Unauthorized installed equip?

You can go down a long rat hole chasing stuff, throw lots of money away in the process and in the end it doesn't actually change the installation, the methods used, or measurably improve safety. What it does is create paperwork.
 
So does the iPad and the Garmin and the Sirius and the...

It seems that you are bound and determined to prove that this hypothetical landing light is illegal, that it can't possibly be legal but the documents you are using to support that contradict it. You seem to be saying it's perfectly okay if it's a GoPro, it just can't be a landing light.

A quote from the link you provided above addressing a question on external mounts for cameras:



I think you also need to understand a fundamental aspect of all of this that you seem to be missing. "determination is done on a case-by-case basis and made by the installer" In this hypothetical case there is a logbook entry made by the A&P for the installation of this landing light. It was determined to be a minor alteration and basically that's it. Dragging all of these documents out concerning PMA and TSO that do not apply is an exercise in futility. Nobody is asking to manufacture replacement aircraft parts here such as gear legs or door handles. As an A&P you have acquired the license, the responsibility and the authority to make specific decisions. You don't need to have the local FSDO on speed dial to call every time you want to do that. It's your right to refuse to make such an installation if you chose, even to refuse to sign of an annual if that's the way you want to go about it but you need to lighten up a bit.

I know, that's why i pointed out it has interesting wording :D.

And you and I both know a gopro and a landing light aren't really all that different, but does the ASI that ramp checks you agree? This is where I would like to have something to point out that directly addresses my concerns to an ASI that comes knocking.

I'm open to being proven wrong (and would love to, I too find a lot of this stuff annoying), but with the FAA's whole "right hand doesn't know what the left hand is doing" thing going on, I am going to need more than this if something Results in an action. What I've gotten was a list of documents that says it does have to be an approved/acceptable part. I did point out earlier that if it is an approved/acceptable part you can install it on logbook entry though!
 
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...What I've gotten was a list of documents that says it does have to be an approved/acceptable part...

What you have gotten are documents on Parts Manufacturer Approval which is an entirely different thing, not really an end user issue. This is for those who wish to manufacture and sell replacement parts for certificated aircraft or major alterations to them.

As for an ASI and a ramp check, you could spend your entire life worrying about all kinds of nit picky little things in that regard. If the light is determined to be a minor alteration and the logbook has a signed entry by a licensed A&P mechanic then what is the basis in deeming it unairworthy?

Then you are going to have to deal with the owner who has read ASTM F2490 − 05 and is convinced that no A&P mechanic out there is capable of conducting an electrical load analysis for a 100 watt landing light :rolleyes:
 
Is bolting or strapping a device onto a part of the airplane a modification?

If you were not required to alter the part, no it is not.

How was this gear modified? If I add a adel clamp to the engine mount to add a wire is that engine mount modified? = NO.

Tell me which part of the landing gear no longer looks like the blue print form which it was made?

Which part number would you place in block 8 of the 337 telling what was altered?

Attaching stuff to movable flight controls does modify the the flight control and when it alters the airflow over the flight control is a major modification, and one must prove it meets the criteria for flutter testing.
 
They won't bother the owner, they'll bother me. They will ask me under what authority did I have to install this airworthy part on that airplane. If I can't point to a specific document, they start asking a lot of questions. This isn't me worrying about possibilities, this is me witnessing these events firsthand in one of the shops I was helping in. Our local FSDO are real sticklers about approvals and stickers on everything and it's a pain in the ass.

I really, REALLY want to find a document that directly addresses being able to install any airworthy part on any aircraft, even if it lacks a specific installation approval. Basically, letting mechanics install parts just based on acceptable data*, and addressing minor vs major alterations. I want to be WRONG about my claim and what everyone who has been telling me on the phone, because that would make my life so much easier! I would be happy to write an apology letter to every single person in this thread who has been telling me I am wrong if I can find such a letter! But, it needs to directly address these points, because again, the FAA has a problem with the right hand not knowing what the left hand is doing, and of course, ASIs are not lawyers :)

*It's going to come up. I know, fabrication blah blah :). The FAA addresses fabrication and doesn't consider raw material as parts, and we're authorized to manufacture parts under 21.9(a)(5).
 
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Because it's a hypothetical question and in my hypothetical it doesn't. You can't counter that with "yea, but what if it does?"


