kortopates Posted October 10, 2019 Report Posted October 10, 2019 (edited) Its an interesting issue and one I don't have any qualifications to say right or wrong. But I know a few here have gone through the STC and PMA process and have a better understanding of what's involved to get FAA approval. But I do understand Guy's argument, which I believe amounts to that he is merely supplying the raw materials for the owner or mechanics to install. Taking an example, his baffling kits, where he saves the owner/mechanic time in sourcing the baffling material and supplies as well as pre-cutting the baffling segments. Does the baffling material turn into a unapproved part once he cuts it to match an old one without obtaining an STC and PMA? The FAA apparently believes so yet Guy thinks not. But I believe Guy can also provide specially formed ducting which appears much harder to justify as merely pre-cut raw materials. The forming of the ends of the ducting is much more involved that just cutting it so here I get where the FAA is coming from. That said he provides a real need or value to the plane owners, so I hope this doesn't shut him down and he finds an economically feasible way to stay in business and meet the FAA's requirements. Edited October 10, 2019 by kortopates 2 Quote
carusoam Posted October 10, 2019 Report Posted October 10, 2019 Sounds like a good resource and case for owner produced parts... As Guy was cutting with precision, the aviation quality materials... based on the designs and parts that owners were sending him... I’m sure there are proper legal channels to be followed... It probably took years for our engine controls guys to get figured out... The FAA is slowly moving in the right direction, sort of glacially... Planes are going too long without proper replacements that can be properly made and supplied as owner produced parts... Continuing the grass roots campaign... when left too long... Engine controls have stuck and broke... Fuel caps have leaked water entry at an alarming rate... Engine CHTs have become hard to control... Add airbags and seat belts to this list as well... How does one certify, or properly manufacture, a better solution to a $10 part, that can be life saving? The $600 cost is clearly getting in the way of owners doing what needs to be done. There are too many $600 needs on each plane... Giant PP surmising, not a legal genius... Best regards, -a- 2 Quote
carusoam Posted October 18, 2019 Report Posted October 18, 2019 Hey!!! Guy is alive! @GEE-BEE There are a couple of requests floating around here lately for intake hoses... I think the factory quoted price was .6amu... If you have a minute to review that project again... Best regards, -a- 1 Quote
Yetti Posted October 19, 2019 Report Posted October 19, 2019 On 10/17/2019 at 11:08 PM, carusoam said: Hey!!! Guy is alive! @GEE-BEE There are a couple of requests floating around here lately for intake hoses... I think the factory quoted price was .6amu... If you have a minute to review that project again... Best regards, -a- A year ago they were unatainable. I had SWTA drop ship one from the factory this Feb for about $320.00. Seems like alot for a semi flexible rubber over cloth piece. But they have the mold. You still have to cut the holes. I used a leather punch with the aluminum squares in situ. Seems like a perfect application for something in silicone. The top center bolt is a bith to start. I saved my old one in case I want to play with silicone molding and such. 1 Quote
Guest Posted October 20, 2019 Report Posted October 20, 2019 It seems goofy to me an exhaust system can be replaced entirely with new and it’s called a “repair” because by just one tiny part was re-used. Yet Gee Bee pre-cuts baffle seal material to fit and he’s in trouble. The FAA clearly has an over staffing issue. Clarence Quote
EricJ Posted October 20, 2019 Report Posted October 20, 2019 4 hours ago, M20Doc said: It seems goofy to me an exhaust system can be replaced entirely with new and it’s called a “repair” because by just one tiny part was re-used. Yet Gee Bee pre-cuts baffle seal material to fit and he’s in trouble. The FAA clearly has an over staffing issue. Clarence Overstaffing is apparently not the issue. My understanding is that there have been significant problems with unauthorized/counterfeit PMA stuff and the FAA has been in crackdown mode. I think Gee Bee just got caught in that, right or wrong. Quote
Jblanton Posted October 20, 2019 Report Posted October 20, 2019 I have a G model with carburetor. This is what I am doing next time I need a boot. I am an IA, and do have experience on many types of planes. The manufactures that hook the engine to the cowling with a flex duct all have the same problem. Why just keep doing the same thing? I am going to be doing a field approval, and making the duct out of aluminum. The filter will be mounted solid to the airbox, and the cowl will be slightly modified to allow the filter to move behind the trim plate of the cowl. Who knows, maybe I will do an STC. Jeff 2 Quote
Sabremech Posted October 22, 2019 Report Posted October 22, 2019 On 10/20/2019 at 11:16 AM, Jblanton said: I have a G model with carburetor. This is what I am doing next time I need a boot. I am an IA, and do have experience on many types of planes. The manufactures that hook the engine to the cowling with a flex duct all have the same problem. Why just keep doing the same thing? I am going to be doing a field approval, and making the duct out of aluminum. The filter will be mounted solid to the airbox, and the cowl will be slightly modified to allow the filter to move behind the trim plate of the cowl. Who knows, maybe I will do an STC. Jeff Hi Jeff, I think you have a good idea to fix the problem of the induction boot availability, but other issues will pop up that you don't expect. Personally, I think making a new FAA/PMA induction boot out of newer and more robust materials would be the way to go and cost much less for you and your customers in the long run. Thanks, David 3 Quote
