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Is using automotive paint on airplanes legal?


Rmag

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@mooneyman started a thread about his airplane being painted here:  https://mooneyspace.com/topic/25226-mooney-n94mr-paint-project/  On page 3 of his thread people started asking various questions about automotive paint versus aircraft paint, to which I responded to in his original thread.

 

@xcrmckenna asked the follow up question, “Would automotive paint on an airplane be legal? Or is it just not going to hold up as well as aviation paint?

 

As to not further hijack mooneyman’s thread that should be for admiring his new paint job.  I felt that it would be best to take this conversation into a separate thread.

 

The original post I made was this:

 

Lots of questions about aviation paint.  As a paint shop owner (SureFlight at KMQS), I thought I would chime in and answer some of the questions.

 

On ‎2‎/‎21‎/‎2018 at 2:39 PM, xcrmckenna said:

I have a few friends that are high end automotive painters. One guy has painted a few Lakers cars and I’ve bent their ears a few times about airplane paint. They say the types of paint most shops are using are archaic compared to the newer automotive paints. They last longer and the clean up is much safer. They don’t fade as bad and resist defects. I guess it means a less experienced painter can make it look good, but I think that makes an expert painter look perfect.

 

The aviation market is miniscule compared to the automotive market.  There will always be more innovation in the automotive market to due its size and volume.  Automotive paint is easier to use.  It lays out flatter with less defects.  Its easier to make a nice-looking finish.  xcrmckenna is correct, a less experienced painter can make automotive paint look good.  Aircraft paint is more finicky and more opt to have defects such as sags, runs, dry spots, reactions, orange peel, etc.  It is more difficult to apply.  With rare exception, you can’t just take an automotive painter and have him paint an aircraft with aviation paint and have it turn out well. 

 

On ‎2‎/‎21‎/‎2018 at 3:59 PM, mooneyman said:

It's interesting that you mention automotive paint because that's what Ken uses at Flying Colors. I knew that I wanted metallic silver as base with some red graphics. Instead of looking at Sherwin-Williams Jet Glo sample charts, he told me to visit various automotive websites and find some colors that I liked. The shade of red that we picked is from Porsche and the silver is from Mercedes. I agree that it looks awesome! Can't wait to see it in person!

 

You really want to check to see if they put automotive paint on your aircraft.  If you go to their website and read their processes, step 12 regarding paint they use Jet Glo or Acry Glo which is Sherwin Williams Aviation Paint.  They might have had you look at automotive colors to get a better sampling than Sherwin Williams samples.  You can match aviation paint colors to automotive colors.  We have a mixing room with all of the tints, metallics, pearlescent, etc.  We have a special camera that takes a picture of the paint finish and produces a formula to mix any color we want in aviation paint.  You don’t want car paint on your aircraft.  See why below…

 

On ‎2‎/‎23‎/‎2018 at 11:33 AM, Hyett6420 said:

  Ok FAA you need to regulate paint shops. ;)  

 

The FAA does regulate paint shops.  We are an FAA Part 145 Repair Station paint shop.  The FAA audits us at least annually to make sure we are following regulations.  They pull a sample of our paint work orders to make sure we are following aircraft maintenance manuals.  Some manuals not only specify paint process, but also which paint has to be used.  Cirrus aircraft for example specifies a specific Axalta (used to be DuPont) paint.  Older Cirrus specified PPG.  They are also checking what kind of paint we are using.  See why below…

 

On ‎2‎/‎23‎/‎2018 at 3:26 PM, DonMuncy said:

I'm not really very familiar with automotive or aircraft paint. But I was of the opinion that aircraft paints were more expensive than automotive. Is that factual? Is there any downside to using automotive paint on a plane? If automotive paints are superior, why are the aircraft paint facilities still using aircraft products? Or do they? 

