Installing non-PMA'd, TSO'd or STC'd map lights

[NotarPilot]

I'm hoping someone has some experience with this or knows of an FAA letter of interpretation or reg that may cover this but I'm considering putting in a couple of these swivel head map lights that I found on Spruce's website but they carry no type of approval. In the Q&A tab, Spruce says they can be installed as auxiliary lighting as long as they are not installed as "primary" lighting. That doesn't make sense to me and I'm wondering where this may be permissible.  I prefer for everything on my plane to be 100% legal so there's never a question about airworthiness should I have an incident and insurance people need to be involved.  I have a primary map light so these would definitely be auxiliary lights.

Also, would the rocker switches used to turn these on and off need to be approved? Or are commercially available switches sufficient and legal to use?

[Andy95W]

Wow, talk about a can-of-worms question.  If you ask 10 different A&Ps and FAA inspectors you'll get 10 different answers.

It really comes down to the person doing the installation, and then the IA doing the annual inspection every year thereafter.  The FAA has never specifically said that non-TSO or non-PMA parts could not be installed on an airplane, but I agree with the Spruce catalog that these lights would have to be supplemental and not primary lighting.  To try to make them primary would take an approval process like an STC or Field Apprval and documented on a 337.

Since that isn't the case here, then the only question that remains is whether the installation creates a hazard and is installed in a manner that allows return to service in an airworthy condition, and this is where the different opinions come in.  If you are successful in finding an A&P who is willing to sign off the installation as airworthy, then every year you will need an IA to sign off the annual inspections that also agrees with that airworthiness determination.

In this case, if someone asked me to do their installation, I would first want to look at the lights to see if I truly felt that they were manufactured to a standard that I felt comfortable installing in an aircraft.  Next, I would install them in a location that did not inhibit any other design function of the airplane or that would create an additional hazard in the event of a crash.  Finally, the lights would have to be installed with aircraft grade hardware and components such as toggle switch, wiring, circuit breaker or fuse.

If I were inspecting the airplane for an annual inspection, I would be looking for the same things- and if I saw an automotive store toggle switch providing power I would not sign off the annual.  And I would be very suspicious about the installation in general if that were the case- as well as the rest of the airplane in general.  If someone is going to cut corners on a toggle switch, what else are they willing to cut corners on?

Bottom line?  There are very good quality battery powered lights that you can put in yourself using either Velcro or Command strips that wouldn't raise a single eyebrow.  Why not just do that?

I am just one A&P/IA with only one opinion.  Hopefully we can get 9 more to weigh in.

[1964-M20E]

I'm neither an A&P nor an IA but I say minor alteration.  JMHO

 

 

[Andy95W]

Just now, 1964-M20E said:

I'm neither an A&P nor an IA but I say minor alteration.  JMHO

Totally agree, minor alteration, simple logbook entry.  

But if the thing looks like a chintzy piece of crap or the owner wants to use a plastic toggle switch he bought at NAPA, good luck finding an A&P willing to sign that logbook entry.

[NotarPilot]

I'm generally in agreement with you both of you but I'm trying to figure out where Spruce came up with their interpretation that it could be installed without any kind of approval. My understanding is that just about anything you permanently attach to your plane needs some kind of approval especially if it's electrical in nature i.e. Lights, switches, etc. 

I'm not really wanting to go the way of battery powered Velcro attached. 

[Andy95W]

The approval is the A&P who is willing to sign off the logbook entry.

[Sean S]

To do the install IMHO you may also need to perform an electrical load analysis to show that the system does not get overloaded when using these lights.

[tony]

I'd say the benefit isn't worth the hassle.  Go buy a couple of flashlights.

[cliffy]

BSpeed is correct. An ELA would need to be done and the installation still has to meet "airworthy" standards. An A&P installing still has to sign it off even if it is called a "minor alteration". One can't just do what one wants to do and sign something off as a MA. As mentioned, the IA at annual time will also be looking. It's not your Father's 56 Chevy! You can't just do what you want to do. 

I guess I'm just too dense to understand what is so hard about understanding why things have to be safe AND LEGAL when installed on a certified airplane. 

Here's a question- Are there any "hard mounted and wired" Garmin 796s out there, signed off in the log book as a minor alteration? If not, I wonder why?

[Yetti]

They look goofy as hell so I try not to evar be seen with one in public, but they sure are handy as all get out.   Doing things in the attic rate high up on the list where they are incredibly useful

https://www.rei.com/learn/expert-advice/headlamp.html

[Skates97]

2 hours ago, Yetti said:

They look goofy as hell so I try not to evar be seen with one in public, but they sure are handy as all get out.   Doing things in the attic rate high up on the list where they are incredibly useful

https://www.rei.com/learn/expert-advice/headlamp.html

I wear a headlamp for night flights, then there's always a red glow wherever I'm looking in the plane. It doesn't reflect much at all off the glass, I don't even notice it. 

