What would happen?

U

Unregistered

Guest
(Not the appropriate forum, but I wanted anonymity.)
Let's say I buy a 1950s-60s single-engine piston airplane. Decent plane with no shoulder belts.

Let's suppose I add my own shoulder belts. Let's suppose I do it correctly, with correct parts (FIA/SFI or Aviation-specific). Let's suppose I then crash.

The shoulder belts help greatly and I avoid injury. But, they're not legal - no STC/paperwork and not installed by an A&P.
What happens? Will the FAA go after me? On what grounds?

Let's say I get an A&P to do the installation, but no STC or paperwork. Again, there's an incident and the illegal shoulder belts undoubtedly eliminate injury.
What happens? Will the FAA go after the A&P?
 
Don't know about your first scenario. In the second, if there is no paperwork, how would they know who to go after?
 
Unregistered said:
What happens?
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Hard to say.

Will the FAA go after me?
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They could, but they might not. Depends on circumstances.

On what grounds?
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As the pilot flying, for violating 91.7 by flying an unairworthy aircraft. As the person who did the work, for violating several sections of Part 43 regarding alterations, including persons authorized to perform the work, approval for return to service, and recording of alterations.

Let's say I get an A&P to do the installation, but no STC or paperwork.
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In order for an A&P to do that, s/he would be violating all those Part 43 provisions (since an IA is required to make this major alteration, not just an A&P), and it's not likely that any A&P you'd want to work on your plane would do that. And you would still be violating 91.7 by flying it that way.

Again, there's an incident and the illegal shoulder belts undoubtedly eliminate injury.
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Assumes facts not in evidence, including the idea that shoulder harnesses installed illegally and without approval by an unauthorized and unqualified person (you) not make things worse rather than better.

What happens? Will the FAA go after the A&P?
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They certainly will if the can prove that A&P did the work (hard to do if the A&P doesn't make any logbook entries and denies your accusation that s/he actually did the illegal wok). But they'll start with you.

And that's just the FAA. The insurance company will deny any coverage, too, and that could get really expensive for you. Any decent plaintiff's attorney would make mincemeat of your argument that shoulder harnesses installed illegally and without approval by an unauthorized and unqualified person (you) would make things better rather than worse.
 
After you crash, the FAA will request your logbooks for the plane, and for you as the pilot. If there's no entry in the logs for the shoulder harness install, they they will look at the plane and go; 'hmmmmm, that is interesting.' Then, most likely they will ask you about the shoulder harness with no logbook entry. At which point you get to A; Lie and tell them you know nothing about it, and they should ask the A&P. or B; Lie and tell them you installed them with the assistance of Joe in flibtown, but they aren't STCed.

Either way, they will find that the installation isn't kosher, and here's a best guess on what will transpire - you will get a letter of reprimand for operating the plane without the proper entries in the logs, and unapproved parts installed. Also best guess, as long as the harness didn't contribute to the crash, it'll be a 90 day or 180 day 'sin no more' and the whole thing will be forgotten after the letter is written. If it contributed to the crash, the penalty phase will be far worse. Maybe a suspension, and a 709 ride, or a suspension and a fine(unless you showed reckless disregard, in which case things get even worse).

Wag Aero sells all kinds of kits for all kinds of planes. Also, even if your old bird isn't approved for harnesses, I would have an A&P/IA buy a similar kit, install it in your plane, and have the FSDO look at the install and bless it as a one-time modification on a 337 form.
 
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AC 43.13-2B chapter 9 addresses shoulder harnesses and provides approved data for adding them. An IA may return a properly modified airplane to service without FAA involvement. It's unlikely that shoulder harnesses would cause or contribute to an accident. Liability for injuries would be a better thing to worry about, and that isn't the FAA's problem.
 
Stewartb said:
AC 43.13-2B chapter 9 addresses shoulder harnesses and provides approved data for adding them. An IA may return a properly modified airplane to service without FAA involvement.
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But it would still require both an IA (not just an A&P) and appropriate maintenance record entries including a 337 citing that existing approved data (as I think this would constitute a major alteration -- and you must, too, or you wouldn't say it requires an IA). Absent that paperwork, the mechanic who did it is in violation of a couple of sections of Part 43 and the pilot is in violation of 91.7.
 