 

Aircraft paint is more expensive.  Its boutique compared to automotive paint.  Aviation paint is specifically formulated for the aviation environment.  Some of this is not as important on a single engine piston like we are flying, but aviation paint has to withstand 400-500 knot jet aircraft airspeeds in weather without it coming off.  It is formulated so that aviation fuels do not stain the finish.  It is resistant to hydraulic fluids like Skydrol that is used in some helicopters and jets.  Skydrol would strip automotive paint right off the aircraft.  Every can of aviation paint is also labeled with an expiration date and batch numbers for FAA traceability.  Just like anything that is permanently installed or applied to a certified aircraft, you can’t just install whatever you want.  You can’t go to Home Depot and buy a bunch of nuts, bolts, and screws and use them in your aircraft.  You can’t go to Radio Shack and buy a bunch of wires and wire up some avionics.  If something materially fails with a paint that causes a problem, the FAA wants to be able to trace the paint back to its date, and batch.  It can use this information to see if any other aircraft may be affected and determine failure root causes.  So yes, there is a downside to using car paint on an aircraft.  Automotive paints are superior in their ease of use and ability to make look good, but they are not formulated for the aviation environment, and they lack any traceability.  Frankly, I don’t know how someone can do a proper logbook sign off using car paint.  The FAA specifically looks at this when they audit us.  They also go through our paint cabinets.  If there is any expired paint or paint without traceability labels, we get a write-up.

 

On ‎2‎/‎23‎/‎2018 at 3:29 PM, aviatoreb said:

I thought the deal with factory auto paint was that it was painted on in booths and then baked on.  Making it not reasonable for aircraft repainting shops.

 

This is exactly how paint is applied.  We have a paint booth/hangar, we apply the paint, and then bake it on.  A paint booth moves the air while you are spraying so that you don’t have overspray settling on your paint job.  It also heats the air so that you are spraying in a warm temperature.  After it is sprayed, it is baked for proper curing.  Our booth can heat the air to 170 degrees F and it exchanges the entire volume of air in the entire hangar every 48 seconds.

 

If you don’t have a paint booth and are painting in a regular hangar, you have much more chance of dirt and debris getting in your paint, overspray, etc. because there is not as clean of an environment and doesn’t have sufficient air movement.  If you are not baking the paint, some painters will kick the accelerant to make it dry faster which can kill the gloss of the paint.  Or you can just wait a couple days for the paint to dry.  Which also extends the amount of time dirt or debris can settle into the paint.

 

On ‎2‎/‎23‎/‎2018 at 4:45 PM, Hyett6420 said:

My understanding is that air paint is thinner and lighter, but to be honest, i know nought about car paints.  

Actually, car paint would be thinner and lighter.  It's water based.

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Answering @xcrmckenna's question about the legality of using automotive paint, let me first start by saying I am not an FAA Attorney so I am not going to make a definitive statement about the legality of it.  I will offer my opinion on it below.

 

What I can provide you is some information about what the FAA has to say about it and you can make your own conclusion.  I own a part 145 Repair Station.  The FAA has direct oversight of our operations and processes as it pertains to working on FAA certified aircraft.  The FAA requires us to use aviation paint because it is specifically formulated for aviation, and it meets the expiration and traceability requirements that we have to adhere to as a Repair Station. 

 

As I wrote in my prior responses, automotive paint is not formulated to be resistant to the solvents, fuels, hydraulic fluids, etc. found in an aviation environment.  Relatively thinner automotive paint does not provide the same corrosion protection in an aircraft environment that an aviation paint has.  Paint is not just to make your plane look pretty, but it also serves as corrosion protection for the aircraft.

 

Putting the FAA aside, as a business, we warrant our paint work.  It does not make sense to put another paint that is not specifically formulated and tested for our specific application and industry on your airplane and then warrant it.  If the paint fails, the manufacturer surely will not warrant using non-aviation paint on an airplane.  They make aviation paint for a reason…  Keep in mind, the harsh environment that aviation paint is tested to.  A Jet at 40,000 feet experiences -60 degrees C and descends to the hot Arizona ramp at 120 deg F.  The pressure changes require flexibility.