When I am asked to approve a configuration, process, or material change at work (airline engineer), there are two questions I have to answer per FAA Approved company policy.

1 - Do I have the authority
2 - Do I have data to substantiate the requested change

We have to account for those two things in a written statement. Believe me some of the substantiations are better written than others.

I don't know what GA IAs are are told in their training. I assume IAs are responsible for performing QA craftsmanship, paperwork, completion checks.

Even in the hypothetical situation (alteration plus landing gear) I don't see where an A&P or IA has the approval authority to make the determination it has no effect, the way Part 43 Appendix A is written.
 
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They won't bother the owner, they'll bother me. They will ask me under what authority did I have to install this airworthy part on that airplane. If I can't point to a specific document, they start asking a lot of questions. This isn't me worrying about possibilities, this is me witnessing these events firsthand in one of the shops I was helping in. Our local FSDO are real sticklers about approvals and stickers on everything and it's a pain in the ass.

I really, REALLY want to find a document that directly addresses being able to install any airworthy part on any aircraft, even if it lacks a specific installation approval (basically, letting mechanics install parts just based on acceptable data), and addressing minor vs major alterations. I want to be WRONG about my claim and what everyone who has been telling me on the phone, because that would make my life so much easier! I would be happy to write an apology letter to every single person in this thread who has been telling me I am wrong if I can find such a letter! :)

The FAA gives you the authority to make the determination as to the airworthiness of parts, and their use when they gave you your A&P certificate.

They will never authorize you to make major alterations or modifications with out engineering to prove it is safe to operate.

And they trust you to know the difference.
 
The FAA gives you the authority to make the determination as to the airworthiness of parts, and their use when they gave you your A&P certificate.

They will never authorize you to make major alterations or modifications with out engineering to prove it is safe to operate.

And they trust you to know the difference.

Yes yes I know that. :p

Basically, it's coming down to these general conditions:

  • This is not a major alteration.
  • This IS an airworthy part (unairworthy part can't be used on TC a/c per 21.9)
  • I do not have a document (statement of conformity (this is a thing right?), AD, STC, OEM part, etc. etc. etc.) that this can be installed on this aircraft, but there is also no prohibition that I can find either.
  • This part does not appreciably affect the weight and balance, flight characteristics, etc.
Can I install it on this plane, given these conditions? Everyone that I am talking to on the phone (FSDO, AFS-300, the repair station) are all saying NO. They keep referencing the various regs and docs I'm linking. They keep saying that parts have absolutely nothing to do with 43 appendix A. I got off the phone with the FSDO airworthiness inspector today and he was also citing 43.13 (a) and (b), and talking about the airworthiness certificate and meeting the type design. I do feel like they are stretching their interpretations, but I can't afford to be wrong.

I'm considering writing to the chief council so I can put the issue to rest, and, if they support the position that we CAN install any airworthy part on any aircraft, as long as it is a minor alteration and at my discretion as an A&P, then I will be very happy! I will also have a very powerful document in my arsenal when the local ASIs ask questions about parts installations and who has the authority to determine if that part can be installed.
 
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Corey, I think you are wasting your time talking with folks at the FSDO. They are going to be in the CYA mode all the time and say things that may be different from how stuff works in real life.

You need to spend considerable time with a seasoned IA to find out how the system really works.
 
Corey, I think you are wasting your time talking with folks at the FSDO. They are going to be in the CYA mode all the time and say things that may be different from how stuff works in real life.

You need to spend considerable time with a seasoned IA to find out how the system really works.

I do, but he's also in CYA mode.

In fact, this forum is the first place that I've run into where people are saying we don't need an installation approval to install a part if it's a minor alteration. Everyone at school, and the three shops I've lent a hand to all have the same position that I've stated. I want the people on this forum to be right because it would make some things so much more simple :D!
 
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I'm considering writing to the chief council so I can put the issue to rest, and, if ....

Corey. this is not an attempt to be snarky here, but when (if) you do write the Chief Counsel please spell his title correctly. Little things sometimes go a long way.

-Skip
 
I wrote it as counsel, thought it looked funny, and changed it. Silly me :D
 
Hey Bruce!

This PMA got linked above:

http://www.tempestplus.com/Portals/0/PDFs/PMA All.pdf

That's an example for when I say "PMA Direct Replacement". It actually has part numbers and approval basis listed within the PMA itself, so I can use it as a basis for the installation.

