RST Audio Panel Legality

[[email protected]]

Jim Weir,
See link. Why would the FAA get involved?
http://cgi.ebay.com/ebaymotors/ws/eBayISAPI.dll?ViewItem&category=90973&item=4519498097&rd=1
tw

[John T]

The description says the feds busted him for using a non-certified part
in a certified airplane.

John

[Juan Jimenez]

Umm... I would guesstimate he got busted for not having the paperwork that
would allow him to use the part. :)

"John T" > wrote in message
...
> The description says the feds busted him for using a non-certified part in
> a certified airplane.
>
> John
>

[Juan Jimenez]

"T o d d P a t t i s t" > wrote in message
...
> "Juan Jimenez" > wrote:
>
>>Umm... I would guesstimate he got busted for not having the paperwork that
>>would allow him to use the part. :)
>>
>>> The description says the feds busted him for using a non-certified part
>>> in
>>> a certified airplane.
>
> Presumably he originally intended it to be an "owner-produced" part.

Hmm. Kinda makes you wonder if that could be done with something as
relatively simple as an audio panel...

[RST Engineering]

From the very first sentence that the guy wrote:

"I had this Audio Panel assembled by a professional. He charged $100.00 but
said it ended up taking 40 hours.The work inside is first class."

Reading that sentence, can you POSSIBLY construe "owner built part" from the
process? He PAID somebody to do the work that the owner was supposed to do
himself. We are VERY CLEAR that the owner of the aircraft must do the
assembly or the part cannot be legally installed on a certificated airplane.

Now, 504 hasn't been produced for almost ten years. Without a serial, the
unit might possibly be 20 years old or so. So for ten to twenty annuals,
this guy has been just fine, and all of a sudden the FAA "busts" him? I
think there is more to the story than this.

Not only that, but he then hires some amateur sparky that knifes off the
connections INSIDE the audio panel when all he had to do is simply
disconnect three nylon connectors? Wait a minnit...this one smells fishy.
I remember fifteen years ago or thereabouts some idiot sending me back an
audio panel that he had made "better" by some convoluted connector scheme
that couldn't have been undone by Houdini. We sent that one back with a
note that we didn't consider this an airworthy modification and that we
wanted no part of the product. I don't know that this is that unit, but the
time frame and reason for unairworthiness may somehow be connected.

However, he is correct that at this time this is NOT a certified or
certifiable part under 21.303(b)(2) as an owner produced part and is only
good for an experimental aircraft. And if anybody wants to start "splicing"
30 or so small gauge wires to make this sucker work, more power to you.

Youse guyzes have to start learning how the game is played...and out of ten
thousand RST audio panels out in the field, for one guy to goof up and not
follow directions doesn't speak too poorly of us.

Jim


> wrote in message
ups.com...
> Jim Weir,
> See link. Why would the FAA get involved?
> http://cgi.ebay.com/ebaymotors/ws/eBayISAPI.dll?ViewItem&category=90973&item=4519498097&rd=1
> tw
>

[[email protected]]

> Now, 504 hasn't been produced for almost ten years. Without a
serial, the
> unit might possibly be 20 years old or so. So for ten to twenty
annuals,
> this guy has been just fine, and all of a sudden the FAA "busts" him?
I
> think there is more to the story than this.
>
Thanks for the response(s). So what happens when the aircraft gets
sold and there's a new owner. Is the installation grandfathered? What
would have prevented this guy from just saying, "I" built it and "I"
obviously did a good job as it's worked perfectly for x number of years.

[Juan Jimenez]

"RST Engineering" > wrote in message
...
> From the very first sentence that the guy wrote:
>
> "I had this Audio Panel assembled by a professional. He charged $100.00
> but said it ended up taking 40 hours.The work inside is first class."
>
> Reading that sentence, can you POSSIBLY construe "owner built part" from
> the process? He PAID somebody to do the work that the owner was supposed
> to do himself. We are VERY CLEAR that the owner of the aircraft must do
> the assembly or the part cannot be legally installed on a certificated
> airplane.

Owner-produced doesn't mean "owner assembled" or "owner manufactured." My
understanding is that the FAR that allows this doesn't specify the owner has
to do the construction and/or assembly.

[RST Engineering]

> Thanks for the response(s). So what happens when the aircraft gets
> sold and there's a new owner. Is the installation grandfathered?

The same answer as to what happens when an aircraft is sold with an STC'd
part on it. Does the new owner have to go to the STC holder and apply for a
new STC? No, once the part is installed as approved, who owns the airplane
from that point on is immaterial. The approval goes with the PART, not the
owner.

What
> would have prevented this guy from just saying, "I" built it and "I"
> obviously did a good job as it's worked perfectly for x number of years.

He made the cardinal mistake when dealing with the FAA...he told the truth.

As to those who say that parts can be made by taking your design down and
having it built by the local machine shop, you are correct. However, YOU
had a hand in making the design and convincing your mechanic/IA that the
part would be airworthy as-built. However, in this case, the feller took MY
design down and asked another person to build it. That makes the feller
just a conduit from me to the actual manufacturer. I'd have a hard time
looking the Feds in the eye and saying that "I" built it under this
scenario.

