Any legal reason a USB charger has to be certified?

[MikeOH]

13 minutes ago, Shiny moose said:

Not picking a fight here but

They get to and you don't. Doing it anyway cause you think its good enough for them it must be good enough for me, getting an unsuspecting IA to sign an annual with installed unapproved parts, yes I agree would be disingenuous 

Hmm, seems to me that if an A&P inspects and determines the part to be airworthy, signs off on a 337 (if he thinks that's what it requires)...then it is no longer an unapproved part.

[ragedracer1977]

1 hour ago, cliffy said:

Below is a cut directly from the FAA website on electronic parts=

A part manufactured in complete compliance with an established industry or U.S. Government specification which includes design, manufacturing, test and acceptance criteria, and uniform identification requirements; or for a type of part which the Administrator has found demonstrates conformity based solely on meeting performance criteria, is in complete compliance with an established industry or U.S. Government specification which contains performance criteria, test and acceptance criteria, and uniform identification requirements. The specification must include all information necessary to produce and conform the part and be published so that any party may manufacture the part. Examples include, but are not limited to, National Aerospace Standard (NAS), Army-Navy Aeronautical Standard (AN), Society of Automotive Engineers (SAE), SAE Sematec, Joint Electron Device Engineering Council, Joint Electron Tube Engineering Council, and American National Standards Institute (ANSI).

This definition incorporates two categories of standard part criteria. Initially, the FAA recognized as “standard” those parts that met published specifications that included information clearly establishing design, materials, manufacture, and uniform identification requirements. The FAA issued a subsequent interpretation of standard part that provided for a class of parts conforming to a standard not based on their physical configuration but on their meeting a specified performance criterion. The FAA stated this second category of standard parts is best exemplified by discrete electrical and electronic parts. See 62 Fed. Reg. 9,923 (1997). The FAA must make a specific finding of applicability to a class of parts before the “performance only” criterion can be used.

So, in the above paragraph a standard part has to be made according to and tested to a specific design criteria set up by a nationally recognized authority. so that exact duplicates can be made by anyone.

The last sentence actually points to (as one example) an LED light bulb. The LED is not made to exactly duplicate the incandescent  light bulb that it wants to replace only its performance matches the called for light bulb THEREFORE it must have a separate FAA approval to be used. 

Ok, let's dig down the rabbit hole further.  Garmin has a TSOd charger.  If I get one, reverse engineer it, and build my own "Gorwim" chargers to exactly the same specs, is it now a standard part and could be sold without TSO?

[Shiny moose]

10 minutes ago, MikeOH said:

Hmm, seems to me that if an A&P inspects and determines the part to be airworthy, signs off on a 337 (if he thinks that's what it requires)...then it is no longer an unapproved part.

Are you meaning a field approval 337? What FSDO are you in haha

would you use a Fram oil filter on your mooney cause they make good filters, they are used everywhere, then try and tell your new IA Fram is acceptable cause the last mechanic signed the log book with the Fram installed

 

[MikeOH]

3 minutes ago, Shiny moose said:

Are you meaning a field approval 337? What FSDO are you in haha

Sigh... my point is if you get a 337 approved, the install is legal.

[MikeOH]

9 minutes ago, ragedracer1977 said:

Ok, let's dig down the rabbit hole further.  Garmin has a TSOd charger.  If I get one, reverse engineer it, and build my own "Gorwim" chargers to exactly the same specs, is it now a standard part and could be sold without TSO?

Forgetting the IP violations, I believe YOU will need to perform and submit test data to obtain a "Gorwim" TSO.  You can't just say, "Well, I built mine exactly like Garmin, so I can use their TSO."

[ragedracer1977]

1 minute ago, MikeOH said:

Forgetting the IP violations, I believe YOU will need to perform and submit test data to obtain a "Gorwim" TSO.  You can't just say, "Well, I built mine exactly like Garmin, so I can use their TSO."

