Seat Belt TSO tag

brien23

brien23

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Display name:
Brien
Old seat belt TSO tag torn off any good place to send it for a new tag or re web of the belt. Not sure how the FAA considers this a major repair and who can put a new tag on the seat belt but they do. Note if your tag is missing on your seat belt you aircraft in not airworthy? I think this is the FAA version of if you tear the tag off your bed, mattress is a federal crime.
 

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There are many repair stations in the USA that can reweb seatbelts for USA registered aircraft.

http://lmgtfy.com/?q=aircraft+seat+belt+rewebbing

Tag worn off? That's a purely argumentative question. Millions of parts have the identification painted over, worn off, damaged, faded, destroyed etc. It was airworthy when installed, its still airworthy if:

  • Not a life limited part, which requires positive identification and tracking, or can be tracked back to the last maintenance release with times & cycles recorded and total accumulated times & cycles can be summed.
  • No Airworthiness Directive requiring similar as above.
  • Still operating and functioning properly.
 
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brien23 said:
Note if your tag is missing on your seat belt you aircraft in not airworthy?
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Yes it is still airworthy. There was a FAA notice/order on this years ago and I believe there's an AC that gives guidance also. But a missing or illegible tag is not cause for removal. However, if you still want to reweb, AmSafe is a good option.
 
bnt83 said:
There are many repair stations in the USA that can reweb seatbelts for USA registered aircraft.

http://lmgtfy.com/?q=aircraft+seat+belt+rewebbing

Tag worn off? That's a purely argumentative question. Millions of parts have the identification painted over, worn off, damaged, faded, destroyed etc. It was airworthy when installed, its still airworthy if:

  • Not a life limited part, which requires positive identification and tracking, or can be tracked back to the last maintenance release with times & cycles recorded and total accumulated times & cycles can be summed.
  • No Airworthiness Directive requiring similar as above.
  • Still operating and functioning properly.
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With out a tag, how do you know it is the belt that came as part of the OEM equipment?
It isn't like these belts are fastened to the aircraft in a manor that would be apparent if it were changed?

Now repair of a belt as a major, I have a problem with.
 
Send your defective belts (include TSO tags) and all hardware to: AERO FABRICATORS, P.O. Box 181, 1216 North Road, Lyons, WI 53148

Can't use these guys when you don't have a tag. betcha lots of other places are the same.
 
brien23 said:
Old seat belt TSO tag torn off any good place to send it for a new tag or re web of the belt. Not sure how the FAA considers this a major repair and who can put a new tag on the seat belt but they do. Note if your tag is missing on your seat belt you aircraft in not airworthy? I think this is the FAA version of if you tear the tag off your bed, mattress is a federal crime.
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Just buy a set of BAS shoulder harness and install them. Safest, most cost effective solution.
Better than getting your ticket busted trying to save buck.
 
Tom-D said:
With out a tag, how do you know it is the belt that came as part of the OEM equipment?
It isn't like these belts are fastened to the aircraft in a manor that would be apparent if it were changed?
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Can't the same be said for virtually every part on the airplane? Unless the A&P has reason to believe it's been changed (red flags, such as new hardware, belts that are clearly newer than the logbooks would show, etc.), seems that the safe assumption is that absent a logbook entry showing the belts were changed out, those are the OEM belts.
 
bradg33 said:
Can't the same be said for virtually every part on the airplane? Unless the A&P has reason to believe it's been changed (red flags, such as new hardware, belts that are clearly newer than the logbooks would show, etc.), seems that the safe assumption is that absent a logbook entry showing the belts were changed out, those are the OEM belts.
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Not really Lots of parts would be readily seen as new or changed, seat belts not so much.
Lots of work now being done by the owners with no supporting paper.
I'm a firm supporter of BAS shoulder harnesses.
My Friend Roger had shoulder harnesses in this cub and lived thru it. hurt but alive.
 

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Bell206 said:
Yes it is still airworthy. There was a FAA notice/order on this years ago and I believe there's an AC that gives guidance also. But a missing or illegible tag is not cause for removal. However, if you still want to reweb, AmSafe is a good option.
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Without identification you have no clue as to what it is. How do you tell if it is bogus or not?
 
Tom-D said:
How do you tell if it is bogus or not?
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How do you tell if the installed carpet or seat covers are legal or bogus?

As I mentioned, there is existing FAA guidance to assist you in making that determination. It is plainly stated, that missing or unreadable tags/markings is not a disqualifying reason for part removal or airworthiness determination.
 
