Unapproved Plastic Elevator Tips Question

Alright, here is a good one for you. Stene in Montana manufactures and
sells very nice fiberglas tips for elevators, stabilizers, wings, and
rudders, mostly for Pipers and Cessnas. You can find these parts advertised
in TAP and on the internet. I have inspected, painted, and installed
several of these fairings and was impressed with their workmanship. They
are very well-made. The plastic parts replaced by these Stene parts are
probably from Cessna. They are probably Royalite. Besides being
ill-fitting and ugly, they are brittle and crack and break of easily,
especially at the rivet holes. After a few years they get brittle and break
away.

An aeroplastics company in Texas sells these fairings too, and they are
PMA'd. I do not know how much more costly they are than Stene's but
understand the extra expense is substantial.

Now why should you be stuck with PMA'd parts when Stene's, which are NOT
PMA'd are just as servicable, just as durable? And if Stene's are not
legal, then how does Stene get off selling them?

Yesterday I looked at a 172 with all new Stene tips on the empennage
surfaces. They were quite beautiful. And, by the way, I saw this
aircraft's sister ship flying with most of the tips broken off and gone back
in the summer, so you can't very well say that the absence of one or more of
these fairings, or one having cracked and broken, is a hazard, can you?

What am I missing here, Gene?

" jls" wrote in message
...

Alright, here is a good one for you. Stene in Montana manufactures and
sells very nice fiberglas tips for elevators, stabilizers, wings, and
rudders, mostly for Pipers and Cessnas. You can find these parts
advertised
in TAP and on the internet. I have inspected, painted, and installed
several of these fairings and was impressed with their workmanship. They
are very well-made. The plastic parts replaced by these Stene parts are
probably from Cessna. They are probably Royalite. Besides being
ill-fitting and ugly, they are brittle and crack and break of easily,
especially at the rivet holes. After a few years they get brittle and
break
away.

An aeroplastics company in Texas sells these fairings too, and they are
PMA'd. I do not know how much more costly they are than Stene's but
understand the extra expense is substantial.

Now why should you be stuck with PMA'd parts when Stene's, which are NOT
PMA'd are just as servicable, just as durable?


Because non-PMA parts will cause the aircraft to fall out of the sky without
warning.



And if Stene's are not legal, then how does Stene get off selling them?


Probably because no law is broken until the parts are placed in service.

In article . net,
"Steven P. McNicoll" wrote:


Because non-PMA parts will cause the aircraft to fall out of the sky without
warning.

unless, of course, the paperwork has been properly completed.

--
Bob Noel
looking for a sig the lawyers will like

Isn't part of your A&P authority the ability to determine that the
parts you have are identifcal to the original, and therefor approve
them? We don't get PMA's on screws and bolts.

On 28 Dec 2004 16:47:05 -0800, "Robert M. Gary"
wrotD:

Isn't part of your A&P authority the ability to determine that the
parts you have are identifcal to the original, and therefor approve
them? We don't get PMA's on screws and bolts.

An A&P can only install approved parts - that includes screws of a
type approved by the manufacturer. The manufacturer builds the parts
under their manufacturing authority and not via the PMA process.

An A&P does not have the skill set or engineering degree to make that
evaluation. Maybe they are being installed via an STC which is an
engineered and approved package. As long as the A&P follows the STC
he can install them, documenting the work with a 337.

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"Don Hammer" wrote in message
...
On 28 Dec 2004 16:47:05 -0800, "Robert M. Gary"
wrotD:

Isn't part of your A&P authority the ability to determine that the
parts you have are identifcal to the original, and therefor approve
them? We don't get PMA's on screws and bolts.

An A&P can only install approved parts - that includes screws of a
type approved by the manufacturer. The manufacturer builds the parts
under their manufacturing authority and not via the PMA process.

I have read that they can install owner manufactured parts?

An A&P can only install approved parts - that includes screws of a
type approved by the manufacturer. The manufacturer builds the parts
under their manufacturing authority and not via the PMA process.

I have read that they can install
owner manufactured parts?

They can but the owner needs to show that the part is identical to the
original. Not better, not different identical. A writer for Lightplane
Maintenance documented how he made is own fiberglass rudder tip for his Cessna
right up to installing it and then removing it on advice from the FAA that it
did not meet their definition of an owner produced part. Of course your FAA
may vary depending on location.