Cool. The tread has gone in multiple directions. I need to go back and catch up on what I missed.

My own experience is that a lot of the FAA's rules make sense when you understand the entire process. Unfortunately, trying to formulate a general understanding of some processes from one-off experiences in Mx is hard because the underlying requirements are often not the same in each case and it's hard to reconcile the differences when you only occasionally see a little bit of it.

I believe that's where some of the "cargo cult" approach comes from. Still, I'm not proud, I accept help anywhere I find it.
 
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Hey Bruce!

This PMA got linked above:

http://www.tempestplus.com/Portals/0/PDFs/PMA All.pdf

That's an example for when I say "PMA Direct Replacement". It actually has part numbers and approval basis listed within the PMA itself, so I can use it as a basis for the installation.

In our hypothetical case you are not "replacing" a part, not a torque link or a steering rod or a pump. Also let's keep in mind we aren't talking about part 121 operations where you wouldn't even be allowed to use a single engined aircraft to begin with.

As is typical this discussion has gone completely out of scope.
 
In our hypothetical case you are not "replacing" a part, not a torque link or a steering rod or a pump. Also let's keep in mind we aren't talking about part 121 operations where you wouldn't even be allowed to use a single engined aircraft to begin with.

As is typical this discussion has gone completely out of scope.

It was a side conversation and was one of the things I had included in my blanket statement in my first post. As bruce said, this topic has gone in all sorts of directions :D
 
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Yes yes I know that. :p

Basically, it's coming down to these general conditions:

  • This is not a major alteration.
  • This IS an airworthy part (unairworthy part can't be used on TC a/c per 21.9)
  • I do not have a document (statement of conformity (this is a thing right?), AD, STC, OEM part, etc. etc. etc.) that this can be installed on this aircraft, but there is also no prohibition that I can find either.
  • This part does not appreciably affect the weight and balance, flight characteristics, etc.
Can I install it on this plane, given these conditions? Everyone that I am talking to on the phone (FSDO, AFS-300, the repair station) are all saying NO. They keep referencing the various regs and docs I'm linking. They keep saying that parts have absolutely nothing to do with 43 appendix A. I got off the phone with the FSDO airworthiness inspector today and he was also citing 43.13 (a) and (b), and talking about the airworthiness certificate and meeting the type design. I do feel like they are stretching their interpretations, but I can't afford to be wrong.

I'm considering writing to the chief council so I can put the issue to rest, and, if they support the position that we CAN install any airworthy part on any aircraft, as long as it is a minor alteration and at my discretion as an A&P, then I will be very happy! I will also have a very powerful document in my arsenal when the local ASIs ask questions about parts installations and who has the authority to determine if that part can be installed.

Do you realize that the type design has a list of authorized parts for that make and model aircraft? any deviance to the parts listed there should have data as to their application.

Just because the part is PMA, or TSOed does not mean it is in the list of authorized parts for that make and model.

The best argument for a Major alteration is "That is does change the type design" It was not sent out the factory door equipped that way. so it is a alteration, its simply a matter of is it a major or minor and how it is documented.

There are a great many parts that have been up graded by AD, or have been superseded by up grades to the material.

Be very careful what you ask C/C, you just get it and screw the rest of us that do understand the rules.
 
I'm considering writing to the chief council so I can put the issue to rest,

I would suggest, that prior to writing Chief Council (sic) that you buy a copy of Richard Bach's "Gift of Wings" and read "Found at Pharisee", a chapter in the book. Read it . Read it again. Think about it.

Now think about who you are. A young snot-nosed kid (you should pardon the expression of course) who has met half a dozen IAs in this group, most of whom have more time in grade than you have years on the planet. We've been around the FAA maypole a few times. We've been in the aviation business all of our lives and have some ways of dealing with mods to aircraft that aren't covered in the books you read in school. Nor in those "discussions" that you just might have forced into a contrary opinion.

Give it a rest. Get a few years into this business. Then if you have a legitimate question ask the General Counsel their considerate opinion. Right now you have no basis to ask the question.

Jim
 
Asking chief counsel? Why not ask your FSDO? That's who you need to work with isn't it?
 
...I'm considering writing to the chief council so I can put the issue to rest...

