molding plexiglas websites?

You just won't get it, will you. The "FAA" wrote that? Interesting!
Sorry, but although I agree and make as many parts as I can get away
with (I'm going to try the adobe prop next weekend) it's not correct.
I'll also say that I very seldom travel at or under the speed limit,
but I won't even justify that as being acceptable, even though it is.
What we're speaking about here is legalities, not Old Wives Tales and
pressures put on lone FAA employees to pen a document.

Just too bad that the people who really know why this reg was put into
effect are not wasting time on the news groups. You folks would
probably be pretty interested, as it's a logical explanation.

On Sun, 13 Feb 2005 19:56:07 -0600, wrote:

Jon,

please read and think about what your writing about.

Please read every word.

"
Question 6: Is there anything else a mechanic must do?

Answer 6: The mechanic must ensure that the owner produced part meets
form, fit, and function, and within reasonable limits, ensure that the
part does meet its approved type design (e.g. like looking at the
approved data used to make the part). Then the mechanic installs the
part on the aircraft, makes an operational check if applicable and signs
off the required section 43.9 maintenance entry.
"


This is an article from the FAA about owner produced parts.

================================================= ========================
02/21/01

AMT Magazine

FAA Feedback column

“I” verses “We"

Bill O’Brien, NRS

Along with the pilot shortage and mechanic shortage there is also a
parts shortage that plagues the general aviation industry. Because
supply and demand are out of balance the cost of new and used parts seem
to increase every day. Let’s examine the reasons why this is so.

First, we have an old fleet. The average general aviation single engine
airplane is approximately 32 years old. The average age of GA
multi-engine reciprocating aircraft is close to 27 years old. The
average age for the turbine powered multi-engine propeller driven
aircraft average out around 19 years of age. So do to long term wear and
tear the demand for replacement parts and large sub-assemblies is much
greater today than it was even 10 years ago.

The second reason is our General Aviation fleet has been well maintained
over the years. So well maintained in fact, the average GA aircraft with
a mid time engine and decent avionics has appreciated to two or three
times it’s original purchase price and is still climbing. Yet even in
that land of many zeros the older aircraft are still substantially lower
in price than the cost of brand new aircraft with similar performance
numbers and equipment. So the value of older aircraft in good shape are
proven investments that over time has beat the DOW JONES average. So we
have an economic imperative on the part of the owners to keep
maintaining older aircraft in flying condition which increases the
demand for replacement parts.

The third reason is the increasing production costs to make a part.
Today aircraft manufacturers are not making makes and models of aircraft
in the same quantity they made them back in the seventies. So the
production runs for parts are not as frequent and not as many parts are
produced. In addition it is not cost effective for a manufacturer to
make a lot of parts even if the unit price for each part is out of this
world because taxes on maintaining a large inventory of parts would eat
all of the profits. This low parts production keeps the supply of
replacement parts low.

The fourth reason is that some manufacturers would prefer that their
older makes and model aircraft that they made a million years ago would
quietly disappear from the aircraft registry. This retroactive birth
control on the part of the manufacturers may seem not to make any sense
until you look at aircraft market dynamics of creating demand and
reducing costs. First , each older aircraft that is no longer in service
creates a demand for a new, more expensive aircraft to take its place.
Second, despite some tort claim relief granted to GA manufacturers in
the early nineties, the fewer older aircraft there are in service, the
manufacturers of those aircraft enjoy reduced overall liability claims
and ever decreasing continuing airworthiness responsibilities.

So how are we going to maintain these older aircraft with an ever
dwindling parts supply when Part 21, section 21.303 Replacement and
modification of parts requires us to use the Parts Manufactured Approval
(PMA) parts on a type certificated product? Well, the same rule grants
four exemptions to the PMA requirement.

1. You can use parts produced under a type or production
certificate such as a Piper Cessna, or Mooney produced part;


2. A owner or operator produced part to maintain or alter their
own product;

3. Parts produced under a Technical Standard Order (TSO) such
as radios, life vest and rafts, and GPS; or,

4. A standard aviation part such as fasteners, washers, or
safety wire.

Before I segue into the subject of “owner produced parts” as called out
in section 21.303 which is the purpose of this article. I would like to
create a small uproar with this statement: “ FAA Airframe and Powerplant
rated mechanics can maintain, repair, and modify parts, but they cannot
make a brand new part and call it a repair.” Before you accuse me of
losing dendrites by the minute, check out section 65.81 General
privileges and limitations. The section talks to maintenance, preventive
maintenance, and alterations but not to manufacturing of parts. Nor is
it implied privilege in Part 65, because Part 21 section 21.303 says “NO
PERSON” may make a REPLACEMENT part for a TC product unless that person
has a PMA, etc.

While I write this I can remember 25 pounds ago and when I had hair, I
worked in the real world and I specialized in making engine baffles for
Lycoming engines. Before someone accuses me of bureaucratic
ventriloquism which is roughly translated as “talking out of both sides
of my mouth.” My weak defense is, I made the parts because I thought I
could.” It never dawned on me that I could not legally make a part. Some
of you may be astounded that I make this confession freely. Its no big
thing because I know the statue of limitations has run out years ago and
a jury of my peers would never look me in the eye and convict me.

So here is our problem that we must solve. Since mechanics cannot
legally make parts for aircraft and aircraft need replacement parts, how
are we going to keep the fleet flying?

If we cannot find PMA, TSO, standard, or production holder replacement
parts, we are left to make the part under the owner produced option
under section 21.303(b)(2). However, we must remember that the part is
for the owner/operator’s aircraft only and is not manufacturered for
sale to other TC aircraft.

