Unapproved Parts

[mooniac15u]

I saw this on BeechTalk and it lists Mooneys so I'm just posting it here as an FYI.  I know a lot of folks here are very happy with the quality of products from this supplier but apparently there are some unresolved issues with the FAA.

https://www.faa.gov/aircraft/safety/programs/sups/upn/media/2017/2017_98_071R.pdf

 

[Marauder]

I saw this on BeechTalk and it lists Mooneys so I'm just posting it here as an FYI.  I know a lot of folks here are very happy with the quality of products from this supplier but apparently there are some unresolved issues with the FAA.
https://www.faa.gov/aircraft/safety/programs/sups/upn/media/2017/2017_98_071R.pdf
 

Wow! And this guy has been on this site preaching the quality of their products. And this FAA notice is not new, it was issued in 2000.


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[DonMuncy]

It would be interesting to hear the whole story on this.

[RLCarter]

1 hour ago, Marauder said:

Wow! And this guy has been on this site preaching the quality of their products. And this FAA notice is not new, it was issued in 2000.

 

Quality doesn't get the FAA/PMA, there is 3 sides to every story

[kortopates]

No one is saying Guy's products are not quality; not even the FAA.  Many will tell you they are better quality than any of the alternative  approved parts available. The simple fact is GEE-BEE doesn't have PMA authority to produce these and hence they are unapproved parts. In Guy's defense, using Baffles as an example, I believe he would claim he is providing the raw materials that may or may not be approved but meet the same standards (or something like that) just as if we acquired the products from approved sources and cut them ourselves and then installed legitimately. But in his case, the FAA is saying he needs PMA approval to do so. Just like LASAR and others have gotten for all the "improved" parts they provide. in other words their parts are manufactured and distributed with the FAA's oversight and approval of their manufacturing processes, quality controls, record keeping etc etc. Guy has obviously chosen a different path for reasons we can only speculate (expense of getting PMA authority?) and given all this time has passed without getting approval I doubt he intends too - but only he can answer to that. Yet he is online now.  

Anyway I don't expect anything is going to change, except perhaps further expansion of his products offerings. Nor do I see the demand for his products going away; except perhaps by repair stations. But I do imagine owner installers will be more careful to only refer to the installed materials or as owner produced parts  and avoid mention of GEE-BEE in the maintenance records for obvious reasons.

I wish him the best. The products I have seen are very good quality (yet unapproved).

[Marauder]

Quality doesn't get the FAA/PMA, there is 3 sides to every story

If you are indeed making a superior product, why not get the PMA? Sure there is cost associated with it but that is the nature of how this industry is regulated.


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[N6758N]

11 minutes ago, kortopates said:

No one is saying Guy's products are not quality; not even the FAA.  Many will tell you they are better quality than any of the alternative  approved parts available. The simple fact is GEE-BEE doesn't have PMA authority to produce these and hence they are unapproved parts. In Guy's defense, using Baffles as an example, I believe he would claim he is providing the raw materials that may or may not be approved but meet the same standards (or something like that) just as if we acquired the products from approved sources and cut them ourselves and then installed legitimately. But in his case, the FAA is saying he needs PMA approval to do so. Just like LASAR and others have gotten for all the "improved" parts they provide. in other words their parts are manufactured and distributed with the FAA's oversight and approval of their manufacturing processes, quality controls, record keeping etc etc. Guy has obviously chosen a different path for reasons we can only speculate (expense of getting PMA authority?) and given all this time has passed without getting approval I doubt he intends too - but only he can answer to that. Yet he is online now.  

Anyway I don't expect anything is going to change, except perhaps further expansion of his products offerings. Nor do I see the demand for his products going away; except perhaps by repair stations. But I do imagine owner installers will be more careful to only refer to the installed materials or as owner produced parts  and avoid mention of GEE-BEE in the maintenance records for obvious reasons.

I wish him the best. The products I have seen are very good quality (yet unapproved).

You know what they say Paul, LEGAL and SAFE aren't spelled the same. Classic example here.

[Marauder]

4 minutes ago, N6758N said:

You know what they say Paul, LEGAL and SAFE aren't spelled the same. Classic example here.

You IAs. You're sooooo smart.  

 

[Danb]

So what are the ramifications if for instance one had an accident or incident do to engine failure, could the FAA thereby the insurance company nullify payment on the claim?

[N6758N]

Just now, Danb said:

So what are the ramifications if for instance one had an accident or incident do to engine failure, could the FAA thereby the insurance company nullify payment on the claim?

Doubtful unless they could directly prove the part somehow caused the accident. I'm sure the lawyer types would try their best to sue the crap out of anyone they could though. 

[smccray]

22 minutes ago, Marauder said:

 

If you are indeed making a superior product, why not get the PMA? Sure there is cost associated with it but that is the nature of how this industry is regulated.


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I seem to recall some discussion about this a while back on BeechTalk.  It's not exactly clear that the PMA is required, but it seems reasonable to me that the PMA would be required.  I suspect we're in some sort of legal gray area here.  I don't fully understand it but I would like to...hoping it becomes clear.

If that thread on beechtalk is any indication, the Gee Bee products are superior to what the FAA says is approved.