I don't want to use the TSO.  I want it to be a standard part.  Since I used previously approved data, why wouldn't it be? All of these chargers are essentially the same.

How about the one I actually bought. The Guardian Avionics.  No TSO No PMA.  Produced under NORSEE.  FAA approved.  

At what point does a part become a standard part? If building it exactly the same, how could it not be? 

 

And, yes. I know I'm being obtuse.  Indulge me. I'm entertaining myself.  

[ragedracer1977]

1 hour ago, cliffy said:

Unfortunately I really don't like going into DVT. Just my thing. Just don't like the place. The restaurant is good however. 

Somehow I've never made it to page.  Want to do lunch sometime? 

[Shiny moose]

4 minutes ago, MikeOH said:

Sigh... my point is if you get a 337 approved, the install is legal.

337 are used for major repairs and alterations not for part approvals, I would think you would have difficulties Getting a major alteration 337 field approved with an unapproved part. 

[MikeOH]

2 minutes ago, ragedracer1977 said:

I don't want to use the TSO.  I want it to be a standard part.  Since I used previously approved data, why wouldn't it be? All of these chargers are essentially the same.

How about the one I actually bought. The Guardian Avionics.  No TSO No PMA.  Produced under NORSEE.  FAA approved.  

At what point does a part become a standard part? If building it exactly the same, how could it not be? 

 

And, yes. I know I'm being obtuse.  Indulge me. I'm entertaining myself.  

HAH!  Okay, I'll indulge you!

A TSO is not the same as a standard part.  But, obviously, you're just trying to build something you can legally install.  Using the 'previously approved data' would seem to be a path to getting a 337 approved.

I STRONGLY disagree that 'all of these chargers are essentially the same."  As a practicing EE, I can assure you they are not; especially in regards to EMI/RFI.  It costs extra components to achieve low EMI/RFI performance; the cheap options tend to lack the necessary components.

A part becomes standard when it conforms to the appropriate/applicable STANDARD specification (e.g. MS or AN hardwares).  There is not, to my knowledge, a FAA recognized standard for USB chargers!

It's more than building the same.  For one thing, it is common to have certified quality systems in place to insure consistent production processes are used.

[MikeOH]

3 minutes ago, Shiny moose said:

337 are used for major repairs and alterations not for part approvals, I would think you would have difficulties Getting a major alteration 337 field approved with an unapproved part. 

Maybe.  Yet, again, my point is that an approved 337 represents a legal, approved installation.

[ragedracer1977]

2 minutes ago, MikeOH said:

Maybe.  Yet, again, my point is that an approved 337 represents a legal, approved installation.

I guarantee I could get my IA to sign off on the charger I posted in the original post. 

I still won't install it, because the next IA or buyer might not feel the same way my IA did.  

[MikeOH]

Just now, ragedracer1977 said:

I guarantee I could get my IA to sign off on the charger I posted in the original post. 

I still won't install it, because the next IA or buyer might not feel the same way my IA did.  

Depending on cost, you might want to do that.  You have something legal to stand on.

[ragedracer1977]

Just now, MikeOH said:

Depending on cost, you might want to do that.  You have something legal to stand on.

$200 isn't really worth it.  I don't want to be the guinea pig lol

[MikeOH]

Just now, ragedracer1977 said:

$200 isn't really worth it.  I don't want to be the guinea pig lol

Yeah, I get that.

I installed a LED landing light and spent $100 to have my A&P sign it off.  Maybe it won't hold up...but, if I have some anal retentive IA balk at my A&P's approval, I'll just tell him to put in the GE bulb and give me the LED light back.  The hangar fairies will reinstall and I'll pick a different IA for the next year's annual

[Jeph357]

5 hours ago, MikeOH said:

Hmm, seems to me that if an A&P inspects and determines the part to be airworthy, signs off on a 337 (if he thinks that's what it requires)...then it is no longer an unapproved part.

