Calling A&P, IA, and Avionics folks - used avionics paperwork questions

[65eTurbo]

So, I'm looking at some used avionics.  Anyone here with expertise and without a business model to protect that can set me straight.  I'm patching together info from multiple sources.  I'm looking to establish what is legal, not what is safe.

Used avionics dealer sells equipment without 8130s, claims that installing said equipment is legal if an IA makes a log entry - "Removed xx, Serial Number yy, replaced with xx equipment, serial number zz."  Is that true without an 8130?  

Second question, say I wanted to replace a TC with a T&B using the same log entries, would that still be legal?

Third question, if I install a new transponder consistent with an STC and that STC made freely available by the holder, do I need anything more than an IA signoff "Installed aaa transponder in accordance with STC 12345.... blah blah blah" and a pitot static check?

Fourth question, if I install a GPS source bought used without an 8130 that is part of that STC and verify operation via the transponder computer check and a ground check, is that legal or is an 8130 or C o C required?  

Fifth question, am I asking the right questions?

Thanks.

Rant about STC installs limited to dealerships, pricing supports, absurdity of separate avionics components when it could all be one much cheaper box, big players forcing out little players by gumming up obtuse and unnecessary certification processes, the perpetual life of government bureaucracies etc. withheld.

Edited July 26, 2019 by 65eTurbo

[Yetti]

Well if Garmin is involved you have to use a dealer because they control the documentation.  The Garmin 175/comm kills off the 430W market because why give $7K for 15 year old equipment.

I could never find a STC for any of the Bendix King 155 165.   So an IA and a 337 are good because the Bendix king were factory installed and on the equipment list.

There was loose documentation back then so it makes it harder now.   The comfort level of your IA is your guide.

[EricJ]

Installation of anything with an STC requires a 337 with an IA signoff.   It also requires permission from the STC holder, usually in the form of the typical STC letter.

8130s are generally not required.

Transponder checks are required.   You'll need a full check with a pitot static check for IFR.
 

Disclaimer:   not quite an A&P yet although almost an A.

[carusoam]

65E,

your message seems to be vanishing... at least as seen via an iPad...

it appears to be light gray on a white background...

if I understand correctly...

Don’t swap a TC out to get only a TnB in exchange... that is going from bad to worse...

The TC is a technical step up, compared to the TnB... as a back-up in IMC, old worn gyros can really suck in bumpy turbulence... suck is a technical term for not usable in certain unexpected conditions...

Doing IR training in school planes, partial panel following a bumpy TC was near impossible as it just flicked around because of the bumps...

Sorry if I missed something... the original Post was hard to read.

Best regards,

-a- 

[kortopates]

Original post is totally unreadable from Tapatalk - invisible font like Anthony said. But couldn't read anything. I am betting the text was pasted in.


Sent from my iPhone using Tapatalk

[Niko182]

For all you fold wondering what it said.

 

So, I'm looking at some used avionics.  Anyone here with expertise and without a business model to protect that can set me straight.  I'm patching together info from multiple sources.  I'm looking to establish what is legal, not what is safe.

Used avionics dealer sells equipment without 8130s, claims that installing said equipment is legal if an IA makes a log entry - "Removed xx, Serial Number yy, replaced with xx equipment, serial number zz."  Is that true without an 8130?  

Second question, say I wanted to replace a TC with a T&B using the same log entries, would that still be legal?

Third question, if I install a new transponder consistent with an STC and that STC made freely available by the holder, do I need anything more than an IA signoff "Installed aaa transponder in accordance with STC 12345.... blah blah blah" and a pitot static check?

Fourth question, if I install a GPS source bought used without an 8130 that is part of that STC and verify operation via the transponder computer check and a ground check, is that legal or is an 8130 or C o C required?  

Fifth question, am I asking the right questions?

Thanks.

Rant about STC installs limited to dealerships, pricing supports, absurdity of separate avionics components when it could all be one much cheaper box, big players forcing out little players by gumming up obtuse and unnecessary certification processes, the perpetual life of government bureaucracies etc. withheld.

[Cruiser]

There are two parts to FAA approval of equipment in an aircraft.

