Any legal reason a USB charger has to be certified?

[Andy95W]

I agree with Cliffy's post, above, and will add just one caveat-  

If an A&P/IA does get an STC or a Field Approval to install El Cheapo USB charger into an airplane, then that USB charger is now an approved part. But as Cliffy said, it would have to be a 337 that a FSDO or DER has signed off on to validate the component, and installation, as approved data.

But the first question that the FSDO or DER would ask is "why not just install the Garmin for $349?"

[tigers2007]

Wow this was a tough thread to scroll through trying to find a CB charger that doesn’t have RFI and is under $100. We’ve discussed this specific topic here before. I’m just a (probationary) CB trying to find a panel mounted USB charger. The Appareo one in my M20D works great but the installed price was ridiculous. I bought a huge Scoshe external from Sporty’s years ago and it works great ( no RFI ).
The reviews at Spruce claim this $26 one has no RFI and they say it has a built in filter. https://www.aircraftspruce.com/catalog/elpages/easmartdualusb.php

[tmo]

1 hour ago, cliffy said:

One way of doing that is the 8130  Airworthiness Release tag

Off topic and a thread drift, but the good folks at JPI charge $100 to issue one...

[Yetti]

10 hours 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. 

And so the plot thickens here using your definition.    A wheelen PAR 46 LED bulb for tractors sold off Amazon is certified to SAE J1113-42 Class 5 EMI.  So now we have a regulated body and nationally identified standards.   Good go?

https://www.amazon.com/Whelen-PAR-46-Super-LED-Steady-8-DEGREE/dp/B009LQG64S/ref=sr_1_2?keywords=whelen+led+par&qid=1583421733&sr=8-2

 

 

[jaylw314]

15 hours ago, N201MKTurbo said:

There are TSOs for the landing light. Besides, it was on the original parts list when certified. There are specific regs concerning upholstery.

FWIW, landing lights have no TSO.  They have no required specs, so there would be no standard to compare them to

11 hours ago, cliffy said:

Yetti - As has been said many times over the years right here   Aviation light bulbs come under "STANDARD PARTS"  as there is an SAE paper that describe exactly how to make any aviation light bulb. NO PMA is required for light bulbs just like no PMA is required for AN bolts because they are made to a national standard so anyone can make an exact duplicate of the article. 

Other bulbs, like strobes and cabin lights, wouldn't, just like landing lights.  However, navigation lights DO have required specs and a TSO ( and I don't think would be considered a standard part). 

A PMA is technically required for a manufacturer to use the word "aviation" in the part description in their sales catalog.  In theory that is the only meaning of PMA.

[Skates97]

10 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

 

10 hours 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 

Yes, I believe I stated that in my post. I'm not advocating putting in the unapproved parts. I'm talking about the arguments that have been made in this and other threads about it being a certified plane and therefore needing certified equipment to be safe.

2 hours ago, Cruiser said:

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. 

Not confused about the two, I thought I was clear about that when I posted. In fact the last few sentences that are underlined I believe already state the two items you are listing.

[RobertGary1]

How is adding a USB charger a major alteration? Just a quick minor mod sign off from an A&P would seem to do it. No 337, no STC, no TSO, no PMA.  All legal. Whether the A&P would feel comfortable using his certificate to do that is a different issue.

 

-Robert

[ragedracer1977]

1 hour ago, Yetti said:

And so the plot thickens here using your definition.    A wheelen PAR 46 LED bulb for tractors sold off Amazon is certified to SAE J1113-42 Class 5 EMI.  So now we have a regulated body and nationally identified standards.   Good go?

https://www.amazon.com/Whelen-PAR-46-Super-LED-Steady-8-DEGREE/dp/B009LQG64S/ref=sr_1_2?keywords=whelen+led+par&qid=1583421733&sr=8-2

 

 

You got there before I did.  I've been trying to steer it that way lol.  There's a LOT of parts that meet the definitions set forth in that AC.  

[Jerry 5TJ]

A log entry will cover many situations. 

My all-time favorite was found in the airframe log of a Cessna T210. It read in its entirety, and I quote, “replaced left wing with serviceable unit.”   

[RLCarter]

26 minutes ago, Jerry 5TJ said:

“replaced left wing with serviceable unit.”   

At least it’s in the logs.....

[Michel02]

some  usb charger  from no were at $5    induce noise in radio com , some dont ,,,,,

[Stephen]

14 hours ago, ragedracer1977 said:

 

 

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

Just as long as you are not acutely obtuse. 

[RobertGary1]

3 hours ago, Jerry 5TJ said:

A log entry will cover many situations. 

My all-time favorite was found in the airframe log of a Cessna T210. It read in its entirety, and I quote, “replaced left wing with serviceable unit.”   

Should have said “ as a minor mod”.

