Non TSO'd instruments in certified aircraft

[danb35]

Quote: tony

Therefore (and this my opinion only) I think installing a non TSO’d device in the aircraft is authorized as long as it does not replace any of the equipment that changes the cert basis and is installed with a 337.

[M204ever]

Tony is definitely right.

TSO is not a must. Equipment must be qualified. The qualification requirements are based on the operational environment, usually DO160 is considered but not required as a only means to show compliance. It is the responsibility of the installing agency, here in Europe the design organization, to demonstrate that the modification is qualified, safe when operated and is not affecting existing equipment. The process doing this under consideration of the applicable certification basis is mentioned certification and ends up with the mod. approval making it airworthy.

Engine instruments usually are non-TSO equipment. They have been qualified and certified by the airframe manufacturer.They may be supported or even replaced by non-TSOd JPIs etc. 

[peter]

Quote: tony

This is a great conversation over a beer.  Peter you are right, but lets not forget 25.1309 which says.  There shall be no single element in the design that,if it fails, an maifest itself as a catasptophic event.  Isn't the DO-178B software thats in your displays an element?  Perhaps we should just keep those airspeed, altitide and attitiude indicators just to mitigate the hazard?

[Cruiser]

Wow, sounds like vacuum pumps would never be approved if they were software.

[peter]

Tony is kind of right.  TSO is not mandatory; it is just one way to show that a part is approved.  There are also other ways to achieve approval of a part.  For example, the EFIS displays in most (perhaps all) Boeing aircraft are not TSO’d, rather they are approved under the TC process.

However, the original question was about installing a non-certified EFIS in a part 23 aircraft for supplemental use, where the EFIS would be in addition to the existing instruments.  In this specific case I think the FAA has been very clear.

Under FAR part 21, all changes to a certified aircraft must be approved.  Major changes require STC, while minor changes may be approved in a “manner acceptable to the administrator”. 

FAA Order 8900.1 tells FSDOs that a field approval (e.g. an FAA approved form 337) is not permitted for EFIS; an STC is required.

There is a flight standards memo that says that TSO and STC are required for EFIS. 

There is FAA advisory circular AC23.1311-1B which states that installation of instruments that show primary flight information (attitude, altitude, airspeed) for "situational awareness" is not acceptable. Such installation must show compliance to the rules.  The AC says that those systems must be certified under part 23, and the equipment should meet the minimum standards of applicable TSOs.

So, in answer the original question, installation of an unapproved EFIS for supplemental use is only acceptable if an STC is obtained for that installation.  A field approval is not permitted and a log book entry would not be acceptable.

On the more general question of whether a part needs TSO to be installed, the answer is no.  TSO is not mandatory; however, parts do need to be approved.  There are various ways by which parts can be approved.

TSO is one way for a part to be considered approved.  Other ways include PMA (an STC process), approval under Type Certificate, field approval, standard parts, and some other methods approved under part 43 (rules for repairs) and part 145 (repair stations). 

In addition to the part itself being approved, an approval is needed to install the part.  Installation approval may be obtained by STC, TC, amended STC or TC, major alteration or repair (form 337) and minor alteration or repair (A&P or IA sign off).  Sometime a part is approved by virtue of the installation approval. 

When it comes to certification basis (i.e. Car3 versus FAR 23), FAR 21.101 is a rule that can require a modification to also meet the latest certification rules instead of the original certification basis. This may be the case if the original rules are not sufficient, or did not consider the type of modification being considered.  For example, for EFIS systems CAR3 did not envision this type of technology and the FAA requires these system to meet more modern rules, such as rules for HIRF and lightning.

An amendment to part 21 will become effective next April that further clarifies requirements for replacement and modification parts.  This forthcoming rule change says that any replacement or modification article that a person knows, or should know, is reasonably likely to be installed on a type- certificated product, must be produced under TC, an FAA production approval (such as TSO or PMA), be a standard part (such as a MS bolt), or be a defined commercial part (i.e. identified by a TC or STC holder in an ICA), be an owner produced part (owner produced parts still need to have a design approval), or be manufactured by a certificate holder with an approved QA system. 

Guys, I don’t make these rules, and often wish they were different.  However, it is my business to know the rules and work within them.  When it comes to the products my company produces, we must adhere to the rules, guidance and policy published by the FAA or we will leave our customers in a tough spot. 

When it comes to your personal aircraft you will have to make your own decisions about what to do. 

[Piloto]

An FAA approved product is analogus to an FDA approved medication. Would you risk taking a non-FDA approved medication for your ED condition? Because Viagra is expensive a friend of mine opted for a non-FDA approved Taco Duro medication. His experience? Instead of having a passionate night he end up at the throne reading the whole Trade-A-Plane that night.