:rolleyes: First of all, the CC is not the venue to air hypothetical "what ifs". Secondly, go back and read the document you posted a link to earlier that had Q&A's on the mounting of electronics in the cockpit and external airframe. In fact, read that a couple of times until it sinks in and you realize that there is not an answer there to be found. Lots of words arranged in subtle and crafty ambiguity that leave you thinking "huh?" :dunno:

Now you may someday come across an issue that will require you to seek guidance or advise from a manufacturer or your FSDO, possibly even the Chief but certainly not for something as trivial as this. When that day comes I'll give you an idea of how it's generally going to work out:

You'll spend the first week or so conducting a number of back and forth correspondences the result of which will be to bring your contact up to speed on what you already know. Follow that up with continued back and forth discussions that more likely than not will leave you scratching your head as to what their answer actually was. You'll find it very difficult to pin them down and they may simply blow you off by making an absurd recommendation.

Of course this isn't in every case but in a large majority of them this is how it pans out. Above all you don't want to be the kid who's always putting his hand up in class trying to impress the teacher on how smart he is. Use you delegated authority to make decisions and if you want to be conservative in those choices that's your prerogative. That's why you have the license.
 
I'm done. I'm done mudrassling with this pig. I get all dirty and the pig likes it.

You guys take it from here. Some day this little lady is going to get the picture of how the real world operates. Until then ... have fun.

Jim
 
Asking chief counsel? Why not ask your FSDO? That's who you need to work with isn't it?

I did, two people. Said that before. In fact, after my first post and people said it isn't true, they were the first call I made. This is why I would love to have something absolutely definitive to show the ASI that comes around from time to time.

That's also why I don't honestly give two ****s about how much experience people here have. I've been screwed already by someone with "years of experience", and two friends of mine just got royally ****ed with a travel air and lost tens of thousands from a prebuy by a guy who had "years of experience".

This is why I seek to have definitive answers, or at least very good from a legally defensive perspective, and why I refuse to accept "years of experience" and "this is how it's done" as reasons. In the end, it's the way the ASIs interpret the regs that will result in attempts at enforcement action. Even if I win in court, I still lose.

As for writing the CC: I said I might. I know it's a very sharp double edge sword, and if I end up being right (or rather, how they think it is right, not the first time there's been a redacted interpretation), it would throw a lot of people under the bus.
 
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Do it however you want, you are apparently unable to make your own interpretations and decisions. You've already been to the FSDO twice and still don't have your "definitive" answer.

Maybe you should ask the President ? :dunno:
 
Do it however you want, you are apparently unable to make your own interpretations and decisions. You've already been to the FSDO twice and still don't have your "definitive" answer.

Maybe you should ask the President ? :dunno:

Because the FSDO says one thing, yet everyone here says another. I acknowledge the FSDO guys are not lawyers. I'm sharing the answers I'm getting, and reading what you guys post back. I was hoping a legal document would come up supporting one position or another outright, rather than leave hints and trails. Context is important in the legal world, so cutting snippets out of ACs is a risky avenue.
 
You've already been to the FSDO twice and still don't have your "definitive" answer.
Simply because there isn't one, and that is a good thing, they leave it up to us to make these decisions. Some know how to do that, using the data we have, and some don't.
 
Because the FSDO says one thing, yet everyone here says another. I acknowledge the FSDO guys are not lawyers. I'm sharing the answers I'm getting, and reading what you guys post back. I was hoping a legal document would come up supporting one position or another outright, rather than leave hints and trails. Context is important in the legal world, so cutting snippets out of ACs is a risky avenue.
I think you are missing the whole freaking point. the data is already in use. Either the part is a portion of the type design or it isn't, if it isn't, what data placed it on the aircraft? If there is no authorization it is not authorized to be used on that aircraft, no matter where it came from or who made it.

Best example a simple old 172 / 0-300 some have generators, some have alternators. each will interchange with out alteration. yet we can not simply up grade the old generators with out a STC/or field approval. simply because of the usable on codes that Cessna places in the IPC.
 
I think you are missing the whole freaking point. the data is already in use. Either the part is a portion of the type design or it isn't, if it isn't, what data placed it on the aircraft? If there is no authorization it is not authorized to be used on that aircraft, no matter where it came from or who made it.