 

-Robert 

[jlunseth]

The US Supreme Court decided a case 36 years ago called Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc.  It resulted in what lawyers call "Chevron deference."  Chevron deference means that courts defer to a Federal agency’s answer or interpretation of its own regulations, where the agency’s answer is not unreasonable, and Congress has not spoken directly to the precise issue.  That is a long hand, legal way of saying that what the agency says, goes (in this case the FAA). It is not important whether or not there is an agency rule or regulation that specifically prohibits an act or allows an act, if there are regulations that the agency can, in its own wisdom, construe as prohibiting the act.  So if there is a regulation, for example, that requires an aircraft to be certified (which there is), and an aircraft is so certified at the time of manufacture, then the agency can construe those regulations to require that aircraft to stay in exactly that condition to remain airworthy, unless the agency's regulations for a modification or substitution (STC, TSO, PMA, 337) are followed.  Again, it does not matter whether there is a statute or regulation that says so, what matters is the agency's interpretation of its own rules, and on that subject the agency is the final authority. 

On 337's, it does not ineluctably follow that because someone added an "X" component to their panel under a 337 from one FSDO, that anyone can then just add the same component without getting a 337 of their own.  There may be more to the original 337 than that, or the component may have been added to one model of aircraft where the FSDO was satisfied the addition was airworthy, but they would not be satisfied if the same thing was added to another model.  Or another FSDO may have a different view of the addition.

It is not simple, and one cannot just look at regs and say based on the express language of the regs that something is or is not prohibited.  There are lots of FAA interpretations of regs that would not pass muster based on the language of the reg as used in regular life, or as used in the courtroom, but that nevertheless wind up as the successful basis of an enforcement proceeding against a pilot or operator.

It is definitely not a case of "Better to ask forgiveness than permission," because the FAA does not have to agree with you or forgive. 

[0TreeLemur]

A spectrum analyzer allows measurement of noise level associated with different chargers.   A circuit breaker protects against over-current situations.    If it isn't installed in the panel, it is not permanent.   If you don't have access to a spectrum analyzer or if you want to install it in the panel, then buy one of the PMA units.  Either way, problem solved.  All it takes is money.

[0TreeLemur]

14 minutes ago, Stephen said:

Just as long as you are not acutely obtuse. 

One of the funniest things I've read on MS in a looooong time!

[Igor_U]

1 hour ago, RobertGary1 said:

Should have said “ as a minor mod”.

 

-Robert 

Some would argue it's not a mod. Just a part swap, right?

[Skates97]

1 hour ago, 0TreeLemur said:

All it takes is money.

And enough of it can solve all of your aircraft related issues.

[0TreeLemur]

If money can't buy happiness, how do you explain airplanes?

3 minutes ago, Skates97 said:

And enough of it can solve all of your aircraft related issues.

 

[RobertGary1]

2 hours ago, jlunseth said:

The US Supreme Court decided a case 36 years ago called Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc.  It resulted in what lawyers call "Chevron deference."  Chevron deference means that courts defer to a Federal agency’s answer or interpretation of its own regulations,

Not as good as the Chewbacca defense. 

"Why would a Wookiee, an 8-foot-tall Wookiee, want to live on Endor, with a bunch of 2-foot-tall Ewoks? That does not make sense! But more important, you have to ask yourself: What does this have to do with this case? Nothing. Ladies and gentlemen, it has nothing to do with this case! It does not make sense! Look at me. I'm a lawyer defending a major record company, and I'm talkin' about Chewbacca! Does that make sense? Ladies and gentlemen, I am not making any sense! None of this makes sense! And so you have to remember, when you're in that jury room deliberatin' and conjugatin' the Emancipation Proclamation, does it make sense? No! Ladies and gentlemen of this supposed jury, it does not make sense! If Chewbacca lives on Endor, you must acquit! The defense rests^["

 

^-Robert

[Yetti]

Just now, RobertGary1 said:

Not as good as the Chewbacca defense. 

"Why would a Wookiee, an 8-foot-tall Wookiee, want to live on Endor, with a bunch of 2-foot-tall Ewoks? That does not make sense! But more important, you have to ask yourself: What does this have to do with this case? Nothing. Ladies and gentlemen, it has nothing to do with this case! It does not make sense! Look at me. I'm a lawyer defending a major record company, and I'm talkin' about Chewbacca! Does that make sense? Ladies and gentlemen, I am not making any sense! None of this makes sense! And so you have to remember, when you're in that jury room deliberatin' and conjugatin' the Emancipation Proclamation, does it make sense? No! Ladies and gentlemen of this supposed jury, it does not make sense! If Chewbacca lives on Endor, you must acquit! The defense rests^["

 

^-Robert

Was it over when the Germans bombed Perl Harbor? NO!  I am not just going to sit here and let you degrade America.

My IA solves this by just referring the fancy lectrical stuff "You might just want to go talk to an Avionics shop"  

[Cruiser]

as my wise mechanic once said, "if this thing fails on you at 10,000 feet, you would have paid any amount of money to replace" 

[jlunseth]

Hey, I ain’t sayin’ its right or even that it is good.  Just that it is what it is.  The S. Ct. is reportedly not too happy with the consequences of its own decision either, and may revisit.  Wouldn’t that be great.  Agencies would not be able to just make things up. On their own.