First part is the equipment itself. Is the equipment tested and approved for aviation use? Normally this would be certified by TSO or now by ASTM testing. The 8130 form you are referencing only provides a paper trail to the history of the equipment. Normally an A&P needs evidence the equipment is operating properly. If there is no 8130 form then the A&P installing the equipment will need to approve it by testing after installed in the aircraft.

Second part is the use in a specific make and model of aircraft. Does the equipment to be installed have FAA approval for the specific Make and Model aircraft. The list of approved equipment can be found in the TC (type certificate).

If the equipment you are adding is not on the TC then normally an STC (supplemental type certificate) provides the evidence that the equipment is compatible with the airframe. Finally if there is not an STC there are many small parts that are not MAJOR modifications to the airframe that can be approved by the A&P/IA by logbook entry.

[65eTurbo]

2 hours ago, Cruiser said:

There are two parts to FAA approval of equipment in an aircraft.

First part is the equipment itself. Is the equipment tested and approved for aviation use? Normally this would be certified by TSO or now by ASTM testing. The 8130 form you are referencing only provides a paper trail to the history of the equipment. Normally an A&P needs evidence the equipment is operating properly. If there is no 8130 form then the A&P installing the equipment will need to approve it by testing after installed in the aircraft.

Second part is the use in a specific make and model of aircraft. Does the equipment to be installed have FAA approval for the specific Make and Model aircraft. The list of approved equipment can be found in the TC (type certificate).

If the equipment you are adding is not on the TC then normally an STC (supplemental type certificate) provides the evidence that the equipment is compatible with the airframe. Finally if there is not an STC there are many small parts that are not MAJOR modifications to the airframe that can be approved by the A&P/IA by logbook entry.

This is great. Thanks.  

Am I correct that the STC holder must grant permisson to use the STC for the airframe if it exists?

I read your comments to say that an A&P can determine if equipment is working properly in the aircraft in lieu of an 8130 that says it was working when removed from the previous aircraft.  Is it up to the judgement of the A&P?  In the case of a WAAS GPS source, could such a thing as a successful test by the integrating transponder and a ground test (like maybe a receiver) be sufficient?  Is there guidance from the FAA on what test are required if an 8130 isn't used?  I used equipment dealer represented that used equipment could be installed with nothing more than a logbook entry.

I understand that a pitot static cert is required for a transponder swap.

Edited July 26, 2019 by 65eTurbo

[JimB]

9 hours ago, Niko182 said:

Used avionics dealer sells equipment without 8130s, claims that installing said equipment is legal if an IA makes a log entry - "Removed xx, Serial Number yy, replaced with xx equipment, serial number zz."  Is that true without an 8130?  

Second question, say I wanted to replace a TC with a T&B using the same log entries, would that still be legal?

Third question, if I install a new transponder consistent with an STC and that STC made freely available by the holder, do I need anything more than an IA signoff "Installed aaa transponder in accordance with STC 12345.... blah blah blah" and a pitot static check?

Fourth question, if I install a GPS source bought used without an 8130 that is part of that STC and verify operation via the transponder computer check and a ground check, is that legal or is an 8130 or C o C required?  

Fifth question, am I asking the right questions?

Used avionics dealer sells equipment without 8130s, claims that installing said equipment is legal if an IA makes a log entry - "Removed xx, Serial Number yy, replaced with xx equipment, serial number zz."  Is that true without an 8130?  A FAA Form 8130 is just an industry form that is acceptable. If the truth were told, as an A&P I could put the same information on a cocktail napkin. Not saying you will get a lot of people to accept my napkin serviceable tag, but it does mean the same thing. To answer your question, I would at a minimum for any used equipment expect some sort of "Serviceable as Removed from NXXXX TT XXXX" paperwork signed by an A&P. Otherwise, how do you have any idea about it? 

Second question, say I wanted to replace a TC with a T&B using the same log entries, would that still be legal? It depends, but everything else being ok (serviceable unit, TSO'd or FAA Approved in some way) yes it would be legal. Now if you are removing part of the Positive Control wing leveler system that is the POH and now it is disabled, you need to have a discussion with the A&P/IA to determine if that would be considered a Major Alteration. 

