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#11
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Bob Noel wrote:
If the part is not PMA'd for your aircraft, you'll need a different "basis" for the approval of the installation in your aircraft. This does not need to be via an STC. Ah, so a PMA is aircraft-specific? That's a little suprising - although reasonable in retrospect - as a number of aftermarket instrument lighting vendors advertise that their product is "PMA certified", or some such. No mention is made of "...for the following aircraft...". As an example, a digital OAT probe I installed in my cherokee was PMA'd for certain beechcraft aircraft but not my cherokee. The installation this digital OAT probe was approved via a 337. I'm confused about the role of a 337. When is one required? One example is what you've cited: a change for which neither PMA nor STC exists. But is one required for a replacement with a PMAed "part"? Is one required for an STCed alteration? - Andrew |
#12
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"Andrew Gideon" wrote in message online.com... It sounds from the above like an STC is required before any major alteration because it "provides authority to make the major alteration". Is that right? An STC is one way of getting approval for the alteration. Other "data acceptable to the administrator" is allowed as well. This is called a field approval (or sometimes incorrectly, a one time STC). A lot seems to hinge on the distinction between "major" and "minor" alterations. What is the difference? Given a particular change (ie. replacing a panel overlay, or adding instrument lights), how does one know into which category the change falls? The definitions are here (I'm not going to post them inline as they are a bit long): http://www.access.gpo.gov/nara/cfr/c...4cfr43_00.html Some of it is a gray area. Somethings people read more into it than others. For example, just because something changes the w&b, it is not a major alteration. It is only a major alteration if it changes the permissable envelope. |
#13
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"Andrew Gideon" wrote in message online.com... Ah, so a PMA is aircraft-specific? No. PMA ce I'm confused about the role of a 337. When is one required? A 337 is required to report any major alterations whether the are supported by an STC or just "other acceptable data." Some people sometimes use "approved by 337" to mean field approval. One example is what you've cited: a change for which neither PMA nor STC exists. But is one required for a replacement with a PMAed "part"? Is one required for an STCed alteration? There are two principles he 1. Approval of the modification, that is authority to make this change to the aircraft. 2. Approval of the part itself (It's manufacture, quality control, etc..). The first is accomplished by either being supported by the Type Certificate, or an STC, or other approved data, or being so minor as being inconsequential. The second, can be accomplished by a PMA, a TSOA, the type certificate itself (for the original manufacturer), by recognition of certain non-FAA standards (like MilSpec's for things like fasteners), or by the owner himself producing the part in accordance with FAA-approved data. |
#14
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I did a Google search for "owner produced parts" then started clicking.
Very interesting reading!! 1. http://www2.faa.gov/avr/afs/news/arc...2002/Parts.htm 2. http://www.dvcfi.com/aviation/stc.php 3. http://makeashorterlink.com/?L2A512696 4. http://makeashorterlink.com/?H1C521696 Talked to a guy at my airport who is doing much of this with his 177 project. He said he's surprised more owners don't make parts for their planes, or have the parts made for them. Measure it, build it - is his motto. -- Montblack ("Dan Thomas" wrote) Aircraft manufacturers publish parts manuals for the airplanes they build. The law says that you must use the parts specified in the manual when replacing things. If the part has an industry-standard number, like an AN bolt or fitting or wheel bearing, you can buy it from any aircraft parts supplier. If the number is a proprietary number (invented by and belonging to the airplane manufacturer), such as a throttle control cable, the requirement to use only that part means that you have to buy it from the airplane dealer. The manufacturers are inclined to take advantage of this and we see some ridiculous prices. snip |
#15
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Andrew Gideon wrote: Ah, so a PMA is aircraft-specific? Not exactly. If the item is (for example) a Cessna wing flap, then the answer is yes. If it's a replacement for something more generic, it can be used to replace that item on any aircraft that uses it. A good example would be one of these lightweight starter motors. Since the part is legally a direct replacement part, no STC is required. The 337 is required for any change that the local FSDO believes is a "major" modification. An STC is legally a change to the original type certificate that allows you do do something the original manufacturer didn't do. George Patterson A man who carries a cat by the tail learns something that can be learned no other way. |
#16
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On Wed, 19 Nov 2003 14:01:52 -0600, "Montblack"