Edited February 23, 2017 by Skates97

[NotarPilot]

Thanks for all the replies but I have more flashlights than I know what to do with. I'm not interested in battery powered lights, headlamps, etc. I was looking for some guidance on the legality of installing these lights which carry no FAA approval but Aircraft Spruce seems to say you can.  Here is a copy of exactly what it says under the Q&A portion under this product.

Are these 754 series LED lights approved for use in a certified aircraft?  
These are currently used in certified aircraft as auxiliary lighting. If this is used as auxiliary lighting this would not require any PMA or STC. Although if you are using this as the primary lighting then it would require approval.

So back to my original question, does anyone have an idea where they might be getting this legal interpretation from?

[Yetti]

Once you attach it to the ships power (which would be easy to do with the eyeball light if you have one) it needs an STC Because you are changing the type certificate.

Every person who inspects the plane will question them because they are not standard.

You would probably be better off getting some of the old torpedo lights from a 60s Mooney and converting them to LED.  At least they are on the Mooney Parts list and there is some lineage to Mooney.

Or paint those black so they look like the ones that came from an old mooney.

 

 

[Andy95W]

2 hours ago, Yetti said:

Once you attach it to the ships power (which would be easy to do with the eyeball light if you have one) it needs an STC Because you are changing the type certificate.

I disagree with this statement.  It is not how I was taught, it is not written this way in either the FARs or Advisory Circulars, and I have never heard this opinion expressed by an FAA maintenance inspector.

[Andy95W]

8 hours ago, NotarPilot said:

Are these 754 series LED lights approved for use in a certified aircraft?  

These are currently used in certified aircraft as auxiliary lighting. If this is used as auxiliary lighting this would not require any PMA or STC. Although if you are using this as the primary lighting then it would require approval.

So back to my original question, does anyone have an idea where they might be getting this legal interpretation from?

Probably they are referring to the FAAs definitions of what constitutes a major vs. minor alteration.

Appendix A to Part 43 - Major Alterations, Major Repairs, and Preventive Maintenance

(a)Major alterations - 

(1)Airframe major alterations. Alterations of the following parts and alterations of the following types, when not listed in the aircraft specifications issued by the FAA, are airframe major alterations:

(xii) Changes to the basic design of the fuel, oil, cooling, heating, cabin pressurization, electrical, hydraulic, de-icing, or exhaust systems.

 

Most people would agree that replacing the factory installed lighting with something else would indeed be a change to the "basic design" of what the manufacturer had intended for interior lighting (even though that is not specifically called out in the definition, most would choose to infer that).  But that does not apply here, because this would only supplement, and not replace or modify, the factory installed components.  So we would have to go to the FAAs definition of what a minor alteration is:

Minor alteration means an alteration other than a major alteration. 

Minor alterations are "approved" by the installer (an appropriately rated A&P) and annotated by a logbook entry.

[cliffy]

There is a section somewhere (I don't have the info right now where) that allows "commercial products" to be installed in certified aircraft but normally as part of an on going STC (such as a cabin retrofit in a jet with TVs and stereos as "commercial products". This might be where the reference comes from. 

I ask again, what about hard mounting a 796? It's not part of required equipment but it can't be hard mounted. Same rules.

[NotarPilot]

1 hour ago, cliffy said:

There is a section somewhere (I don't have the info right now where) that allows "commercial products" to be installed in certified aircraft but normally as part of an on going STC (such as a cabin retrofit in a jet with TVs and stereos as "commercial products". This might be where the reference comes from. 

I ask again, what about hard mounting a 796? It's not part of required equipment but it can't be hard mounted. Same rules.

YES! That's the reference I'm thinking of. I heard there was a reference about using commercial parts as long as they meet a commercial standard or something like that. I think I heard this in a Mike Busch webinar a few years ago. 

Funny you mention the hard wired 796. We actually have that very set up in 3 aircraft at work. I asked our mechanic if they are installed with just logbook entries and he said they are but he doesn't think that's right either (BTW he was not the one who installed them but one of the installations came from the OEM like that when we ordered it).

[cliffy]

Just curious as to what was hard wired in your airplanes? Could they be disconnected from the pilot seat? Could they be dismounted from the pilot seat?

What kind of airplanes were they? I'm really quiet interested

[carusoam]

When it becomes OK to technically mount the lights....  

make sure they don't become a hazard to the occupants while bouncing around inside the cabin...

The photograph kinda hides the scale or size of the devices.  In turbulence, they may leave a mark on your scalp....