[EricJ]

3 hours ago, 0TreeLemur said:

A spectrum analyzer allows measurement of noise level associated with different chargers.   A circuit breaker protects against over-current situations.    If it isn't installed in the panel, it is not permanent.   If you don't have access to a spectrum analyzer or if you want to install it in the panel, then buy one of the PMA units.  Either way, problem solved.  All it takes is money.

Having done said spectrum analyzer measurements in the past, I wouldn't assume for a second that a PMA or TSO stamp or an expensive price tag implies that it is any more electrically quiet (i.e., minimizes RFI) than a cheapie 12V lighter-socket plug-in unit or any of the inexpensive units linked from aircraftspruce or anywhere else.    Expensive doesn't imply any kind of quality.

As I alluded previously, recently we're finding some very expensive, heavily TSO-PMA screened equipment that is generating a lot of electrical interference (RFI).   I'm not sure why people assume that the expensive units, or name brand units, or PMA or TSO units are any quieter than any others.   The only way to know is to test them, and even when I was doing testing the results varied across units in a batch, and varied across the input voltage to the device as well as the load current on the device.

The TSO relevant to the chargers (DC-DC converter) is TSO-C71, which does not have a meaningful RFI limitation, i.e., it has no guarantee or specification of being any better than a cheap piece of crap plugged into a 12V lighter socket.    Here is the relevant paragraph from TSO-C71:

"The emission of radio frequency energy at discreet frequencies within the range of 90 kc to 1500 Mc shall not exceed 200 microvolts between any cable terminal to ground.

Note: It is recognized that the radio frequency emissions having a level considerably less than the maximum permitted by the above standard are capable off interfering with the operation of other electronic equipment in an aircraft installation. It is also recognized that the method of reducing the level of emission of radio frequency energy to much lower values are known. However, at the present state of the art, large and expensive filters are often required in addition to the exercise of care in the mechanical and electrical design of equipment. The end result is often a compromise between what is desired and cost.

In view of the above, the emission standards were set at a level which can be met by the exercise of reasonable care in design and yet effect the reduction in the present overall interference problem. Lower emission levels are desirable and it is, therefore, recommended that the equipment manufacturers make a determined effort to reduce the level of emission from electronic equipment, to the lowest practicable value below that specified above."

In other words, in my interpretation, "it might cost a lot and be difficult to fully filter the output, so we're making a mediocre spec and just do the best you can."   The actual technical spec here is measured between the cable terminals and ground, and isn't even a radiated specification.  There is no limit specified on radiated energy. 

So I don't know what one gets for those higher price tags on the expensive units, and I sure wouldn't assume that it's quieter RFI.   The testing I did previously showed a super-cheapie (spiff giveaway) plug-in unit was about as quiet as could be measured to make no difference, so even an expensive unit wouldn't be much better or potentially even measurably better.   

Edited March 5, 2020 by EricJ

[Yooper Rocketman]

Four pages on whether you can install a USB port in a certified airplane that doesn't have the FAA's blessing?  And you wonder why I built my own!!!

@Skates97 had a very valid point.  One of the top avionics /panel builders in the country has a USB port in EVERY panel they sell.  I can assure you it's not TSO or PMA approved based on what it cost me.  I suspect nearly every new home built plane has a non-TSO'ed USB port and I have yet to read about one issue with them.  I got so sick of ridiculous regulations and restrictions, I saw the path to satisfaction in the Experimental world.  For a significant amount of time now Van's RV series home built's (yes, just one brand of home built airplane) has certified more new planes annually than the entire GA Certified Fleet COMBINED.  Now, amazingly, some of the "Experimental" Avionics are being approved for "Certified" use.  I did most my own work on all of my planes, under the supervision of my best friend (and A&P).  He struggled with the antiquity of the FAA regs, and how ridiculously slow change came.  He thought he died and went to heaven working on my Lancair with me.  Common sense was permitted!  He went to his grave (recently) with his proudest accomplishment (aviation wise) being his participation in my project.

And the comments to ask your FSDO ........ seriously???  I'm close to a ton of A&P's / IA's on my field AND in Florida.  Getting the same answer from FSDO's across the country is a joke.  They've even complained about inconsistencies within a specific FSDO.  A retired friend of my, former DOM for a significant FBO in the Midwest, spent hours during my visit in January telling me about these very issues (inconsistencies) as he is restoring an old rag wing and needing approvals for upgrades (and how he's found a way to get around those without a clue, by going farther up the chain).

The final straw ....... since I still deal with our wonderful certified world as chair of the maintenance committee for our mercy flight org with two planes,  is how many times I am cited incorrect regulations and requirements from our certified professionals.  I feel bad for those that DON"T know the regs, as you will clearly pay more in a lot of cases as you are told what has to be done when the regs don't support it.  Don't get me wrong, there are a lot of good mechanics and they are pretty easy to figure out once you work with them for a while.  Sometimes the issue I see is the foggy line these guys develop when they deal with commercial ops AND Part 91. 

Tom