wrote: I did a Google search for "owner produced parts" then started clicking. Very interesting reading!! 1. http://www2.faa.gov/avr/afs/news/arc...2002/Parts.htm 2. http://www.dvcfi.com/aviation/stc.php 3. http://makeashorterlink.com/?L2A512696 4. http://makeashorterlink.com/?H1C521696 Talked to a guy at my airport who is doing much of this with his 177 project. He said he's surprised more owners don't make parts for their planes, or have the parts made for them. Measure it, build it - is his motto. I'd be interested in knowing if this guy is generating approved data for these parts. If he isn't, he is doing no more than producing numerous unapproved parts with which to get himself and his mechanic and/or inspector violated. ... not a clever money-saving scheme. |
#17
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And your background and authority for making this statement are? Jim Gene Kearns shared these priceless pearls of wisdom: -Talked to a guy at my airport who is doing much of this with his 177 -project. He said he's surprised more owners don't make parts for their -planes, or have the parts made for them. Measure it, build it - is his -motto. - -I'd be interested in knowing if this guy is generating approved data -for these parts. If he isn't, he is doing no more than producing -numerous unapproved parts with which to get himself and his mechanic -and/or inspector violated. ... not a clever money-saving scheme. Jim Weir (A&P/IA, CFI, & other good alphabet soup) VP Eng RST Pres. Cyberchapter EAA Tech. Counselor http://www.rst-engr.com |
#18
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In article ne.com,
Andrew Gideon wrote: If the part is not PMA'd for your aircraft, you'll need a different "basis" for the approval of the installation in your aircraft. This does not need to be via an STC. Ah, so a PMA is aircraft-specific? That's a little suprising - although reasonable in retrospect - as a number of aftermarket instrument lighting vendors advertise that their product is "PMA certified", or some such. No mention is made of "...for the following aircraft...". I'm sorry. I was sloppy with my language. I shouldn't have said "not PMA'd for your aircraft", but something more like "not a PMA replacement for a part for your aircraft." As an example, a digital OAT probe I installed in my cherokee was PMA'd for certain beechcraft aircraft but not my cherokee. The installation this digital OAT probe was approved via a 337. I'm confused about the role of a 337. When is one required? One example is what you've cited: a change for which neither PMA nor STC exists. But is one required for a replacement with a PMAed "part"? It is my understanding that replacing an existing part with a PMA replacement part wouldn't require a 337. Is one required for an STCed alteration? Yes. are we confused yet? -- Bob Noel |
#19
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On Wed, 19 Nov 2003 16:21:09 -0800, Jim Weir wrote:
And your background and authority for making this statement are? Are you the credentials police? If you take issue with the substance of what I have said, offer information contrary to my assertion. FAR 21.303 does not give blanket authority to an owner to produce any sort of part using any sort of materials and any sort of means available. (Nor does it give a mechanic permission to install an unapproved part.) If you do disagree with my assertion, I suggest you read FAR 43.13 and FAA Order 8300.10 Chapter 83 for content and then offer some means available to the owner/operator for legal approval of owner/operator produced parts other than: (1) reverse engineering and field approval or (2) securing original manufacturing data from the TCD or PMA holder or (3) securing original manufacturers data via freedom of information act from the FAA Aircraft Certification Directorate In any event, the part must be certified as airworthy in the maintenance records by the owner/operator and that assertion should not be made unless the part conforms to the original type design. A mechanic that installs owner/operator parts not so (accurately) certified in just asking for trouble. Gene Kearns shared these priceless pearls of wisdom: -Talked to a guy at my airport who is doing much of this with his 177 -project. He said he's surprised more owners don't make parts for their -planes, or have the parts made for them. Measure it, build it - is his -motto. - -I'd be interested in knowing if this guy is generating approved data -for these parts. If he isn't, he is doing no more than producing -numerous unapproved parts with which to get himself and his mechanic -and/or inspector violated. ... not a clever money-saving scheme. Jim Weir (A&P/IA, CFI, & other good alphabet soup) VP Eng RST Pres. Cyberchapter EAA Tech. Counselor http://www.rst-engr.com |
#20
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Bob Noel wrote in
: Is one {PMA} required for an STCed alteration? Yes. Not quite. A part may be manufactured by the owner/operator and installed under STC, or it may be manufactured *and installed* by the holder of the STC without PMA. Both these minor points are seldom worthy of note, but they are there. For example: GAMI designed their new fuel injectors. They went through testing and the STC was awarded. They were then allowed to make them and install them on all aircraft/engines for which the STC applied. The FAA would not allow the PMA application to be even be submitted until the STC was approved. [It's not clear that this is a rule, so much as an FSDO made up rule.] Until the PMA was approved GAMI could not sell the injectors to anyone else for installation elsewhere. You wanted the injectors, you flew to Oklahoma and had GAMI put them in. Once the PMA was approved the restriction went away. ----------------------------------------------- James M. Knox TriSoft ph 512-385-0316 1109-A Shady Lane fax 512-366-4331 Austin, Tx 78721 ----------------------------------------------- |
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