 

This is a good article here from the Modification and Replacement Parts Association (MARPA) regarding, “FAA APPROVAL OF CONSUMABLE MATERIALS FOR TYPE CERTIFICATED  AIRCRAFT” www.pmamarpa.com/pdf/MARPAMaterials.pdf

 

You can find in the last two paragraphs of the introduction, the following, “The second category of consumable materials consists of those materials that become part of the aircraft, engine or propeller. Example of these items can include hydraulic fluids, lubricating oils, greases, sealants, adhesives, room temperature vulcanizing silicone compounds, paints, lock-wire, and high temperature tapes. These materials are all consumable items that become part of the aircraft, engine or propeller, and they were part of the type certificated product when the FAA approved the product.

 

Under current regulations, materials that are reasonably likely to be installed on a type certificated product (those that become part of the aircraft, engine or propeller) must be produced under FAA-approval, or they must fit within one of the regulatory exceptions to the approval paradigm.

 

The FAA views paint as a consumable that is applied to an article.  If it stays on the article (your aircraft), then the FAA has something to say about it.

 

Basically, the PMA rules state that if the material is reasonable likely to be installed on a type certificated product then it needs to be FAA approved or fit into a recognized FAA exception.

 

One exception is the MIL-spec that aviation paint is approved to.

 

Materials that are produced in compliance with a government or established industry specification (i.e. standard materials; e.g. materials produced to AMS, ASTM or MIL standards);

 

From the FAA maintenance Airframe Mechanic manual…  https://www.faa.gov/regulations_policies/handbooks_manuals/aircraft/amt_airframe_handbook/media/ama_Ch08.pdf

 

Page 8-2 first paragraph:  “Paint is more than aesthetics; it affects the weight of the aircraft and protects the integrity of the airframe. The topcoat finish is applied to protect the exposed surfaces from corrosion and deterioration. Also, a properly painted aircraft is easier to clean and maintain because the exposed surfaces are more resistant to corrosion and dirt, and oil does not adhere as readily to the surface.

 

A wide variety of materials and finishes are used to protect and provide the desired appearance of the aircraft. The term “paint” is used in a general sense and includes primers, enamels, lacquers, and the various multipart finishing formulas. Paint has three components: resin as coating material, pigment for color, and solvents to reduce the mix to a workable viscosity.

 

Internal structure and unexposed components are finished to protect them from corrosion and deterioration. All exposed surfaces and components are finished to provide protection and to present a pleasing appearance. Decorative finishing includes trim striping, the addition of company logos and

emblems, and the application of decals, identification numbers, and letters.”

 

Page 8-10 under “Primer and Paint”:  Purchase aircraft paint for the aviation painting project.  Paint manufacturers use different formulas for aircraft and automobiles because of the environments they operate in. The aviation coatings are formulated to have more flexibility and chemical resistance than the automotive paint.

 

And finally, in many cases the aircraft Maintenance Manual will spell out at a minimum a MIL spec for the paint to use.  At a maximum, it will spell out a specific paint manufacturers product AND color.  The Cirrus is an example of the latter.

 

Your aircraft maintenance manual or structural repair manual will have the requirements of paint and is what any paint shop must adhere to.  Certainly, painting an aircraft in violation of what is specifically stated in the maintenance manual or structural repair manual would not be legal.

 

As to a Mooney…  The older aircraft maintenance manuals are not concrete in their requirements.  I have not looked at one of the newer aircraft manuals.  In the case where it is not spelled out in specific detail I would argue it is still best practice to put aviation paint on an aircraft.

 

In my opinion, there is no logical reason to not use aviation paint on your airplane, other than car paint might be cheaper and more convenient to use.  Aircraft paint is made for aircraft.  The FAA requires us as a repair station to use it, based on that I think one can infer what the FAA thinks about it…

 

An A&P painting your airplane may not have the same FAA oversight that a repair station has and may have no problem using car paint.  Do I think the FAA is going to be knocking down your door in the middle of the night due to automotive paint on your plane?  No.  Does the FAA endorse car paint on your plane?  Certainly not.  Do I personally think using car paint is legal?  For whatever my opinion is worth and in light of what I presented above, no.