Best example a simple old 172 / 0-300 some have generators, some have alternators. each will interchange with out alteration. yet we can not simply up grade the old generators with out a STC/or field approval. simply because of the usable on codes that Cessna places in the IPC.

????????????????????????????????????????????? Isn't this what I've been saying all along? If it doesn't have some sort of approval/acceptance (I like your word authorization, that seems like a much better word), then it can't be put on the aircraft?

Also, I know I didn't explicitly say type design at all, but that was meant to be lumped in with the TCDS and TC related stuff.

Another interesting event (somewhat related) would be magnetos on an engine that can accept both bendix and slick mags on an engine that lists both in the TCDS. I was involved with an IA where we were discussing the installation of bendix mags on a Diamond DA-40. Diamond was screaming that it's not allowed etc, etc, etc, and the FAA got involved. The IA asked me on the issue for reassurance and I told him I strongly believe that the TCDS of the engine trumped what the aircraft manufacturer says (unless an AD or some sort of airworthiness limitation says otherwise as an example), and it got high up the chain at the FAA. In the end, we were judged to be right, and diamond wrong.

That DA-40 runs so much better now and is easy to start.
 
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????????????????????????????????????????????? Isn't this what I've been saying all along?

Also, I know I didn't explicitly say type design at all, but that was meant to be lumped in with the TCDS and TC related stuff.

If it is, what's the problem?

The TCDS will not authorize you to use any parts, it is just a list of options that can be placed on the aircraft that are not alterations. The rest of the TCDS is operation limits and such.

Fuel pump 12345-6 and fuel pump 12345-7 made for two different aircraft and listed in each aircraft's IPC under the specific P/N..

Can they be interchanged without an STC of Field approval?
 
Another interesting event (somewhat related) would be magnetos on an engine that can accept both bendix and slick mags on an engine that lists both in the TCDS. I was involved with an IA where we were discussing the installation of bendix mags on a Diamond DA-40. Diamond was screaming that it's not allowed etc, etc, etc, and the FAA got involved. The IA asked me on the issue for reassurance and I told him I strongly believe that the TCDS of the engine trumped what the aircraft manufacturer says (unless an AD or some sort of airworthiness limitation says otherwise as an example), and it got high up the chain at the FAA. In the end, we were judged to be right, and diamond wrong.

That DA-40 runs so much better now and is easy to start.

With out that letter from the FAA the mag swap would be illegal. the Aircraft manufacturer sets the type design, and the TCDS sets the alternate P/Ns and equipment. Changing the mags from Slick to TCM on a Lycoming actually changes the engine model.

see 43-A as to what it requires to change the model of any engine.
 
If it is, what's the problem?

I don't know. This topic is all over the place now and I don't know who is responding to what, and people have been coming and going in the middle of it and I've had to repeat the same thing a few times :/

The TCDS will not authorize you to use any parts, it is just a list of options that can be placed on the aircraft that are not alterations. The rest of the TCDS is operation limits and such.

Can you elaborate? Why wouldn't the "list of options that can be placed on the aircraft" in this approved (a real approval) document be used as a basis for installing or changing those parts?

Fuel pump 12345-6 and fuel pump 12345-7 made for two different aircraft and listed in each aircraft's IPC under the specific P/N..

Can they be interchanged without an STC of Field approval?

IPC is for finding manufacturer part numbers and seeing assembly diagrams. I was taught it cannot be used as a basis for alteration as it is neither approved nor acceptable data. For that reason, I'd say we would need something else to make this determination.

With out that letter from the FAA the mag swap would be illegal. the Aircraft manufacturer sets the type design, and the TCDS sets the alternate P/Ns and equipment. Changing the mags from Slick to TCM on a Lycoming actually changes the engine model.

see 43-A as to what it requires to change the model of any engine.

I am pretty sure that they do have that letter.

I'm going to ask about those events again. I do remember being shown briefly what looked to be a TCDS which listed the bendix model magneto, but now that I think about it, I didn't look too closely (he's an IA and I was just a "snot nosed brat" only a year into school at the time :p). I just pulled up the TCDS for the engine models that get fitted to DA40s that I know of, and I don't see a single engine model that has both slick and bendix mags, so I am really confused as to what document I saw...

By the way, you said a type design has a list of parts. Are you referring to a specific document that lists out these parts or something? Or the collective engineering data such as the drawings of the various parts of the aircraft?
 