Jim

[Dale Alexander]

"RST Engineering" > wrote in message
...

>
> He made the cardinal mistake when dealing with the FAA...he told the
truth.
>
>
> Jim
>
>
Careful Jim, that'll come back and haunt you the next time you run for
Governor...

Dale Alexander

[RST Engineering]

If ever I have to watch what I say when it is what I believe from my heart,
then I don't need the goddamned job.

Besides the NEXT round against Aahnold is a hell of a lot more than a $3500
filing fee...although just for grins I might consider it...especially if
SiliconeBoobs Carey runs again {;-)

Jim





>> He made the cardinal mistake when dealing with the FAA...he told the
> truth.
>>
>>
>> Jim
>>
>>
> Careful Jim, that'll come back and haunt you the next time you run for
> Governor...
>
> Dale Alexander
>
>

[Matt Whiting]

Dale Alexander wrote:
> "RST Engineering" > wrote in message
> ...
>
>
>>He made the cardinal mistake when dealing with the FAA...he told the
>
> truth.
>
>>
>>Jim
>>
>>
>
> Careful Jim, that'll come back and haunt you the next time you run for
> Governor...

Isn't that Governator in CA? :-)


Matt

[Ron Natalie]

RST Engineering wrote:

>
> Reading that sentence, can you POSSIBLY construe "owner built part" from the
> process? He PAID somebody to do the work that the owner was supposed to do
> himself. We are VERY CLEAR that the owner of the aircraft must do the
> assembly or the part cannot be legally installed on a certificated airplane.

Not so fast Jim. I can't say based on the limitted info presented by the
original poster, but your statement isn't true on face value. The FAA
doesn't require the parts under the owner-produced rule to actually be
constructed by the hand of the owner. If I need a part made, I can go
write up a list of specifications, go to a machine shop, have it made up
to those specifications, inspect it to verify that the work has been done
properly, and then have it installed. This isn't a rule like the amateur
built where the part has to be done for the education of the builder.

However, this only covers the production of the part. Just because you
build the part yourself, doesn't mean that you are free to install it in
your plane any more than if you bought it from a FAA-approved manufacturer.
The authority to produce the part, and the authority to have it installed
are seperate.

[RST Engineering]

Not so fast, Ron. I agree with your statement that YOU can write up a list
of specifications, do any drawings necessary, and go to a machine shop to
actually fabricate the part.

This is a horse of a different cruller. He took MY parts and MY drawings,
and simply handed them off to another person to fabricate. In my opinion
(and my opinion only) this is one step removed from your scenario. In this
case, the owner was simply taking a design in with his left hand and
transferring it to the fabrication shop with his right hand. I'd argue that
the spirit, if not the law, of 21.303(b)(2) was violated.

Jim



"Ron Natalie" > wrote in message
m...
> RST Engineering wrote:
>
> Not so fast Jim. I can't say based on the limitted info presented by the
> original poster, but your statement isn't true on face value. The FAA
> doesn't require the parts under the owner-produced rule to actually be
> constructed by the hand of the owner. If I need a part made, I can go
> write up a list of specifications, go to a machine shop, have it made up
> to those specifications, inspect it to verify that the work has been done
> properly, and then have it installed.

[Dave]

Hi all
Produced means produced, not built.
I think that he satisfies the requirement with step #2.

Heres a list of five things that qualifies the owner to have produced
the part. Only one of these needs to apply.
(BTW, I didn't come up with these these came from an FAA website)

1. provide the manufacturer with the design or performance data from
which to make the part, or

2. provide the manufacturer with the materials to make the part, or

3. provide the manufacturer with fabrication processes or assembly
methods to make the part, or

4. provide the quality control procedures to make the part, or

5. personally supervised the manufacturer of the part.

Ripped from:
http://www.faa.gov/avr/afs/news/archive/julyaugust/IvsWe.htm



Hope this helps

Dave


RST Engineering wrote:
> Not so fast, Ron. I agree with your statement that YOU can write up a list
> of specifications, do any drawings necessary, and go to a machine shop to
> actually fabricate the part.
>
> This is a horse of a different cruller. He took MY parts and MY drawings,
> and simply handed them off to another person to fabricate. In my opinion
> (and my opinion only) this is one step removed from your scenario. In this
> case, the owner was simply taking a design in with his left hand and
> transferring it to the fabrication shop with his right hand. I'd argue that
> the spirit, if not the law, of 21.303(b)(2) was violated.
>
> Jim
>
>
>
> "Ron Natalie" > wrote in message
> m...
>
>>RST Engineering wrote:
>>
>>Not so fast Jim. I can't say based on the limitted info presented by the
>>original poster, but your statement isn't true on face value. The FAA
>>doesn't require the parts under the owner-produced rule to actually be
>>constructed by the hand of the owner. If I need a part made, I can go
>>write up a list of specifications, go to a machine shop, have it made up
>>to those specifications, inspect it to verify that the work has been done
>>properly, and then have it installed.
>
>
>