 

Dan

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Answering [mention=12769]xcrmckenna[/mention]'s question about the legality of using automotive paint, let me first start by saying I am not an FAA Attorney so I am not going to make a definitive statement about the legality of it.  I will offer my opinion on it below.

 

What I can provide you is some information about what the FAA has to say about it and you can make your own conclusion.  I own a part 145 Repair Station.  The FAA has direct oversight of our operations and processes as it pertains to working on FAA certified aircraft.  The FAA requires us to use aviation paint because it is specifically formulated for aviation, and it meets the expiration and traceability requirements that we have to adhere to as a Repair Station. 

 

As I wrote in my prior responses, automotive paint is not formulated to be resistant to the solvents, fuels, hydraulic fluids, etc. found in an aviation environment.  Relatively thinner automotive paint does not provide the same corrosion protection in an aircraft environment that an aviation paint has.  Paint is not just to make your plane look pretty, but it also serves as corrosion protection for the aircraft.

 

Putting the FAA aside, as a business, we warrant our paint work.  It does not make sense to put another paint that is not specifically formulated and tested for our specific application and industry on your airplane and then warrant it.  If the paint fails, the manufacturer surely will not warrant using non-aviation paint on an airplane.  They make aviation paint for a reason…  Keep in mind, the harsh environment that aviation paint is tested to.  A Jet at 40,000 feet experiences -60 degrees C and descends to the hot Arizona ramp at 120 deg F.  The pressure changes require flexibility.

 

This is a good article here from the Modification and Replacement Parts Association (MARPA) regarding, “FAA APPROVAL OF CONSUMABLE MATERIALS FOR TYPE CERTIFICATED  AIRCRAFT” www.pmamarpa.com/pdf/MARPAMaterials.pdf

 

You can find in the last two paragraphs of the introduction, the following, “The second category of consumable materials consists of those materials that become part of the aircraft, engine or propeller. Example of these items can include hydraulic fluids, lubricating oils, greases, sealants, adhesives, room temperature vulcanizing silicone compounds, paints, lock-wire, and high temperature tapes. These materials are all consumable items that become part of the aircraft, engine or propeller, and they were part of the type certificated product when the FAA approved the product.

 

Under current regulations, materials that are reasonably likely to be installed on a type certificated product (those that become part of the aircraft, engine or propeller) must be produced under FAA-approval, or they must fit within one of the regulatory exceptions to the approval paradigm.

 

The FAA views paint as a consumable that is applied to an article.  If it stays on the article (your aircraft), then the FAA has something to say about it.

 

Basically, the PMA rules state that if the material is reasonable likely to be installed on a type certificated product then it needs to be FAA approved or fit into a recognized FAA exception.

 

One exception is the MIL-spec that aviation paint is approved to.

 

Materials that are produced in compliance with a government or established industry specification (i.e. standard materials; e.g. materials produced to AMS, ASTM or MIL standards);

 

From the FAA maintenance Airframe Mechanic manual…  https://www.faa.gov/regulations_policies/handbooks_manuals/aircraft/amt_airframe_handbook/media/ama_Ch08.pdf

 

Page 8-2 first paragraph:  “Paint is more than aesthetics; it affects the weight of the aircraft and protects the integrity of the airframe. The topcoat finish is applied to protect the exposed surfaces from corrosion and deterioration. Also, a properly painted aircraft is easier to clean and maintain because the exposed surfaces are more resistant to corrosion and dirt, and oil does not adhere as readily to the surface.

 

A wide variety of materials and finishes are used to protect and provide the desired appearance of the aircraft. The term “paint” is used in a general sense and includes primers, enamels, lacquers, and the various multipart finishing formulas. Paint has three components: resin as coating material, pigment for color, and solvents to reduce the mix to a workable viscosity.