Heres a good read. In my humble opinion, that would fall under the minor alteration category if you have an A&P to do it and sign the logbook then by all means have at it. If you really want to get crazy hook it up to the buss without cutting out the panel and check for EMI/RFI on the ground (not an exact flight representation but a start). Calculate the draw give it its circuit breaker maybe even a fuse....haha.. While your at it cutting out the panel make a blank so if it hurts an IA's feelings or a potential buyer when you choose to sell its an easy removal and not a hole in the panel. 

https://www.savvyaviation.com/wp-content/uploads/articles_eaa/EAA_2015-06_alterations.pdf

[EricJ]

6 hours ago, MikeOH said:

I STRONGLY disagree that 'all of these chargers are essentially the same."  As a practicing EE, I can assure you they are not; especially in regards to EMI/RFI.  It costs extra components to achieve low EMI/RFI performance; the cheap options tend to lack the necessary components.

Actually, I found that some of the cheapest ones were the quietest.

http://ericjacobsen.org/Files/USB_Power_Supply_RF_analysis_2.pdf

 

6 hours ago, MikeOH said:

A part becomes standard when it conforms to the appropriate/applicable STANDARD specification (e.g. MS or AN hardwares).  There is not, to my knowledge, a FAA recognized standard for USB chargers!

I think the point of the FAA citing the use of "industry standards" is that they are not FAA recognized standards.   They give some examples of industry standard bodies, but they do not say that it is a comprehensive list.   A TSO serves the purpose of an FAA standard.

 

6 hours ago, MikeOH said:

It's more than building the same.  For one thing, it is common to have certified quality systems in place to insure consistent production processes are used.

Manufacturing quality testing is typically separate from standard acceptance testing, though.

[J0nathan225]

shameless plug? I have a https://www.appareo.com/aviation/stratus-product-line/stratus-power-usb-charger/ listed on ebay. (new in box) PM me and I can sell direct to you. 

[PMcClure]

Bought this one yesterday: https://www.sportys.com/pilotshop/garmin-gsb-15-usb-charger.html?utm_source=google_shopping&m=configurable&508=7278&aid=24701&&mrkgcl=596&mrkgadid=3208669401&utm_medium=cpc&utm_campaign=Avionics+%26+Radios&adpos=&creative=295428070003&device=c&matchtype=&network=g&gclid=EAIaIQobChMI8sCOi7SD6AIViYjICh1ocgxREAQYASABEgLSffD_BwE&gclsrc=aw.ds

Legal or not, I don't want to muddy up a nice clean instal with a noisy charger. 

[Cruiser]

7 hours ago, Skates97 said:

Here we go a trolling...

I have a hangar neighbor a few hangars down with a beautiful RV that has lots of "non-certified" also not PMA/TSO's electronics/avionics in it. I have another friend around the corner with a Glasair (another pristine plane) with all kinds of "non-certified" also not PMA/TSO's electronics/avionics in it. Somehow the two of them manage to fly around without falling out of the sky or their radios quitting at the most inopportune moment causing a huge safety of flight issue. Yes, I know that my Mooney is not an experimental and thus requires certified or PMA/TSO parts in it per regulations and I knew that when I bought it. However, the argument that putting "non-certified" electronics in it can/will cause a safety of flight issue when there are experimentals flying around with those exact same electronics is disingenuous. Required by regulation? Sure. A safety factor? I have a hard time swallowing that when there are so many flying examples to the contrary.

I should check with my neighbors and see which usb power ports they have installed. My guess is probably something like one of these.

https://www.aircraftspruce.com/catalog/elpages/easmartdualusb.php?clickkey=156696

https://www.aircraftspruce.com/catalog/pspages/usb-adapter.php?clickkey=156696

the issue here is two fold. 

1. is it safe

2. is it legal

most likely both certified and experimental are safe

while it might be legal in the experimental, certified has a different and more stringent requirement. 

try not to confuse the two. 