Bell206 said:
How do you tell if the installed carpet or seat covers are legal or bogus?

As I mentioned, there is existing FAA guidance to assist you in making that determination. It is plainly stated, that missing or unreadable tags/markings is not a disqualifying reason for part removal or airworthiness determination.
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Oh get real, how could a carpet or seat cover be a safety item.
 
Tom-D said:
Oh get real, how could a carpet or seat cover be a safety item.
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This is as real as it gets--when it catches on fire. Which is why it needs to meet an FAA mandated burn rate. There is no option on the burn test like a missing tag on a seatbelt.

These are not my personal opinions when it comes to TSO tags but the FAA's. Now whether you choose to believe in this reality is your own decision.

"6. Guidance.
a. Operations and Maintenance. The following guidance for ASIs concerns the absence of identification data on a part (including but not limited to PMA and TSOA articles) and the subsequent re-marking of these components.
(1) Part marking is not essential for determining the continued airworthiness of an in-service article..."

"6. GUIDANCE.
a. Absence of Identification Data.
(1) The FAA provides the following guidance with regard to the absence of identification data on a part (even if the part was required to be marked at the time of production) and the subsequent re-marking of these parts.
(a) Part marking is not essential for determining the continued airworthiness of an in-service article..."
 
Bell206 said:
This is as real as it gets--when it catches on fire. Which is why it needs to meet an FAA mandated burn rate. There is no option on the burn test like a missing tag on a seatbelt.

These are not my personal opinions when it comes to TSO tags but the FAA's. Now whether you choose to believe in this reality is your own decision.

"6. Guidance.
a. Operations and Maintenance. The following guidance for ASIs concerns the absence of identification data on a part (including but not limited to PMA and TSOA articles) and the subsequent re-marking of these components.
(1) Part marking is not essential for determining the continued airworthiness of an in-service article..."

"6. GUIDANCE.
a. Absence of Identification Data.
(1) The FAA provides the following guidance with regard to the absence of identification data on a part (even if the part was required to be marked at the time of production) and the subsequent re-marking of these parts.
(a) Part marking is not essential for determining the continued airworthiness of an in-service article..."
Click to expand...

Effective 6/5/09 Cancelled 6/5/10 is this still valid?
 
brien23 said:
Effective 6/5/09 Cancelled 6/5/10 is this still valid?
Click to expand...
The Order was cancelled when the data was included in another document. AC 43-213 Change 1 is still valid and is the primary reference to use on our end. The local FSDO will probably know the other document if you need it, but there is also a Letter of Interpretation on the subject which is still valid.
 
brien23 said:
I noticed it was cancelled 6/5/2010 is any of it still valid, I can only hope so.
Click to expand...

It says on the bottom "this notice will be incorporated before the cancellation date".

You guys are a tough crowd to please even with legit spoon fed answers.
 
bnt83 said:
So? Do you mark the covers with a the burn cert? Do you attach a tag to the interior parts have been burn tested?
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It isn't a matter of what I do, it is a matter of whats legal.
You guys try to spin this to seats and upholstery. Why ?

The FAA has given us their opinion, Go argue with them.
 
From the AC
5. GUIDANCE.
a. Absence of Identification Data.

(1) The FAA provides the following guidance with regard to the absence of identification data on a part (even if the part was required to be marked at the time of production) and the subsequent re-marking of these parts.

(a) Part marking is not essential for determining the continued airworthiness of an in-service article, provided the operator and/or its maintenance provider can determine that it conforms to its approved design and is in condition for safe operation.

How are you going to comply with that with no identification, Are you going to go thru the whole process of proving that an old belt is safe to use? Sounds to me like a way to spend $100 bucks to save a dime.
 
Tom-D said:
From the AC
5. GUIDANCE.
a. Absence of Identification Data.

(1) The FAA provides the following guidance with regard to the absence of identification data on a part (even if the part was required to be marked at the time of production) and the subsequent re-marking of these parts.

(a) Part marking is not essential for determining the continued airworthiness of an in-service article, provided the operator and/or its maintenance provider can determine that it conforms to its approved design and is in condition for safe operation.

How are you going to comply with that with no identification, Are you going to go thru the whole process of proving that an old belt is safe to use? Sounds to me like a way to spend $100 bucks to save a dime.
Click to expand...


Fact is an 8130, TSO tag, packing slip and CofC isn't an airworthiness determination, it's simply traceability, which can be fraudulent. A brand new gyro will have the proper paperwork and tags, but may have been damaged in shipping. A brand new $10k main ship battery may be flat dead from improper storage.