 

Internal structure and unexposed components are finished to protect them from corrosion and deterioration. All exposed surfaces and components are finished to provide protection and to present a pleasing appearance. Decorative finishing includes trim striping, the addition of company logos and

emblems, and the application of decals, identification numbers, and letters.”

 

Page 8-10 under “Primer and Paint”:  Purchase aircraft paint for the aviation painting project.  Paint manufacturers use different formulas for aircraft and automobiles because of the environments they operate in. The aviation coatings are formulated to have more flexibility and chemical resistance than the automotive paint.

 

And finally, in many cases the aircraft Maintenance Manual will spell out at a minimum a MIL spec for the paint to use.  At a maximum, it will spell out a specific paint manufacturers product AND color.  The Cirrus is an example of the latter.

 

Your aircraft maintenance manual or structural repair manual will have the requirements of paint and is what any paint shop must adhere to.  Certainly, painting an aircraft in violation of what is specifically stated in the maintenance manual or structural repair manual would not be legal.

 

As to a Mooney…  The older aircraft maintenance manuals are not concrete in their requirements.  I have not looked at one of the newer aircraft manuals.  In the case where it is not spelled out in specific detail I would argue it is still best practice to put aviation paint on an aircraft.

 

In my opinion, there is no logical reason to not use aviation paint on your airplane, other than car paint might be cheaper and more convenient to use.  Aircraft paint is made for aircraft.  The FAA requires us as a repair station to use it, based on that I think one can infer what the FAA thinks about it…

 

An A&P painting your airplane may not have the same FAA oversight that a repair station has and may have no problem using car paint.  Do I think the FAA is going to be knocking down your door in the middle of the night due to automotive paint on your plane?  No.  Does the FAA endorse car paint on your plane?  Certainly not.  Do I personally think using car paint is legal?  For whatever my opinion is worth and in light of what I presented above, no.

 

Dan




Dan,

Thank you for all of the info and your time typing and researching this. I wish your shop was closer to Oregon.



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I’ve heard of folks painting their experimental aircraft with auto paint with no ill effects.  Heck, lots of them are now using vinyl wraps. One of my pals used it on his RV12. He claimed it was lighter, cheaper, and easier to install. I saw the finished product, looked great.

I’ll bet cash money this is nothing more than the FAA stalling us in the technology of yesteryear in the name of safety.

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IIRC on Cirrus aircraft part of the paints job is to provide UV protection for the composite structure underneath so that sunlight exposure doesn't compromise the strength of the plastic airplane. Proper paint is vital to jets and high performance airplanes because (as mentioned, the environment they operate in and the chemicals they carry and use (Skydrol is a killer if you've never used it. Great paint stripper on shoe sole disolver. They say it causes "mild eye irritation- BS, you're blind for 30 mins!, BTDT).

This has been a very enlightening thread. Learn something new every day. 

It seems that as time has marched on over the last 50 years since our airplanes were first made that paint selection has been more focused and restricted as regulations have been modified and interpreted by not only the Feds but the manufacturers themselves.  Just look at the 1964 Pilot's Handbook and the current POH on Mooneys. Same basic airplane, 5 decades difference in time and regulations. 

Dan, thanks for all the effort in your postings. 

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40 minutes ago, jlunseth said:

Why, after spending all the time it takes to remove the old paint without harming the airframe, would anyone want to use anything less than the best product for the job?

I think that is the point someone made or attempted to make.  We know aviation technology is behind automotive for many reasons and that cluld be applied to airplanes.  Yes, jets and hydraulic fluid from skydrol are demanding, but do those challwnges exist in our mooneys?  Perhaps that is the reason paint jobs cost $15k....i had my cessna repainted 20 years ago for $5k, yes slightly smaller but a hige increase beyond inflation.

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There are $5000 paint jobs and there are $15000 paint jobs. Its all in the detail taken and the repairs needed when stripped. There is still a wide spectrum of paint jobs but, by and large, the cost has escalated so that there are very few bottom  end  shops any more. I think one can still find a scratch and spray job if one looks far enough. 