[Cruiser]

7 hours ago, MikeOH said:

Hmm, seems to me that if an A&P inspects and determines the part to be airworthy, signs off on a 337 (if he thinks that's what it requires)...then it is no longer an unapproved part.

not necessarily. anyone can make mistakes. 

[cliffy]

2 hours ago, Jeph357 said:

Heres a good read. In my humble opinion, that would fall under the minor alteration category if you have an A&P to do it and sign the logbook then by all means have at it. If you really want to get crazy hook it up to the buss without cutting out the panel and check for EMI/RFI on the ground (not an exact flight representation but a start). Calculate the draw give it its circuit breaker maybe even a fuse....haha.. While your at it cutting out the panel make a blank so if it hurts an IA's feelings or a potential buyer when you choose to sell its an easy removal and not a hole in the panel. 

https://www.savvyaviation.com/wp-content/uploads/articles_eaa/EAA_2015-06_alterations.pdf

The INSTALLATION may very well be a Minor Alteration attested to by an A&P BUT the A&P MUST still determine that the part being installed is legal to install on certified airplanes. He can't just wave a magic wand and say it is so. The part itself has to qualify as being legal to install all on its own. 

Just like buying a new mag or a repaired fuel pump. The A&P must determine that it is legal to install. One way of doing that is the 8130  Airworthiness Release tag sent with most every article that gets overhauled or repaired. The A&P reviews that and knows that the part is legal to install.

The installation and the approved part are 2 different animals. 

Very good article BTW. 

[Cruiser]

42 minutes ago, Cruiser said:

not necessarily. anyone can make mistakes. 

I don't know the details but I just saw this on another forum and thought it might be appropriate to this thread.

 

"Apparently an individual at the FAA above the (or at least our) local FSDO level has decided that multiple aircraft which had all electric panels approved via 337 and installed must retain vacuum systems and that the previously issued 337’s were incorrectly issued, no fault of the shops and despite FAA policy statements which might be interpreted as supporting. I understand Beech and Cessna planes affected while certain Mooneys are OK since they have an SB or other method to allow approval for vacuum system removal."

[cliffy]

7 hours ago, MikeOH said:

Hmm, seems to me that if an A&P inspects and determines the part to be airworthy, signs off on a 337 (if he thinks that's what it requires)...then it is no longer an unapproved part.

Not quite so-   A 337 is used for Major Repairs and Alterations only. An A&P who installs the part signs off as the installing mechanic (after determining that the part was legal to install in the first place) THEN an A&P with an Inspection Authorization (IA) signs off that the the installation meets some kind of Approved Data for installation (part and the installation, may be the same individual), THEN it goes to the FAA for their review and approval. 

The mere fact that the A&P thinks it should be legal does not make it so. A&Ps can not make an independent evaluation on whether or not a part is legal to be installed on a certified airplane (nor can an IA). The part has to be an already approved part to be installed ( the A&P only verifies this), and it still must meet form, fit, and function for the intended installation to be legal. 

A 337 is NOT used to make an other wise non-certified part legal to install unless its part of a Field Approval and gets the FAA blessing. . Getting a Field Approval is an entirely different animal than just signing off a 337.

[cliffy]

5 minutes ago, Cruiser said:

I don't know the details but I just saw this on another forum and thought it might be appropriate to this thread.

 

"Apparently an individual at the FAA above the (or at least our) local FSDO level has decided that multiple aircraft which had all electric panels approved via 337 and installed must retain vacuum systems and that the previously issued 337’s were incorrectly issued, no fault of the shops and despite FAA policy statements which might be interpreted as supporting. I understand Beech and Cessna planes affected while certain Mooneys are OK since they have an SB or other method to allow approval for vacuum system removal."

And the plot thickens!

[Yetti]

10 minutes ago, cliffy said:

And the plot thickens!

Which is the problem with hard and fast outdated rules with whimsical interpretation by distributed authority.