Third question, if I install a new transponder consistent with an STC and that STC made freely available by the holder, do I need anything more than an IA signoff "Installed aaa transponder in accordance with STC 12345.... blah blah blah" and a pitot static check? Yes. You will need the IA to fill out a Form 337 (Major Alteration) and you need permission to use the STC. Many STC holders post a generic permission letter on the website. Garmin is not one of them.

21.120   Responsibility of supplemental type certificate holders to provide written permission for alterations.

A supplemental type certificate holder who allows a person to use the supplemental type certificate to alter an aircraft, aircraft engine, or propeller must provide that person with written permission acceptable to the FAA

Fourth question, if I install a GPS source bought used without an 8130 that is part of that STC and verify operation via the transponder computer check and a ground check, is that legal or is an 8130 or C o C required? An 8130 or CofC (certificates of conformance only come with new parts and then usually only standard parts) would not be required, but see all the other answers above. 

Fifth question, am I asking the right questions? I guess. Just be careful buying used equipment. Equipment removed serviceable during a panel upgrade at a reputable shop will usually come with some sort of traceability paperwork. Stolen junk smuggled in from other countries and sold as-is with no paperwork can really burn you.

[N201MKTurbo]

At the last IA refresher, we talked about this. If you don't have an individualized STC with explicit permission to use the STC, you are not complacently screwed. You need acceptable data to do a major alteration. An STC is a slam dunk. If you don't have an STC you can do it on a field approval using a copy of the STC as the approved data. You just have to convince the Principal Inspector that you are doing it according to the STC and that it applies to your equipment or is equivalent. The FAA man said this happens often when the company that holds the STC is out of business.

If the company is still in business and you just don't want to pay them, you will probably have a harder time convincing the FAA to go to all the trouble to do a field approval. It is a lot of work for them and they are overloaded.

[JimB]

3 minutes ago, N201MKTurbo said:

You need acceptable data to do a major alteration.

Huh?

[N201MKTurbo]

44 minutes ago, JimB said:

Huh?

You are correct, I should have used Approved Data.

https://www.aviationpros.com/tools-equipment/insurance-finance/aircraft/article/12008268/faa-feedback-approved-data-for-aircraft-maintenance

 

[65eTurbo]

 

 

Thanks.  That is great feedback.  Not sure why previous post was faded.  See further questions below.

1 hour ago, JimB said:

Used avionics dealer sells equipment without 8130s, claims that installing said equipment is legal if an IA makes a log entry - "Removed xx, Serial Number yy, replaced with xx equipment, serial number zz."  Is that true without an 8130?  A FAA Form 8130 is just an industry form that is acceptable. If the truth were told, as an A&P I could put the same information on a cocktail napkin. Not saying you will get a lot of people to accept my napkin serviceable tag, but it does mean the same thing. To answer your question, I would at a minimum for any used equipment expect some sort of "Serviceable as Removed from NXXXX TT XXXX" paperwork signed by an A&P. Otherwise, how do you have any idea about it? 

"Any idea about it?"  - got it. But, that said, is it legally required to have a traceability document?  Can an A&P effectively say "Installed and tested good" without a traceability document?

1 hour ago, JimB said:

Second question, say I wanted to replace a TC with a T&B using the same log entries, would that still be legal? It depends, but everything else being ok (serviceable unit, TSO'd or FAA Approved in some way) yes it would be legal. Now if you are removing part of the Positive Control wing leveler system that is the POH and now it is disabled, you need to have a discussion with the A&P/IA to determine if that would be considered a Major Alteration. 

Third question, if I install a new transponder consistent with an STC and that STC made freely available by the holder, do I need anything more than an IA signoff "Installed aaa transponder in accordance with STC 12345.... blah blah blah" and a pitot static check? Yes. You will need the IA to fill out a Form 337 (Major Alteration) and you need permission to use the STC. Many STC holders post a generic permission letter on the website. Garmin is not one of them.

My point here is that no special avionics expertise is required, other than pitot static test.  I can slide in a trig and an IA can do the paperwork with the publicly available STC?