Keep cherry picking the guidance.
 
Tom-D said:
How are you going to comply with that with no identification
Click to expand...
Read the whole AC... it references a few more options then what you highlighted in red for your benefit.

If you don't agree with the AC then make your customers buy new seatbelts. Simple. If you want to help your customers out--legally--then follow the AC. Simple. Or talk to your friendly local ASI for assistance. But from your previous comments it seems the Seattle FSDO is stuck in the dark ages.

But that is my opinion.

Bottom-line, there are hundreds, if not thousands of seatbelts flying today that have degraded or missing tags... even on Part 121 aircraft, who by the way, are the ones that brought this issue to the forefront back in 2008/2009.
 
brien23 said:
Old seat belt TSO tag torn off any good place to send it for a new tag or re web of the belt. Not sure how the FAA considers this a major repair and who can put a new tag on the seat belt but they do. Note if your tag is missing on your seat belt you aircraft in not airworthy? I think this is the FAA version of if you tear the tag off your bed, mattress is a federal crime.
Click to expand...
Look in the Wag Aero catalog. IIRC it's about $50 ea. to re-web your belts.
 
Bell206 said:
Read the whole AC... it references a few more options then what you highlighted in red for your benefit.

If you don't agree with the AC then make your customers buy new seatbelts. Simple. If you want to help your customers out--legally--then follow the AC. Simple. Or talk to your friendly local ASI for assistance. But from your previous comments it seems the Seattle FSDO is stuck in the dark ages.

But that is my opinion.

Bottom-line, there are hundreds, if not thousands of seatbelts flying today that have degraded or missing tags... even on Part 121 aircraft, who by the way, are the ones that brought this issue to the forefront back in 2008/2009.
Click to expand...
1 simple question, When you look at an old belt, that has no identification, How would you determine airworthiness?
to use the AC you'd be required to do one of these
again from the AC

(2) When identification data is no longer visible, the operator or maintenance provider must determine, through other means, the article’s identity and airworthiness status. Frequently, airworthiness can be established by other means, including, but not limited to:

  • Maintenance records (these may be sufficient to determine the part’s identity and airworthiness status),
    There is nothing in the records mentioning seat belts

  • Visual and/or other types of inspection methods (e,g,, dimensional inspection, operational or functional checks, nondestructive testing, etc.),

    Yep we looked at the belt, looks old, but how are you going to do a functional test? Or are you going to remove it and have it pull tested?

  • Reference to an IPC and/or manufacturer’s, owner’s, or operator’s maintenance manual/component maintenance manual (CMM),
    The IPC gives a part number With no ID on the belt, how do we know what it is>?

  • Knowledge that the article received an appropriate incoming inspection and remains within the control of the same owner, operator, or maintenance provider, etc.
    I don't believe any of us saw the belts go into any aircraft at the factory.

    I simply do not believe you can tell what a seat belt is with out an ID of some sort. So I'm not putting my IA on the line for some thing as cheap as a set of new belts.

    In fact it is my belief that the FAA should mandate retro-fit of shoulder harnesses for all GA.
 
Tom-D said:
1 simple question, When you look at an old belt, that has no identification, How would you determine airworthiness?
Click to expand...
Ha. Maybe compare it to a known belt? The key is to try. But its obvious you prefer to spend your customers money instead of trying to save it.

Tom-D said:
I simply do not believe you can tell what a seat belt is with out an ID of some sort.
Click to expand...
Have you ever tried?

Tom-D said:
In fact it is my belief that the FAA should mandate retro-fit of shoulder harnesses for all GA.
Click to expand...
I think the above statement sums up the reason for all your red font in the previous post.

What I find comical is if anyone presents an alternate, yet legal way, to correct a problem, like owner prop paint touch-up or a discussion on the options of owner produced parts, you break out that red font, reading/comprehending only what you want/can, and follow your post with your signature sign-off:
Tom-D said:
I'm not putting my IA on the line...
Click to expand...

And that is your right as an IA.

However, it becomes more circus-like when you state:
Tom-D said:
It isn't a matter of what I do, it is a matter of whats legal.
Click to expand...

... then why when you perform an identical/similar task to some fanfare and at times near the fringes of acceptable guidance, I don’t see any red font? So tell me, on the parts you recently fabricated for a repair, did you run them through your Quality System before installation as required by the FARs? Or, on the Fairchild parts you manufactured, are they marked appropriately as per appropriate guidance? Will I be able to disassemble those struts and determine the springs are legal by their markings? If not, does the log entry define them as owner produced and list their P/N? From what I've seen in the short time I've been posting here, I think you missed your calling as a lead FBI investigator or maybe even the Director.