To get through confusing regulatory policy with our pride intact, lets
try the question and answer routine. (Note: This policy is taken from
FAA ‘s AGC-200 policy memorandum to AFS-300 on the definition of “Owner
Produced Parts” dated August 5, 1993)

Question 1: Does the owner have to manufacturer the part himself in
order to meet the intent of the rule?

Answer 1: No, the owner does not have to make the part himself. However
to be considered a producer of the part he must have participated in
controlling the design, manufacturer, or quality of the part such as:

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.

Question 2: Can the owner contract out for the manufacturer of the part
and still have a part that is considered, “owner produced?”

Answer 2: Yes, as long as the owner participated in one of the five
functions listed in

answer 1.

Question 3: Can the owner contract out the manufacturer of the part to a
non-certificated person and still have a part that is considered “owner
produced.”

Answer 3: Yes, as long as the owner participated in one of the five
functions listed in

answer 1.

Question 4: If a mechanic manufactuered parts for an owner is he
considered in violation of section 21.303(b)(2)?

Answer 4: The answer would be no if it was found that the owner
participated in controlling the design, manufacture, or quality of the
part. The mechanic would be considered the producer and would not be in
violation of section 21.303(a). On the other hand if the owner did not
play a part in controlling the design, manufacture, or quality of the
part the mechanic runs a good chance of being in violation of section
21.303 (b)(2).

Question 5: What kind of advice you can give on how a mechanic can avoid
even the appearance of violating section 21.303(b)(2)?

Answer: First, a mechanic should never make a logbook or maintenance
entry saying that he made a part under his certificate number. This
foopah will send up a flare and get you undue attention from your local
FAA inspector which you could do without. However, the mechanic can say
on the work order that he helped manufacturer an owner produced part
under 21.303 (b)(2).

Second, the owner or operator should be encouraged to make a log book
entry that is similar to section 43.9 maintenance entry that states: The
part is identified as an owner produced part under section 21.303
(b)(2). The part was manufacturered in accordance with approved data.
The owner/operator’s participation in the manufacturer of the part is
identified such as quality control. The owner must declare that the part
is airworthy and sign and date the entry.

Question 6: Is there anything else a mechanic must do?

Answer 6: The mechanic must ensure that the owner produced part meets
form, fit, and function, and within reasonable limits, ensure that the
part does meet its approved type design (e.g. like looking at the
approved data used to make the part). Then the mechanic installs the
part on the aircraft, makes an operational check if applicable and signs
off the required section 43.9 maintenance entry.

Question 7: What is the owner responsible for, and what is the mechanic
responsible for, concerning owner produced parts?

Answer 7: The owner is responsible that the part meets type design and
is in a condition for safe operation. The mechanic is responsible for
the installation of the owner-produced part is correct, the installation
is airworthy, and a maintenance record for installing the part is made.



Question 8: How does the owner or operator get the approved data to make
a part if the manufacturer and other sources are no longer in business?

Answer 8: For aircraft that the manufacturer is no longer supporting the
continuing airworthiness of then the owner or operator can petition the
FAA Aircraft Certification Directorate under the Freedom of Information
Act for the data on how the part was made. Or the owner or operator can
reverse engineer the part and have the data approved under a FAA field
approval or if it is a real complicated part, have the data approved by
a FAA engineer or FAA Designated Engineering Representative.

Question 9: What happens to the owner produced part on the aircraft if
the original owner sells the aircraft?

Answer 9: Unless the part is no longer airworthy, the original owner
produced part stays on the aircraft.

I hope that I spread some light on the murky subject of owner produced
parts so the next time instead of saying to the owner of an broke
aircraft: “Sure, “I” can make that part”, you will now say “Sure, “WE”
can make that part.”





Jon A. wrote:
On Sun, 13 Feb 2005 09:58:51 -0600, wrote:
I would, but you obviously reject what you can't believe. Why not
read the regs again, and if you missed it, read it again and so on
until it sinks in.

Tell you what. YOU show ME the "reg" and all of it, where it says
that an owner can just slap something together and call it an owner
produced part for his airplane. Don't just list it, text it all ( and
that means all of it) so that I can show you the error of your ways.



Jon A. wrote:


On Sat, 12 Feb 2005 15:10:47 GMT, "Dan Thompson"
wrote:



An owner produced part is not airworthy unless it matches the blueprints the
manufacturer supplied to the FAA when the aircraft was certificated.

Or a 337 with and STC is used.

Or a field approval is obtained.


Holy Crap! Someone else that reads the entire passage, not just what
they want to see! Hope you have your armor on. The pseudo lawyers
are going to get you!



What your indicating is that owner produced parts need to have a 337 to
install. SHOW ME THE REGS!!

The fabricated part does not have to match the origial blueprints. If it
does, SHOW ME THE REGS!!

Lets have anytime someone makes a statement or somebody questions a
statement about what you can do and what you can't do, provide the
regulations to back up that statement.


SHOW ME THE REGS!!

Dave



"Jon A." wrote in message
news

On Fri, 11 Feb 2005 17:39:30 -0800, "RST Engineering"
wrote:



The myth that 21.302 (b)(2) has been rescinded, which it ain't.

Jim



"Javier Henderson" wrote in message
...


Jon A. writes:



Who said that? Are you speaking of the legendary owner manufactured
parts myth that has been repeated so many times that folks are proving
it to be true?

What myth is this?

-jav

No, the myth that an owner could just willy nilly make up a part on
his own.