 

21.120   Responsibility of supplemental type certificate holders to provide written permission for alterations.

A supplemental type certificate holder who allows a person to use the supplemental type certificate to alter an aircraft, aircraft engine, or propeller must provide that person with written permission acceptable to the FAA

Fourth question, if I install a GPS source bought used without an 8130 that is part of that STC and verify operation via the transponder computer check and a ground check, is that legal or is an 8130 or C o C required? An 8130 or CofC (certificates of conformance only come with new parts and then usually only standard parts) would not be required, but see all the other answers above. 

So, an 8130 is not required if it tests good, or more specifically if my IA says it tests good?

1 hour ago, JimB said:

Fifth question, am I asking the right questions? I guess. Just be careful buying used equipment. Equipment removed serviceable during a panel upgrade at a reputable shop will usually come with some sort of traceability paperwork. Stolen junk smuggled in from other countries and sold as-is with no paperwork can really burn you.

"Can really burn you."  Hopefully not the case here but, if something tests good, short of issues with stolen property, is there some other specific risk I should be concerned about?

[EricJ]

My understanding is that 8130-3 forms are only required for import/export of parts for traceability.    Domestic use of parts does not require, and does not prohibit, the use of an 8130.   Basically, for domestic installation of a part you obtained domestically, you do not need an 8130.

I go to our local aviation parts place (NOT the aviation aisle at Lowe's or HD, an actual aviation parts place), and have NEVER been handed an 8130 or any other kind of paperwork with anything that I have bought there.    Even at the airlines that do use them, they may get a single 8130 for a bin full of a dozen or more like parts.   Pull one out of the bin to use, and the next guy pulls the next one, but there's only one 8130 to cover all of them.   It's not important for GA, unless perhaps you're importing or exporting parts.

 

Edited July 28, 2019 by EricJ

[kortopates]

Only two things I haven't seen explicitly mentioned is:

1) When the OEM doesn't grant explicit permission to re-ue their STC to a second hand purchaser, then good chance their will be a significant fee for it depending on the vendor. I am don't know what garmin does but as an example, STEC charges a significant fee. Good to find this out before purchasing.

2) With used avionics acquired without an 8130 - you should realize you can send your used unit in to be benched checked and certified by the OEM or repair station with capability for the specific item. This will also allow you to update the unit to the latest mod level (include firmware and h/w updates that may add capability relevant to your installation.  Lots of talk here that may not be legally necessary, but do you believe that your A&P/IA can do anything more than superficially check out your unit to be working properly? Wouldn't you want to be sure the unit is working properly and have it get any calibration adjustments it may need before you install? Cost to do so are typically reasonable; depending on the vendor. For myself personally, I always factor the cost of doing this in evaluating the whether the item is worth it. Not so much for the piece of paper but for what it presents for getting it re-checked. Plus if the unit has significant issues you want to find this out this asap if you are buying from a reputable shop or person so you don't get stuck with it. Personally, If I can't make passing a re-certification with 8130 a condition of sale or refund, I won't buy it.  

[JimB]

On 7/26/2019 at 3:51 PM, EricJ said:

My understanding is that 8130-3 forms are only required for import/export of parts for traceability.    Domestic use of parts does not require, and does not prohibit, the use of an 8130.   Basically, for domestic installation of a part you obtained domestically, you do not need an 8130.

I go to our local aviation parts place (NOT the aviation aisle at Lowe's or HD, an actual aviation parts place), and have NEVER been handed an 8130 or any other kind of paperwork with anything that I have bought there.    Even at the airlines that do use them, they may get a single 8130 for a bin full of a dozen or more like parts.   Pull one out of the bin to use, and the next guy pulls the next one, but there's only one 8130 to cover all of them.   It's not important for GA, unless perhaps you're importing or exporting parts.

 

This is all very true. The reason for the traceability is just to know the where the part came from. If it fails after installation and causes a problem you will be able to say where it was purchased from and be able to prove it was an aircraft part. Even a receipt from the local parts store or your invoice from Aircraft Spruce becomes a traceability document. I'd have a hard time handing an FAA inspector my Ebay receipt....

But 65e, talk it over with your IA and really whatever they are comfortable with and willing to sign off is fine.