I would rather face the wrath of the FAA for illegal shoulder harnesses after a crash than have my body placed in a coffin because my face got smashed hitting the instrument panel.
 
Unregistered said:
I would rather face the wrath of the FAA for illegal shoulder harnesses after a crash than have my body placed in a coffin because my face got smashed hitting the instrument panel.
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Since the OP notes that there are approved kits for this, that's not a choice the OP must make -- s/he can have legal shoulder harnesses. S/he's just asking about doing it illegally for some unstated reason (which I'm guessing is to avoid paying a qualified mechanic to properly accomplish and document the work).

And note that this could also be an issue in trying to sell the plane later. Discovery of undocumented alterations is in most cases a big red flag. Even if you can post-document the work if it was done properly with approved parts, you are still left wondering what other undocumented alterations you didn't find, and may come back to haunt you later, especially as they may have been improperly accomplished or used unauthorized parts and are not just lacking in documentation. In today's buyer's market, that's an easy walk-away decision for most buyers.
 
Unregistered said:
I would rather face the wrath of the FAA for illegal shoulder harnesses after a crash than have my body placed in a coffin because my face got smashed hitting the instrument panel.
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I'm fully with you. I've seen two accidents that would have been survivable but for the harnesses not being installed. One crash of a Comanche where a tire blew on landing as it touched down, and the plane skidded off the side into a berm of a culvert. The plane wasn't damaged much at all but the pax in the right seat died due to blunt force to the head/face.

Just do it, or have it done. Don't forget it will have to be removed at each annual, or the IA should squawk it. Damn the consequence
 
docmirror said:
Just do it, or have it done. Don't forget it will have to be removed at each annual, or the IA should squawk it. Damn the consequence
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Why do that when it requires only a qualified mechanic and a bit of paperwork to do it legally and so have no consequences about which to worry?
 
Is your life worth a few bucks,put in a legal set from the start.
 
Ron Levy said:
Why do that when it requires only a qualified mechanic and a bit of paperwork to do it legally and so have no consequences about which to worry?
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Fine with me. I don't care either way as long as the harness is in. If the cost for the qualified mech and the paperwork is prohibitive, get something, anything. If the cost is not prohibitive, then have it signed off. Let's keep the focus where it belongs, and that aint the paperwork.
 
docmirror said:
Fine with me. I don't care either way as long as the harness is in. If the cost for the qualified mech and the paperwork is prohibitive, get something, anything. If the cost is not prohibitive, then have it signed off. Let's keep the focus where it belongs, and that aint the paperwork.
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If an owner can afford the parts for this installation but the cost for the mechanic and paperwork above and beyond the parts is "prohibitive", that owner needs to re-evaluate his/her priorities. Outside of anything else, without that mechanic, how do you know you did it right? :dunno:
 
Jeez. People who can't take 'yes' for an answer.

Priority 1: get a harness installed.

Priority 2 - N: Everything else.

And I"m done here.
 
I am the OP. I did not write Post #9, though I agree (as it appears most do). Also, this is a hypothetical question - inspired by what I see on the ramp.

To me, it's unacceptable to not have good shoulder harnesses. If I were an aircraft owner, I'd go the FAA legal route and gripe about the additional cost. (Don't get me started on crappy seats!)

Possibly another argument for the less-regulated Experimental world, but there are tradeoffs either way. Thanks, all, for the solid and useful info.
 
RickG said:
Take a look at ACE-00-23.561-01 Methods of Approval of Retrofit Shoulder Harnesses. In an effort to encourage the addition of shoulder harnesses in older aircraft for safety its a minor alteration logbook entry.
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Exactly. I'm surprised Ron missed that. While STC and 337 are the FAA preferred methods, in an effort to get more folks to add harnesses in older aircraft, the FAA allowed the modification as a minor alt.
 