I'm willing to bet that good automotive stuff would far exceed any testing parameters if it was done. The only barrier?  $$$$$$$$$$$$

Water based auto paints are really good now a days. They can last forever even in direct sun every day. 

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1 hour ago, cliffy said:

There are $5000 paint jobs and there are $15000 paint jobs. Its all in the detail taken and the repairs needed when stripped. There is still a wide spectrum of paint jobs but, by and large, the cost has escalated so that there are very few bottom  end  shops any more. I think one can still find a scratch and spray job if one looks far enough. 

I'm willing to bet that good automotive stuff would far exceed any testing parameters if it was done. The only barrier?  $$$$$$$$$$$$

Water based auto paints are really good now a days. They can last forever even in direct sun every day. 

Water based paints aren't there yet in reliability and durability. Just a couple of years ago, we had to have a Falcon 2000 stripped and light corrosion cleaned from the tops of the wings and the fuselage caused by water base pre-coat. 

The airplane was repainted the old fashion and reliable method of etch, alodined, prime and Jet Glo paint. I for one refuse to use any water base product on my cars or airplanes until it's finally proven to not cause corrosion from trapped moisture and it's reliable. Too much labor or me to do a paint job twice. 

David

Edited by Sabremech
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10 hours ago, cliffy said:

I wonder if it was the application process used? Maybe aluminum instead of steel? Failure of the undercoat/primer?

Have a good friend with a high end body shop who really likes water based paints. 

I don't know as Dassault won't tell us the real cause. They had to strip and repaint quite a number of the airplanes that were painted with the early system. They are also now getting bit with using environmentally friendly primer and sealer in the fuel tanks. Microbes and corrosion on relatively new airplanes. 

This stuff is not there yet. It will be someday but isn't yet. I'm not willing to be the experiment and pay for a job twice. I'll stick with tried and true for as long as I can. 

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Don't mess with the paint geeks - they take their business seriously and engineer their products for the specific application.  For a more involved discussion in a different environment look at Porsche's process for ordering a custom color on a new car.   Just for the color it's a 7k option and could take 3-6 months for approval testing.   The short version is that each requested color is tested on all the surfaces(composists, aluminum, steel, plastic etc) of where it will be applied and evaluated after being exposed to each possible environmental factor over time - heat, sunlight, cold and whatever else they think of.  Remember this is just for a non-factory color - the same paint formulation is being used - just a COLOR change.  Like any specialization - the geeks know their shit.  If Porsche takes its paint this seriously for just color, I would not waste a second on putting a paint formulated for another environment on my plane.

Btw - google irish green 911 - my personal favorite.

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16 minutes ago, rpcc said:

Don't mess with the paint geeks - they take their business seriously and engineer their products for the specific application.  For a more involved discussion in a different environment look at Porsche's process for ordering a custom color on a new car.   Just for the color it's a 7k option and could take 3-6 months for approval testing.   The short version is that each requested color is tested on all the surfaces(composists, aluminum, steel, plastic etc) of where it will be applied and evaluated after being exposed to each possible environmental factor over time - heat, sunlight, cold and whatever else they think of.  Remember this is just for a non-factory color - the same paint formulation is being used - just a COLOR change.  Like any specialization - the geeks know their shit.  If Porsche takes its paint this seriously for just color, I would not waste a second on putting a paint formulated for another environment on my plane.

Btw - google irish green 911 - my personal favorite.

Right on.

I presume the paint formulated for GA is designed also for the way it is expected to be applied.

Isn't factory car paint often applied in specialized booths and baked on?

I once had the pleasure to tour a research facility that included paint geeks - in their own specialized environment.  When I worked at USNA, across the river right near by was a W Tayler Ship research base, and that included a bunch of people doing paint research which is a very important topic in the Navy since they have all those steel ships floating in corrosive salty water.  And somehow they make it work with good paint.  Although their color choice is usually so boring.  Dull grey.  Why don't you ever see a destroyer in sparkly candy apple red with a silver swoopy stripe down the side?  Now that would be cool.

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