Best regards,

-a-

[RobertGary1]

23 minutes ago, cliffy said:

Just curious as to what was hard wired in your airplanes? Could they be disconnected from the pilot seat? Could they be dismounted from the pilot seat?

What kind of airplanes were they? I'm really quiet interested

I certainly enjoy the fact that but simply pulling the connector out of the lighter socket all my portables disconnect all at once. Wouldn't want something that wasn't easy to isolate from the electrical system from the pilot seat in my opinion. Something more than a hidden inline fuse for me. The newer cessnas now have a switch to power off the lighter and the checklist says to turn it off prior to landing 

-Robert

[carusoam]

What is the logic of turning off the power source to the lighter before landing?

In my old M20C the lighter was used to power my portable GPS. It provided guidance for descent, and GS.  Two nice to have pieces of information to improve safety during the landing process...

checking ground speed vs airspeed is a final hint that I am not landing with the wind...  Some airport windsocks become invisible with age...  their age, not mine...

Best regards,

-a-

Edited February 24, 2017 by carusoam

[NotarPilot]

4 hours ago, cliffy said:

Just curious as to what was hard wired in your airplanes? Could they be disconnected from the pilot seat? Could they be dismounted from the pilot seat?

What kind of airplanes were they? I'm really quiet interested

The Ram mount for the 796 is attached to the airframe and the mount is hard wired into ship's power. The 796 can be disconnected easily from the pilot seat if needed to since the mount is a small cradle with a quick release button. And lastly, to answer your question, they're helicopters not airplanes (Not that it matters).

3 hours ago, carusoam said:

What is the logic of turning off the power source to the lighter before landing?

In my old M20C the lighter was used to power my portable GPS. It provided guidance for descent, and GS.  Two nice to have pieces of information to improve safety during the landing process...

checking ground speed vs airspeed is a final hint that I am not landing with the wind...  Some airport windsocks become invisible with age...  there age, not mine...

Best regards,

-a-

I'm only going to guess on this but being that he says this was written in the manuals of newer 172s, during the proliferation of newer cockpit gadgets and other power hungry (somewhat) devices maybe it was to keep these devices from "robbing" power from the battery while the RPM was lower and therefore the alternator was least efficient. I.e. Allowing maximum battery power available to power other essential navaids, instruments, etc. But this is just a guess.

[RobertGary1]

7 hours ago, carusoam said:

What is the logic of turning off the power source to the lighter before landing?

In my old M20C the lighter was used to power my portable GPS. It provided guidance for descent, and GS.  Two nice to have pieces of information to improve safety during the landing process...

checking ground speed vs airspeed is a final hint that I am not landing with the wind...  Some airport windsocks become invisible with age...  their age, not mine...

Best regards,

-a-

The portable gps should do that fine without power but remember these are all G1000 systems . This is on a T206 I delivered from the factory last summer. They mentioned something about certification but I didn't follow up 

https://www.redskyventures.org/doc/cessna-poh/Cessna_206_C206H-TC_T206H_2007_NavIII-G1000+GFC700-POH-PIM-fromCessna.pdf

"CABIN PWR 12V Switch - OFF"

 

-Robert 

Edited February 24, 2017 by RobertGary1

[cliffy]

I have gone thru the mounting issues in helicopters on a 135 ship as a matter of fact. The Ram mount may or may not be an issue, depends on who the FAA guy is. With the unit itself being unhookable by the pilot that makes it compliant as it is not "hard mounted" with screws or bolts unable to be removed easily. I designed and got approval for a Minor Alteration mount for a 496 in a Robbie helicopter.

I did have to show loading capacity per 43.13 and prove non-interference with all operations in my log book sign off. The Feds came in and looked it over and didn't say a word as all the bases were covered. Adding the Ram mount (if it is screwed to the airframe) does require a Minor Alteration sign off in the log books with reference to 43.13. I know, I know, thousands of them are in use every day but that doesn't change the requirements if they are screwed into the airplane (the knob tighten ones don't apply). The wiring does need a sign off in the log books unless it goes to a lighter plug that is easily removable (the lighter plug has to be factory install or signed off as maintenance AND an ELA should be done if a lighter plug is added).  The 796, in your case, being easily removable, does not factor into the equation.  Now, if you made a mount and frame that screwed the 796 into the panel that would need a sign off- its now "hard mounted". 

[Marauder]

On 2/22/2017 at 8:23 PM, Yetti said:

They look goofy as hell so I try not to evar be seen with one in public, but they sure are handy as all get out.   Doing things in the attic rate high up on the list where they are incredibly useful

https://www.rei.com/learn/expert-advice/headlamp.html

I didn't know you were such a spelunker. Then again I should have realized you are a Yetti and have an affinity for mountains and the caves they hold.

I suspect, like most pilots, you have a flashlight fetish. I can't go to Costco without pickup up a new flashlight.