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#1
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Anyone here have the PS Engineering PM3000 stereo 4-place intercom?
Is it really worth $200 more than the comparable Flightcom 403? How well does it sound with music input from an iPod? It's TSO'ed, so my A&P/IA is having much less heartburn about installing it... seems the Houston FSDO has been on a rampage against mechanics installing non-TSO'ed intercoms in spamcans and calling it a minor alteration. |
#2
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Seems like some FSDO is always on a rampage...of COURSE an intercom is a
minor alteration. Several FAA publications are quite explicit on what is major and what is minor, and a publication out of Ok City trumps the Houston FSDO. Your FSDO folks have their panties in a wad and are way off base. As a matter of fact, there is nothing in a part 91 aircraft that HAS to be TSOd, including transponders, altitude encoders, and ELTs. Read the requirements. They have to MEET the TSO spec, but they don't have to be themselves TSOd. Jim -- "If you think you can, or think you can't, you're right." --Henry Ford seems the Houston FSDO has been on a rampage against mechanics installing non-TSO'ed intercoms in spamcans and calling it a minor alteration. |
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You're preaching to the choir here... I'm not an A&P but am in whole-
hearted agreement that an intercom ought be a minor alteration, but the poor A&P's are under duress of the local FSDO interpretations of the regs and there's not much the mechanics can do to challenge that without invoking the ire of their local FSDO inspectors with whom they must maintain a working relationship. Seems like the aircraft maintenance world of today has become a very, very, very different world from what it used to be back in the mid 1990's when I first began flying and a lot more common sense prevailed. Practically everything you might wish to do to an airplane has now suddenly become a major alteration no matter what, and every minor part, practically right down to even the "decorative furnishings" in the cockpit must now be PMA'ed, TSO'ed, STC'ed, or factory original parts only, and getting any kind of field approval is a crap shoot. I sure wish I could afford to build an experimental and be relatively free from such unreasonableness. |
#4
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On Fri, 03 Aug 2007 15:26:56 -0700, One's Too Many
wrote: Practically everything you might wish to do to an airplane has now suddenly become a major alteration no matter what, and every minor part, practically right down to even the "decorative furnishings" in the cockpit must now be PMA'ed, TSO'ed, STC'ed, or factory original parts only, and getting any kind of field approval is a crap shoot. I've heard of clamp-on Ram mounts for Garmin 196's being cited as major mods. No, I'm not confusing it with the Air Gismo dock where a hole is cut, but a mount clamped to a support. |
#5
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On Aug 3, 4:50 pm, "RST Engineering" wrote:
Seems like some FSDO is always on a rampage...of COURSE an intercom is a minor alteration. Several FAA publications are quite explicit on what is major and what is minor, and a publication out of Ok City trumps the Houston FSDO. Your FSDO folks have their panties in a wad and are way off base. As a matter of fact, there is nothing in a part 91 aircraft that HAS to be TSOd, including transponders, altitude encoders, and ELTs. Read the requirements. They have to MEET the TSO spec, but they don't have to be themselves TSOd. Jim -- "If you think you can, or think you can't, you're right." --Henry Ford seems the Houston FSDO has been on a rampage against mechanics installing non-TSO'ed intercoms in spamcans and calling it a minor alteration. Their reply about the TSO, "how can you prove that the device/ appliance meets the specification? Show me the data.". They're making up their own rules where I am. I've asked OKC regulation questions, but they bounce it back to me and tell me to ask my local FSDO. How do you get a legitimate interpretation on a regulation if you can't get past your local office? Where's Bill O'Brien when you need him? I'd love to get into it in a public forum, but I'm in the process of fighting a battle with them which is obvious that they're clearly wrong, but won't admit it. And, the Internet has ears and I'm afraid of what they would put me through if they found out I was bashing them. |
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On Aug 3, 5:26 pm, One's Too Many wrote:
You're preaching to the choir here... I'm not an A&P but am in whole- hearted agreement that an intercom ought be a minor alteration, but the poor A&P's are under duress of the local FSDO interpretations of the regs and there's not much the mechanics can do to challenge that without invoking the ire of their local FSDO inspectors with whom they must maintain a working relationship. Seems like the aircraft maintenance world of today has become a very, very, very different world from what it used to be back in the mid 1990's when I first began flying and a lot more common sense prevailed. Practically everything you might wish to do to an airplane has now suddenly become a major alteration no matter what, and every minor part, practically right down to even the "decorative furnishings" in the cockpit must now be PMA'ed, TSO'ed, STC'ed, or factory original parts only, and getting any kind of field approval is a crap shoot. I sure wish I could afford to build an experimental and be relatively free from such unreasonableness. It's up to the A&P to decide if the modification is a major or minor modification. Why does the FSDO even need to know anything the installation of a component? If it doesn't comply with with the requirements of Part 43 appdx A, it's a minor thing. Just log it and be on your way. We tend to over regulate ourselves by hearsay and rumors. Just because one person or group of people happen to be 337 crazy, doesn't mean that we all need to be. I think that FSDOs accept too many 337's for minor modifications/ alterations. They create monsters out of these A&P's and IA's that are 337 happy. If they bounced back 337's that were minor alterations, it would help everyone out. Good luck |
#7
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wrote ...
