As long as it meets the requirements of the part it is replacing. In the case of a strut, you're going to need the tensile, ductile and compressibility ratings of the materials. Determine the loads in compression, extension, and tensile loads at attach points. Figure the safety margins, and select the materials to match.

Or, you could use the old part as a template, and match what you have.

 

[Stache]

Question: Does the owner have to manufacture the part himself, in order for the part to be considered an "owner produced" part?

Answer: No. An owner would be considered a producer of a part if the owner participated in controlling the design, manufacture, or quality of the part. The FAA would look at many factors in determining whether a person participated in. Controlling the design, manufacture, or quality of a part. The following would tend to indicate that a person produced a part:

1. The owner provided the manufacturer with design or performance data from which to manufacture the part. {This may occur, for instance, where a person provided a part to the manufacturer and asked that the part be duplicated.)
2. The owner provided the manufacturer with materials from which to manufacture the part.
3. The owner provided the manufacturer with fabrication processes or assembly methods to be used in the manufacture of the part.
4. The owner provided the manufacturer with quality control procedures to be used in the manufacture of the part.
5. The owner supervised the manufacturer of the part.

As noted above, prior to Amendment 21-41, FAR 21.303(a) prohibited each person producing a replacement or modification part for sale for installation on a type certificated product from doing so without holding a PMA. In Amendment 21-41, the FAA amended FAR 21.303(a) to allow a PMA holder to contract with a subcontractor or supplier to manufacture a modification or replacement part under the holder's PMA. In that amendment, the FAA recognized that a modification or replacement part can conform to the approved design data and be 'safe for installation on a type certificated product, as long as the part is produced under an approved fabrication inspection system (FIS).

Amendment 21-41 did not specifically address who "should have held the PMA" where the part was produced in "the absence of a PMA. However, any interpretation of FAR 21.303(a) should be consistent with the focus .in that amendment on the establishment and maintenance of the PIS; therefore, I submit that 21.303(a) creates liability for production of a modification or replacement part for sale for installation on a type certificated product for each person who:

1. Participates in controlling the design, manufacture, or quality of the part.
2. And does so with the intent that the part be sold for installation on a type certificated product.

The FAA would not construe the ordering of a part, standing alone, as participating in controlling the design, manufacture, or quality of a part.

If it was concluded that the mechanic produced the part for the purpose of effectuating .the repair, the question would remain whether the mechanic would be in violation of 21.303(a). I submit that the mechanic would not be in violation of 21.303(a), because, the mechanic did not produce the part for sale for installation on a type-certificated product.

Just one man's opinion.

 

[Stache]

There was a question ask about using a DAR to approve date on FAA Form 337's. There are 11 such DARs around the country who can sign block 3 instead of an FAA Inspector. This can be found in FAA Order 8u900.1 Vol 4, Ch 9 Section 1.

For the DAR there is a special code they must have and are considered Management DARs. The 11 DARs are mostly tied to major repair stations.