José 

[Geoff]

Well this has been a really educational discussion.  I will throw some more fuel on the fire and pitch this out there.  I wonder what the FAA would have to say about the "Wingman" (see attached link).  Basically it is a portable EFIS.  I wonder how long it will take AirGizmo's to come up with a "panel dock" for this thing.  No way I would use this as Primary but it could be a "save the bacon" tool for $1,500.

http://www.virtualhud.com/VirtualHud/Wingman.aspx

[carusoam]

Geoff,

Doesn't your portable garmin already give you a panel page?  Note the "turn coordinator" in the photograph below.  This could be mounted in your panel by air gizmos and also supply GPS derived back-up.  Garmin throws the word of caution that indicates that update rate is too slow to use for real time use.  I used an antique as an example, newer Garmins have much faster refresh rates.  One issue with portables is that they do not have a raim check system to verify accuracy for navigation.   Overall,  I think this is an extension of your argument that is widely in use today.

On the other hand, I would prefer the well engineered solution provided by Peter & co that is intended for use in IFR conditions.  Spatial disorientation in clouds is pretty serious business.  I would not be comfortable grasping for straws in an emergency hoping my airgizmos mounted device will be there to save my bacon.

I am with Jose on this...In the US, I buy my medicines from a reliable FDA compliant source.  In Europe the FDA equivalent is the EMEA.   When I travel commercially it is on carriers that follow FAA guidelines. 

See attached photo....

[M20C]

[jetdriven]

I wouldn't rely on a garmin panel page to save my butt, so I installed a second,12v dc attitude indicator.   Of course it disagrees with my vacuum attitude only while ifr by 2 degrees but I can live with that. 

[M20C]

[carusoam]

M20c,

You've pulled out a old one here...

Welcome to the board.  Have you introduced yourself?  

Search for the thread "introduce yourself". It's a good one.

You seem to have a Strong background on this topic.  I would be interested in getting to know more about you.

Best regards,

-a-

[1964-M20E]

This brings up what I have stated before and that is if it is safe for an experimental who flies in the same airspace as I do the why is not safe for me especially in part 91 aircraft.  I can partially understand this in a part 135 aircraft.

 

Bottom line is if it does not directly affect the flight characteristics or aerodynamics we should be able to install it in our panel, cabin or add it to the aircraft and I should be able to do it myself.  Last time I checked my name was on the registration of the aircraft and I am the one flying it.  However, as the FAA goes I might as well be talking to the wall.

[jetdriven]

Does that apply to installing a primary attitude indicator or a vacuum pump on an ifr licensed aircraft? 

[M20C]

[1964-M20E]

Yes it would if you feel you feel competent to do the install. On the question of non TSO’d instruments vs. TSO’d instruments my argument is that if it is safe for the experimental aircraft then why is not safe for me regardless of who installs it?  Furthermore you would need to test the items to make sure they are working before jumping into IFR conditions.

[DaV8or]

M20C-

Have any pictures of your panel?

[M20C]

I do, and the Mooney is next...

[scottfromiowa]

"I've seen, however, signs that the FAA is starting to get concerned as the panel docked GPS' have grown in size and capability, even more so as they get installed in such prominent positions that they are supplanting approved equipment.  I hear rumblings that the FAA may be rethinking their position on this subject. Time will tell."

 

GOOD GRIEF!

[kgbpost]

Quote: peter

[M20C]

The 337 for the panel mod/docking station was easier to get than the 337 for the air data computer...

[M20C]

"I've seen, however, signs that the FAA is starting to get concerned as the panel docked GPS' have grown in size and capability, even more so as they get installed in such prominent positions that they are supplanting approved equipment.  I hear rumblings that the FAA may be rethinking their position on this subject. Time will tell."

 

I can only imagine the backlash from that; not likely... That horse is so far out of the barn....it's gone...

Besides then we would have a rash of people covering their panels in velcro.  BTW; have you seen the new blue tooth ADAHARS for the iPad?

[jetdriven]

We installed the AirGizmos panel dock for the aera, after a call to Avionics Unlimited. They said they have done hundred of them, no 337 required.  So thats what we did.  Installed a piece of dead plastic.

[aerobat95]

Hmmm....interesting.....what about something like autopilots......they are significantly cheaper and a better selection for the homebuilt market.  I have seriously looked at RV-10s because of the many options that you can do without the direct approval from the FAA and cheaper to boot. 

[DaV8or]

Quote: aerobat95