RickG said:
Take a look at ACE-00-23.561-01 Methods of Approval of Retrofit Shoulder Harnesses. In an effort to encourage the addition of shoulder harnesses in older aircraft for safety its a minor alteration logbook entry.
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...in certain specific cases:

  • the front seats of those small airplanes manufactured before July 19, 1978, and​
  • in other seats of those small airplanes manufactured before December 13, 1986.​


 ...not otherwise. Beyond that (E-AB's aside) the two common threads across this policy are:

  1. The involvement of a licensed mechanic in the performance of the work/approval for return to service/documentation of the work in the aircraft maintenance records IAW Part 43, and
  2. The use of harnesses which meet TSO-C114, "those harnesses that meet the Society of Automotive Engineers Aerospace Standard 8043, harnesses produced under a Parts Manufacturer Approval (PMA) or harnesses that meet aircraft military specification requirements."
I just don't see those requirements as an onerous burden.
 
Fearless Tower said:
Exactly. I'm surprised Ron missed that. While STC and 337 are the FAA preferred methods, in an effort to get more folks to add harnesses in older aircraft, the FAA allowed the modification as a minor alt.
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But only in certain limited cases listed above, and then only with harnesses which meet certain standards listed in that policy, and then only with the work performed and documented IAW Part 43.
 
If the installation looked legal and the accident wasn't super special I don't think the belts would trip a fishing expedition. Don't ascribe omniscient powers of observation to regular people doing their regular job.
 
I feel your pain, after seeing the quote for BAS belts I've been tempted to build my own.
 
Like I said earlier, look at AC43.13-2B chapter 9. It provides means and methods to do attachments, which is the big problem with adding shoulder restraints to an old airframe and what's lacking in that other shoulder harness document. Whether minor or major alteration as determined by your mechanic there is a clear path for adding shoulder restraints that does not require FAA inspection or approval. As spelled out in the opening paragraph of the AC, the contents of the AC are approved data.

http://www.faa.gov/documentLibrary/media/Advisory_Circular/AC 43.13-2B.pdf

Here's a snapshot of the added shoulder restraints at the second row jump seats in my own 180. This isn't just Internet chat to me.
 

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Unregistered said:
I would rather face the wrath of the FAA for illegal shoulder harnesses after a crash than have my body placed in a coffin because my face got smashed hitting the instrument panel.
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That's called a "false dichotomy".

Your choice is not as simple as choosing one of the two undesireable paths as stated.

Installing properly blessed shoulder harnesses is clearly the way to go.
 
Since I took the time to read this thread, here's what I got...

The OP was originally under the impression that there was not an easy way to legally add shoulder belts to an older plane. That is, he/she was unaware that AC43.13-2B existed.

With that cleared up, unregistered1 would pay the mechanic to execute on AC43.13-2B in this situation.

next
 
Ron Levy said:
But only in certain limited cases listed above, and then only with harnesses which meet certain standards listed in that policy, and then only with the work performed and documented IAW Part 43.
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I would hardly describe the number of applicable airframes for this AC as "certain limited cases" - this AC is applicable to a very large number of airplanes, probably the majority of the active fleet of single engine prop planes.

This is something that is easy and affordable to accomplish for most planes. Any owner too cheap to pay out for this probably has a scary list of other things they've skimped on.
 
Ron Levy said:
[*]
the front seats of those small airplanes manufactured before July 19, 1978, and​
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That limitation is because front seat shoulder harnesses were required in new certified planes built after that date.

Our 1977 Cessna 182Q, built in late 1976, came with shoulder harnesses from the factory. We switched to BAS harnesses shortly after we bought the plane 10 years ago. Also, the cargo area "coat hangar" hooks make an acceptable location for mounting a rear seat shoulder harness, so no airframe mods were needed to add those.
 
Jeff Oslick said:
This is something that is easy and affordable to accomplish for most planes. Any owner too cheap to pay out for this probably has a scary list of other things they've skimped on.
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Or someone has convinced them that the only legal way to do this is by the purchase of an expensive stc kit. And requires major structural modifications to install.
 
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