This post started when a person asked about seatbelt tags. Several options were presented to get him a solution. But instead of a simple answer on your part, the red font appeared because in your opinion all GA seatbelts should be replaced. I think that is a disservice to brein23 and others who are looking for other options.

But what do I know. Maybe it would just be easier for you to follow your own advice here and save the red ink?
Tom-D said:
The FAA has given us their opinion, Go argue with them.
Click to expand...
 
Bell206 said:
Read the whole AC... it references a few more options then what you highlighted in red for your benefit.

If you don't agree with the AC then make your customers buy new seatbelts. Simple. If you want to help your customers out--legally--then follow the AC. Simple. Or talk to your friendly local ASI for assistance. But from your previous comments it seems the Seattle FSDO is stuck in the dark ages.

But that is my opinion.

Bottom-line, there are hundreds, if not thousands of seatbelts flying today that have degraded or missing tags... even on Part 121 aircraft, who by the way, are the ones that brought this issue to the forefront back in 2008/2009.
Click to expand...

Well said! :)

Tom-D said:
1 simple question, When you look at an old belt, that has no identification, How would you determine airworthiness?
to use the AC you'd be required to do one of these
again from the AC

(2) When identification data is no longer visible, the operator or maintenance provider must determine, through other means, the article’s identity and airworthiness status. Frequently, airworthiness can be established by other means, including, but not limited to:

  • Maintenance records (these may be sufficient to determine the part’s identity and airworthiness status),
    There is nothing in the records mentioning seat belts

  • Visual and/or other types of inspection methods (e,g,, dimensional inspection, operational or functional checks, nondestructive testing, etc.),

    Yep we looked at the belt, looks old, but how are you going to do a functional test? Or are you going to remove it and have it pull tested?

  • Reference to an IPC and/or manufacturer’s, owner’s, or operator’s maintenance manual/component maintenance manual (CMM),
    The IPC gives a part number With no ID on the belt, how do we know what it is>?

  • Knowledge that the article received an appropriate incoming inspection and remains within the control of the same owner, operator, or maintenance provider, etc.
    I don't believe any of us saw the belts go into any aircraft at the factory.

    I simply do not believe you can tell what a seat belt is with out an ID of some sort. So I'm not putting my IA on the line for some thing as cheap as a set of new belts.

    In fact it is my belief that the FAA should mandate retro-fit of shoulder harnesses for all GA.
Click to expand...

Good grief!! :confused: Beyond seat belts, what other items will Tom demand to be changed? Carpet, headliner, seats, control wheels, flight control cables, windows, ...!
 
JAWS said:
Good grief!! :confused: Beyond seat belts, what other items will Tom demand to be changed? Carpet, headliner, seats, control wheels, flight control cables, windows, ...!
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Another slam at me for insisting my customers have their equipment in proper condition.

But I did notice you didn't answer the question.
 
Bell206 said:
But what do I know. Maybe it would just be easier for you to follow your own advice here and save the red ink?
Click to expand...
If you feel that your opinion on what's good and what is not when you have no identification, that is your option. To me that is simply guessing what's good and what isn't.
I think more of my customers than that. There isn't a single one of them that has a questionable part in their aircraft. And it is done that way for a reason, and that's the way they want it.
 
Not a slam, just an observation.

There are hundreds of parts on an aircraft that do not carry part numbers or tags and yet they remain in service. Aircraft carpet and seat coverings are but two.

Earlier you mentioned:
Tom-D said:
Oh get real, how could a carpet or seat cover be a safety item.
Click to expand...

Then stated:
Tom-D said:
Actually you can do burn tests on them.
Click to expand...

So is this what you do on every annual? ;)

I highly doubt it.
 
Piper Aztec manual ? how irrelevant, you should quote your own regs 201.12
 
To those who are still following.

What is legal isn't always safe, What's safe isn't always legal.

So you can argue that parts and equipment can be legal, But who wants their aircraft maintained to the minimum standard?
those who do, can find some one else :)
 
Many planes in the GA fleet should have their seat belts changed. They don't last forever. I use Hooker Harness for my belts.
 
Isn’t there a stress limit aircraft seat belts are required to meet? I’ve read where older belts that get tested usually fail and the failure is at the sewing, not the webbing. I thought there was a recommendation somewhere for an age limit for belts as a result? Maybe it was from a manufacturer, not the FAA?
 
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