It's up to the A&P to decide if the modification is a major or minor modification. Why does the FSDO even need to know anything the installation of a component? I've found the problems not with the A&P installing, but with a new (to the plane) IA a few years later who has a cow about signing it off. Those old 337's are like a "baby blanket" for most IAs. |
#8
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The mechanics around here are getting raked over the coals for not
obtaining official determination first beforehand on whether a job is a minor repair/alteration to grant them permission to log it as such. They're getting micromanaged to death. My own A&P/IA got threatened with certificate action and had to take some remedial training recently because of this. Apparently an IA's authority to make determination if a repair or alteration is major or minor has been eroded away to nothingness and whatever the regs and advisory circulars say has now been trumped by local inspectors' own interpretation instead. I really don't even want to get started into the "unapproved parts" issue since lately it seems like even obvious standard parts like mil-spec AN nuts and bolts are suddenly becoming in danger of being declared unapproved if you can't prove you bought them them from a Cessna/Beech/whatever parts dealer. But, in the case of the Flightcom intercom I originally wanted, since it is not PMA'd, TSO'd or STC'd therefore it is declared to be an "unapproved part" and hence illegal to install on a certificated airplane as an aftermarket upgrade. I guess the extra $200 the PSE intercom costs must be worth it since it should be considered the hassle-avoidance fee. |
#9
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On Aug 3, 6:27 pm, " wrote:
It's up to the A&P to decide if the modification is a major or minor modification. I thought that was the way it is supposed to work too, as reading the regs seems to overtly state this. But in actual practice the A&P is now being basically required to seek permission from above whether he can declare something to be minor or not... that he is expected to assume everything is major unless the FSDO grants him permission to declare it minor after they review the details themselves. If they bounced back 337's that were minor alterations, it would help everyone out. I thought they were supposed to do exactly just that too -- to "decline" the 337 with a note stating that the job is minor and to log it as such. But that's not what's been happening in real life. Good luck Thanks, I'll probably need it, but my IA did say that the 337 for the PSE intercom should slide right thru the bureaucracy like greased butter since a TSO'd part is already an approved part and its installation manual also constitutes "approved data" for the 337 |
#10
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One's Too Many wrote:
On Aug 3, 6:27 pm, " wrote: It's up to the A&P to decide if the modification is a major or minor modification. I thought that was the way it is supposed to work too, as reading the regs seems to overtly state this. But in actual practice the A&P is now being basically required to seek permission from above whether he can declare something to be minor or not... that he is expected to assume everything is major unless the FSDO grants him permission to declare it minor after they review the details themselves. It is the way it works. There is no requirement for an A&P to seek approval/permission for any modification if in his/her estimation it is minor in nature. As an A&P I'll sign off anything I believe is a minor alteration without anybodies approval. If it's a major alteration, then a FSDO approval is necessary and an IA needs to validate the alteration was done in accordance with the data approved. If they bounced back 337's that were minor alterations, it would help everyone out. I thought they were supposed to do exactly just that too -- to "decline" the 337 with a note stating that the job is minor and to log it as such. But that's not what's been happening in real life. Good luck Thanks, I'll probably need it, but my IA did say that the 337 for the PSE intercom should slide right thru the bureaucracy like greased butter since a TSO'd part is already an approved part and its installation manual also constitutes "approved data" for the 337 Just because something is TSO'd doesn't mean that it can be installed every aircraft. TSO's is nothing more than paperwork way to try to generate quality in a product. It's a label like the "UL" label on kitchen appliances. I could probably get a window AC unit TSO'd but it doesn't mean that you can install it in your airplane. It means that it passes what ever TSO standard that it was manufactured to. Take a look at part 43 appendix A, it's pretty interesting. Cheers! |
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