tigers2007 Posted October 22, 2019 Report Posted October 22, 2019 What is the viability of making a mass production of owner-produced part bases (similar to 80% firearm receivers)? I could have 1000 baggage door hinge sets stamped out very cheaply and leave the end screw holes pilot drilled for the owner to complete. I’m sure our vast MS community has Chi-Com connections that could mass produce the accordions on the cheap and have them “trim to fit” by making the end flanges extra-rubbery. Or is there some sort of technique to overhaul the accordions by dipping or spraying them with a coat of specialized aviation grade rubbery material that won’t crumble?Sent from my iPhone using Tapatalk Quote
cliffy Posted October 23, 2019 Report Posted October 23, 2019 Owner produced part has to match what the original part was (IIRC) and NOT be a completely new design (that makes it an Alteration of the Approved Design). It still has to have FAA approved data. Here's a cut from the controlling AC (AC loaded below). Find approved data for the part and have at it! (2) Parts produced by an owner or operator for maintaining or altering their own product and which are shown to conform to FAA-approved data. https://www.faa.gov/documentlibrary/media/advisory_circular/ac 20-62e.pdf Quote
cliffy Posted October 23, 2019 Report Posted October 23, 2019 6 hours ago, tigers2007 said: What is the viability of making a mass production of owner-produced part bases (similar to 80% firearm receivers)? I could have 1000 baggage door hinge sets stamped out very cheaply and leave the end screw holes pilot drilled for the owner to complete. I’m sure our vast MS community has Chi-Com connections that could mass produce the accordions on the cheap and have them “trim to fit” by making the end flanges extra-rubbery.Or is there some sort of technique to overhaul the accordions by dipping or spraying them with a coat of specialized aviation grade rubbery material that won’t crumble? Sent from my iPhone using Tapatalk Doing that would constitute a "Repair" procedure that requires some kind of FAA approved or accepted data that tells you how to do it. Just can't make up a procedure. Quote
jetdriven Posted October 31, 2019 Report Posted October 31, 2019 Are you sure that is even EPDM rubber? All the EP DM I’ve seen last 15 years or longer. It’s not the same as this nitrile rubber sprayed over fabric that it probably is made of 1 Quote
Prior owner Posted October 31, 2019 Report Posted October 31, 2019 Now we just need a rectangular one for the “C” models! 1 Quote
carusoam Posted November 1, 2019 Report Posted November 1, 2019 Now we just need somebody to bring the idea to Mooney to update a drawing with modern materials so Guy can get to work on the ultimate Mooney intake hose... Why would it be called the ultimate hose... probably the last one that would ever need to be redesigned... hmm.... Best regards, -a- 1 Quote
tigers2007 Posted November 1, 2019 Report Posted November 1, 2019 Can you just start banging out silicone accordions from your production line and make one of the end flanges “oversized” so they can be “trimmed to fit”?I see your tubular design has the accordion incorporated; how difficult is it to construct the accordion in a square design? (I am not familiar with how these are formed; mold?)Sent from my iPhone using Tapatalk Quote
Shiny moose Posted November 2, 2019 Report Posted November 2, 2019 Who has the molds? Are they sitting somewhere on a shelf! Let get that mold to GeeBee and see what he can come up with maybe everyone will be happy Quote
cctsurf Posted November 2, 2019 Report Posted November 2, 2019 14 hours ago, Shiny moose said: Who has the molds? Are they sitting somewhere on a shelf! Let get that mold to GeeBee and see what he can come up with maybe everyone will be happy except the faa... "We're not happy 'till you're not happy" --FAA Quote
Shiny moose Posted November 3, 2019 Report Posted November 3, 2019 18 hours ago, cctsurf said: except the faa... "We're not happy 'till you're not happy" --FAA we could all individually help him with the design, the fab process, and quality control of the part, and or supervise from afar to be able to call it a owner produced part. Im thinking a written (fill out) form that shows needed information to meet the requirements . He just would not be able to have them sitting on the shelf and would have to produce them as needed which might get expensive for us from AC 20-62E Owner/Operator Produced Part. Parts that were produced by an owner/operator for installation on their own aircraft (i.e., by a certificated air carrier). An owner/operator is considered a producer of a part, if the owner participated in controlling the design, manufacture, or quality of the part. Participating in the design of the part can include supervising the manufacture of the part or providing the manufacturer with the following: the design data, the materials with which to make the part, the fabrication processes, assembly methods, or the quality control (QC) procedures. 2 Quote