[N6758N]

26 minutes ago, Marauder said:

 

If you are indeed making a superior product, why not get the PMA? Sure there is cost associated with it but that is the nature of how this industry is regulated.


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Time and Money. Just ask @Sabremech

[Marauder]

Just now, Danb said:

So what are the ramifications if for instance one had an accident or incident do to engine failure, could the FAA thereby the insurance company nullify payment on the claim?

That would be my concern. I'm actually reading my policy to see if anything is mentioned about using non-approved parts.

[smccray]

It's an odd situation though right?  is it required to use PMA'd fiberglass / carbon fiber / epoxy when repairing the cowling?  Does the RTV used to seal penetrations in the firewall need to be PMA'd?  I have honestly never understood how all the FAA regs on what can and cannot be used.

My guess is that there's some apparent flexibility in the regulation where the FAA interpretation in that letter has decided that there isn't any flexibility.

[mooniac15u]

6 minutes ago, smccray said:

It's an odd situation though right?  is it required to use PMA'd fiberglass / carbon fiber / epoxy when repairing the cowling?  Does the RTV used to seal penetrations in the firewall need to be PMA'd?  I have honestly never understood how all the FAA regs on what can and cannot be used.

My guess is that there's some apparent flexibility in the regulation where the FAA interpretation in that letter has decided that there isn't any flexibility.

It seems like it might come down to materials vs parts.  The fiberglass and epoxy are materials used to repair a part.  The items in question have part numbers in the Mooney and Lycoming parts catalogs.  When replacing a part you need some kind of approval basis for the new part.  Usually that's a PMA.  I think the problem here is that it seems a little heavy-handed to call a piece of silicone  a "part" in the same way that a flap is a part.

[smccray]

1 minute ago, mooniac15u said:

It seems like it might come down to materials vs parts.  The fiberglass and epoxy are materials used to repair a part.  The items in question have part numbers in the Mooney and Lycoming parts catalogs.  When replacing a part you need some kind of approval basis for the new part.  Usually that's a PMA.  I think the problem here is that it seems a little heavy-handed to call a piece of silicone  a "part" in the same way that a flap is a part.

Same thing with light bulbs right?  the old bulbs didn't require a PMA, but the FAA has decided that an LED bulb does require a PMA driving up the cost of the LED bulb.  I have a PMA'd whelen, although I'm not sure why the LED bulbs sold for tractors wouldn't work just fine.

[mooniac15u]

Just now, smccray said:

Same thing with light bulbs right?  the old bulbs didn't require a PMA, but the FAA has decided that an LED bulb does require a PMA driving up the cost of the LED bulb.  I have a PMA'd whelen, although I'm not sure why the LED bulbs sold for tractors wouldn't work just fine.

With bulbs I think the parts catalog also specifies the approved part number even though it's just a standard part.  Kind of like fasteners.  If the LED bulb is a different part number then I guess it would need some kind of approval basis.

[MB65E]

Who recently pulled this out of the FAA's rear end?

Frustrating that Guy can make things better than the factory can, but ends up getting raked over the coals. 

Production for profit is different than owner produced parts. However,  I would argue most if not all his stuff was owner produced if I needed to get something signed off. 

He makes stuff for the US military, and  most manufactures. In fact I believe all of the Citation line of nose baggage seals are made my him. 

Many of these items are not major alterations. 

Move on,

-Matt

 

[smccray]

Just now, mooniac15u said:

With bulbs I think the parts catalog also specifies the approved part number even though it's just a standard part.  Kind of like fasteners.  If the LED bulb is a different part number then I guess it would need some kind of approval basis.

I don't have a clue but that makes sense.  I don't think the old light bulbs are PMA'd but I could be wrong.

[jetdriven]

None of those GE landing light bulbs are PMA. They are standard parts, just like hardware and rivets.

anyways, it's up to the installing mechanic to determine airworthiness, such as when baffle seal material is as good or better than what came off.  

Edited October 25, 2017 by jetdriven

[INA201]

You can buy a roll of silicone baffling and install it why not pre cut silicone that happens to fit better.

[takair]

The requirement for PMA is heavily based on intent to sell.  If the intent is to sell for installation on certified aircraft then the manufacturer will likely need a PMA or other FAA approved quality system.  The interpretation of this is different between regions and inspectors, but generally true.  This is why many of the catalogue houses specifically note that some products are for experimental aircraft only.  It could come down to something as simple as advertising that a product is intended for a certified aircraft.  I ran into this very issue earlier this year and had differing initial input from the FAA.  In the end, a PMA was required.  I am not familiar with these he situation discussed above, just my own experience with a product intended for a minor alteration.  

[Sabremech]

6 hours ago, N6758N said:

Time and Money. Just ask @Sabremech

I get the FAA's concern especially with the baffle seals. As far as the PMA goes, a lot of time and money. Lately more time which is very painful and hard to make money. 

[Guitarmaster]

I get the FAA's concern especially with the baffle seals. As far as the PMA goes, a lot of time and money. Lately more time which is very painful and hard to make money. 

Especially when you keep slicing yourself up on my airplane... .

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[Marauder]

12 hours ago, Guitarmaster said:

Especially when you keep slicing yourself up on my airplane... .

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Any new photos of the "SE" edition?