"Blueskies" wrote in message . ..
"Steve Foley" wrote in message
...
You don't have PMA.

I cannot buy a Gates belt and put it on my Piper, but I can but a belt from
Piper that they bought from Gates, and put it on my plane. Nobody could tell
the difference, because there is none. That doesn't make it legal.

Same holds true for the u-joint holding my yoke together. It's not legal to
put it in the plane unless Piper has blessed it first (with their invoice).

"psyshrike" wrote in message
om...

If a field mechanic and an FAA expert couldn't tell the difference
between engine A and engine B, is there any regulatory reason this
wouldn't work?



Anyone can reverse engineer the 'part' and apply for PMA for it. The feds will accept it if the process is good...

Do you have an example?

I looked at Advisory circular 21-1B all the Qaulity control standards
appear to be handled through the Production Certificate (PC), which I
guess is what you file to get your Parts Manufacturing Authority
(PMA)? Apparently having a PC, does not directly require a Type
Certificate (TC). Presumably this is intended so that subcontractors
can be regulated. By the look of it you CAN manufacture parts with the
FAA's blessing without a TC.

Refering up-thread to Steves comment, I can understand the engine belt
issue if the OEM for the belt doesn't directly have a PC. In effect
Pipers PC would have to include Quality Control (QC) for the part. But
I can't emagine that the TC dictating that you can only buy part X
from vendor Y. It is more like Vendor Y must comply with FAA safety
standards (have a PC) in order to sell direct. Which is probably not
cost effective for them to do since they probably make nonaviation
parts on the same assembly line.

I am guessing Type Certificates were originally supposed to dictate an
engineering and testing standard required prior to selling the part.
But it eventually evolved so that the PC and flight testing standards
make up the the technical portion, while the TC itself just ends up
being a revision log. O-360-A1A, O-360-A1B etc. Is this fairly
accurate?

It sounds like the catch-22 is this:

Manufacturer: "Here is the engine made in full accordance with my PC,
it has been run up and tested I would like my Airworthyness Tag"

FAA: "What TC number?",

Manufacturer: "Number Contintal O-235 1234",

FAA: "Thats not your TC",

Manufacturer: "Damn your quick",

FAA: "You have to have your own TC, because you have impirically test
for safety",

Manufacturer: "It has already been tested by Contintal Engine Company.
It tested safe. There 5000 in the fleet, and I'd be happy to refer you
to all the happy pilots who've logged a trillion hours on this
engine",

FAA: "Well thats how we do things"

Manufacturer: "No it's not, the regs say that I am free to manufacture
a part for aviation provided that that I have a PC."

FAA: "It's not the same engine"

Manufacturer: "Prove it"

FAA: "We don't have to, we're the FAA"

Manufacturer: "Oh yes you do, and this small army of blood thirsty
lawyers standing behind me says so",

FAA: "But you didn't design it, and go through years of testing so we
could bust your chops and pontificate our naval"

Manufacturer: "You catch on quick"

FAA: "Well you still have to have a TC, so here are the forms, let us
when we can schedule a time to come over and bust you balls."

Manufacturer: (pulls out the same form, already filled out with
references to the the original OEM TC) "No need, here you go, and
heres my Production Certificate as well".

FAA: "This simply won't do."

Manufacturer: "Why not"

FAA: "Well you see, you have to go through the 'process'".

Manufacturer: "Show me that in the regs"

I guess my questions boils down to: Is there any part of the TC that
stipulates that the sale of a part is dependent on the permission of
the TC holder? Does the issuance of an Airworthyness tag require
permission from the TC holder?

-Thanks
-Matt