tigers2007 Posted November 3, 2019 Report Posted November 3, 2019 Well I’m confident we have some engineers here. We have importers and supply chain folks too. We have several members already embedded into the expensive and time-consuming certification process. “Necessity leads to invention”. Maybe if we could make this issue more visible to our technical experts who are also subject to the accordion issue, then this significant part shortage will move closer to resolution. Maybe we can create a work group to identify and resolve these oddball parts that are critically necessary but no longer made. The easiest solution that comes to my mind is Gee-Bee hammering out a large batch of them that are “trim to fit” (I’m guessing it would come with oversized flanges?) and us paying a premium to have them well constructed and for them to last for a long time. Sent from my iPhone using Tapatalk Quote
N201MKTurbo Posted November 3, 2019 Report Posted November 3, 2019 I’m sure the original manufacturer still has the tooling. If you ordered enough of them they would make them for you. The problem is the PMA paperwork. It is probably held by Mooney who is ultimately responsible for assuring that the parts conformed to the drawings. The easiest way to get more is to bug Mooney to order more parts made. My son works in purchasing at Boeing. He has to bug suppliers when they don’t deliver on time. He is very busy! He says some custom short run parts like this need to be ordered a year in advance and then you are lucky to get them when promised. All the aerospace suppliers are swamped. 1 Quote
N201MKTurbo Posted November 3, 2019 Report Posted November 3, 2019 With small runs like this the labor and materials to manufacture the part is a small part of the actual cost to manufacturer it. It goes like this: Mooney sends a RFQ to supplier. $ to prepare RFQ. Supplier researches past production and current production schedules and prepares a quote. $ to prepare quote. Mooney receives quote and prepares purchase order. $ to prepare purchase order. Suppler receives PO. orders material, schedules production. $$ to do all that. Supplier receives material, creates production travelers, finds and prints drawings, instructions and tooling for production. Kit sent to production. $$ to do this. Parts built. If anything goes wrong go back 3 steps. $ for this Parts sent to quality for inspection. $ Parts sent to shipping for packaging and shipping. $ Mooney receives parts. $ Mooney inspects parts and adds them to their inventory. $ Mooney ships parts to fulfill outstanding orders. $ As you can see actual manufacturing is a small part of the cost. If a business doesn't account for all the $ above they go out of business! Quote
cliffy Posted November 3, 2019 Report Posted November 3, 2019 You can do an OPP but it still has to conform FAA Approved Data for the part. Getting the FAA Approved Data is the kicker. Either buy it from the manufacture or submit it and have it approved by the FAA You just can't make it up. Best guess, or as good as, or better than, won't cut it. Secondly the part has to be made in complete compliance with the FAA Approved Data. Change one item (polyethylene to silicone for instance) and now the part is non-conforming to the data and not legal. These are just 2 of the four legs of the Approved Table that have to be met for an OPP. 1 Quote
carusoam Posted November 3, 2019 Report Posted November 3, 2019 Hmmmm... If somebody was sooo skilled at making Mooney cowls... Ultra familiar with the STC process... knows parts manufacturing... Would going the next step make a lot of sense..? Connect the new cowl to the Old intake(s)... with a decent, flame resistant, Smooth bored, air hose... PP musings only, I have an IO550... wich May make a good example for (I)O360s... Best regards, -a- Quote
Sabremech Posted November 3, 2019 Report Posted November 3, 2019 (edited) 5 hours ago, carusoam said: Hmmmm... If somebody was sooo skilled at making Mooney cowls... Ultra familiar with the STC process... knows parts manufacturing... Would going the next step make a lot of sense..? Connect the new cowl to the Old intake(s)... with a decent, flame resistant, Smooth bored, air hose... PP musings only, I have an IO550... wich May make a good example for (I)O360s... Best regards, -a- I’d be more than willing to share my Quality Assurance manual with anyone who wants to get started in the FAA/PMA parts business. I currently have no plans after the cowling projects to do any more FAA/PMA parts manufacturing. It’s too time consuming and cost can be outrageous. My last part took 2 years to get certified and it was a part for an aircraft potable water system. If you’re part isn’t an item directly related to safety, you’re at the back of the line. That part made me seriously consider getting out of the business and do something else. The Cowling project is my last as I turn my focus to specialized tooling for the aging aircraft mechanics. No certification required for tooling and a definite need. Again, if anyone wants to tackle this, I’ll send you a copy of my manual to copy that will make getting your PMA much easier. Thanks, David Edited November 4, 2019 by Sabremech 1 Quote
EricJ Posted November 4, 2019 Report Posted November 4, 2019 5 hours ago, cliffy said: You can do an OPP but it still has to conform FAA Approved Data for the part. Getting the FAA Approved Data is the kicker. Either buy it from the manufacture or submit it and have it approved by the FAA You just can't make it up. Best guess, or as good as, or better than, won't cut it. Secondly the part has to be made in complete compliance with the FAA Approved Data. Change one item (polyethylene to silicone for instance) and now the part is non-conforming to the data and not legal. These are just 2 of the four legs of the Approved Table that have to be met for an OPP. There are also minor and major repairs and alterations that can be performed. Very few Mooneys are how they were when they left the factory. 1 Quote
Recommended Posts
Join the conversation
You can post now and register later. If you have an account, sign in now to post with your account.