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Can you elaborate? Why wouldn't the "list of options that can be placed on the aircraft" in this approved (a real approval) document be used as a basis for installing or changing those parts?

The equipment listed in the TCDS are already approved, why would you want to have them approved again. Alternate engines, skis, floats, any items listed in the TCDS only require a maintenance record entry to install.


IPC is for finding manufacturer part numbers and seeing assembly diagrams. I was taught it cannot be used as a basis for alteration as it is neither approved nor acceptable data. For that reason, I'd say we would need something else to make this determination.

Show me the reference where the IPC can not be used as approved data? Many times equipment can be set to different configurations, and the dash number changed simply be the manufacturers SB.



By the way, you said a type design has a list of parts. Are you referring to a specific document that lists out these parts or something? Or the collective engineering data such as the drawings of the various parts of the aircraft?
Tell me why we have a IPC, if it isn't a list of parts that make up the aircraft as certified.
 
Tom, I am so confused. I feel like we're saying the same thing. I'm tripping over my wording, and maybe that's where all this confusion is coming from.

If it's in the TCDS, that is our basis for installation*; I worded that poorly, I did not mean basis for approval, since that part was already done :). As you said, logbook entry only. (*yeah I know, it's not an industry standard term, again, tripping over wording)

The IPC is, as mentioned prior, used as a part number reference and assembly reference. The maintenance manual is acceptable data, the structural repair data is approved data (if it has the proper signatures and stamps), but the IPC has always been something extra. BUT, as an example, if the mx manual references something in the IPC, then that reference becomes acceptable too. Same with approved data making references to the IPC.

Couple references stating the IPC isn't approved nor acceptable:
One reference (bottom of page 48)
Second reference (question 18)
This was also in my jeppesen book.

As a sidenote, you're asking me to prove the IPC not approved or acceptable. Proving a negative is extremely difficult to do (one of the reasons this whole thread has gone crazy; it's really damn hard to prove negatives). Rather, it would be a lot easier to find references stating what IS acceptable/approved data and make an inference.

Anyways, I do use the IPC as a reference to find out about parts and assembly, but since it's neither approved nor accepted, then technically speaking, it can't be used to determine part interchangeability. If we were asked questions on why we installed a part, and we only said it was listed in the IPC, then we could get nailed. I seriously doubt anyone would make a stink about it though, since, as you said, it's a layout of the parts used in a type design. I have no freaking idea why the IPC isn't considered at least acceptable data. Maybe the reason is it doesn't have any oversight or quality control?
 
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Tell me why we have a IPC, if it isn't a list of parts that make up the aircraft as certified.

The IPC isn't regulatory.

Take a look at the external placard installation for a British design like the Hawker 800XP, which was still in production till a few years ago. Their manuals suck period. It shows placards where they don't belong, such as "NO STEP" on the nose gear doors. That level of correctness and detail encompasses the entire IPC.

That's just one example. There are many other aircraft manuals that suck.
 
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The IPC isn't regulatory.

Try using parts that are not listed in it and see what happens.
Simply because the IPC isn't a FAR does not mean it is not a list of authorized P/Ns to use on that Make and Model.
 
Try using parts that are not listed in it and see what happens.
Simply because the IPC isn't a FAR does not mean it is not a list of authorized P/Ns to use on that Make and Model.

Try it with an old piper. The part numbers in the IPCs haven't been updated in many years. I *think*, as an example, air filters are also completely different from the old designs from 50 years ago, and everyone has to use a freaking table to find the new parts. It's a pain in the ass and I often just call a distributor for the new part #s. But, it is a case in point! :)
 
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Five pages of this thread have accomplished absolutely nothing.

On the contrary. I've been reading, researching, learning. There's a lot of interesting things I've found that I didn't know in the course of this thread, including a rather interesting repair station interpretation that a friend loved when I showed it to him.
 
Try it with an old piper. The part numbers in the IPCs haven't been updated in many years. I *think*, as an example, air filters are also completely different from the old designs from 50 years ago, and everyone has to use a freaking table to find the new parts. It's a pain in the ass and I often just call a distributor for the new part #s. But, it is a case in point! :)

Type certificate is owned by Univair, they change it as they wish to include what ever they sell.
 
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