You can of course by and install Stene's parts and in all likelihood most
future A&P IAs will not notice or ignore them. But you or a future owner might
well run into someone who is more than normally observant and determined to
document the condition of the aircraft and the owner might find himself having
to decide all over again if Stene's were really worth it.

John Dupre'

I have read that they can install
owner manufactured parts?

They can but the owner needs to show that the part is identical to the
original. Not better, not different identical. A writer for Lightplane
Maintenance documented how he made is own fiberglass rudder tip for his Cessna
right up to installing it and then removing it on advice from the FAA that it
did not meet their definition of an owner produced part. Of course your FAA
may vary depending on location.


What regulation allows someone to manufacture and install something on
their own, or anyone else's aircraft?



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JDupre5762 wrote:
They can but the owner needs to show that the part is identical to
the
original. Not better, not different identical.

I've heard that particular opinion before, and it was shared by my
local FSDO. Of course this is the same FSDO that bounced a 337 on the
basis that the manufacturer's installation manual, which was FAA
approved (and labeled as such) and bore a revision number and date
nonetheless did not constitute approved data. As it happens their
opinion on owner-produced parts is no better - it is absolutely
inconsistent with the wording of Part 21, which refers to parts
manufactured to maintain or ALTER (emphasis mine) the owner's product.

Certain repairs/alterations are major, and in those cases the FAA has
decided that since an A&P is not an engineer (usually - and in any case
need not be) he is not to use his judgment in that area, making major
repairs and alterations based only on FAA-approved data (if he can
figure out what that is - clearly just because it says FAA-approved
does not mean the local FSDO will accept it as such). On the other
hand, certain repairs/alterations are minor (by definition - those that
are not major, meaning those not listed in 14CFR43) and in those cases
the A&P is permitted to use his own best judgment as long as the work
is perormed in a manner acceptable to the administrator.

One of our long-time contributors (Jim Weir) has made a business of
selling kits allowing owners to self-produce parts to alter (in minor
ways) their aircraft.

So the bottom line is that something as inconsequential as a plastic
wintip could very reasonably be installed as an owner-produced part.

A writer for Lightplane
Maintenance documented how he made is own fiberglass rudder tip for
his Cessna
right up to installing it and then removing it on advice from the FAA
that it
did not meet their definition of an owner produced part. Of course
your FAA
may vary depending on location.

Unfortunately that last sentence says it all. It should not be that
way, but it is. In fact, that's really what makes it impossible to
maintain the old airplanes safely and economically and stay legal. The
FAA is changing.

Years ago, when I had just started working towards my A&P, I
participated in the rebuild of a Champ. It had started life without
electrics. That was fine in 1946 when it was built, and it would in
fact have been legal to keep it operating that way even five decades
later, under the shelf of a major Class B. However, that wasn't what
the owner wanted. He wanted an electrical system, with radio and
transponder - the basic minimum in the closing years of the century. I
put in a radio stack on that airplane, and we got a field approval for
it all. The guy who field approved it had been with the FAA for
decades.

Just a couple of years later, it was time to do it again - the same
mods to the same make and model Champ. However, things had changed.
The FAA inspector who had issued our field approval had retired. The
one who took his place was unwilling to issue a field approval at all -
not even on the basis of the previous field approval. He told us we
were going to have to get an STC.

In the end, the owner found a guy in a different FSDO - another old guy
who was willing to sign off. One day he will retire too.

In the past, the field approval process was the sensible and correct
way to get modern technology into these old airplanes and keep them
flying. When that process existed and worked, there was really no
excuse for installing unapproved parts. The people who administered
the process were old hands, knowledgeable, and would work with you.
That's gone now. Today, the only reasonable options are illegal,
immoral, or fattening. You FSDO-shop hoping to find a way. You do the
installation by dark of night and pretend it's not there. Or you let
the planes fly in their original condition and wonder why
maintenance-related accidents are going up.

Michael

If this guy says he is an A&P, he's just trolling Don't feed the
trolls. A&P's know not to ask these types of questions. He's from
the manufacturer and is generating interest. Let him go through all
the **** like everyone else and get the PMA.

On 28 Dec 2004 16:47:05 -0800, "Robert M. Gary"
wrote:

Isn't part of your A&P authority the ability to determine that the
parts you have are identifcal to the original, and therefor approve
them? We don't get PMA's on screws and bolts.