Landing gear rubber discs/OPP

[Alan Fox]

42 minutes ago, EricJ said:

PMA has zero to do with parts produced outside of the authorized processes, such as the cables McFarlane provides under the OPP process.    McFarlane very carefully points this out in a disclaimer on the part spec when getting an OPP part that the part is "not FAA approved" and the purchaser's signature certifies "that if this part is to be installed on a type-certificated aircraft it will be installed in full compliance with one of the exceptions listed in 14 CFR 21.9(a)."

When you get a cable from McFarlane with a Mooney part number you do not get that disclaimer, you get an order that says "McFarlane Aviation Products FAA-PMA Replacement Aircraft Parts", an invoice with a Certificate of Conformance citing quality clauses assuring approval, and a tag on the part that says "FAA-PMA".  

They are very different.    An FAA-PMA does not apply to all parts produced by a manufacturer with a PMA authorization, and it is important to understand the distinction.   A part sourced from McFarlane under OPP has the same status as one properly sourced from anywhere else under the OPP processes.

 

Back to the original posters question about the South African Shock Discs , They are not Legal , as they are 1) offered for sale 2) the owner is not part of the design or manufacture process ....   They are NOT owner produced parts ..

 

[EricJ]

11 minutes ago, Alan Fox said:

Back to the original posters question about the South African Shock Discs , They are not Legal , as they are 1) offered for sale 2) the owner is not part of the design or manufacture process ....   They are NOT owner produced parts ..

McFarlane also offers parts for sale per order, which appears to be the same with these.     This manufacturer has an order process and form reasonably similar to the process McFarlane uses to produce the parts that many of us have used under OPP.

Having a part for sale doesn't necessarily exclude it from use under OPP.   The producer, i.e., the aircraft owner, can't sell it, but somebody else may be selling it and the owner qualifies it for use under the various approved OPP processes.

"Participating" in the production isn't well defined, and sometimes people take it to mean the owner has to manufacture the part, which the regs don't say and the FAA has provided guidance that it isn't necessary.

 

    

[Alan Fox]

4 hours ago, EricJ said:

McFarlane also offers parts for sale per order, which appears to be the same with these.     This manufacturer has an order process and form reasonably similar to the process McFarlane uses to produce the parts that many of us have used under OPP.

Having a part for sale doesn't necessarily exclude it from use under OPP.   The producer, i.e., the aircraft owner, can't sell it, but somebody else may be selling it and the owner qualifies it for use under the various approved OPP processes.

"Participating" in the production isn't well defined, and sometimes people take it to mean the owner has to manufacture the part, which the regs don't say and the FAA has provided guidance that it isn't necessary.

 

    

Selling for use on an aircraft , disqualifies it , Look at the nightmare GeeBee is going through ,   Also read that link from the FAA I posted ...  What people take it to mean , means nothing , Its what the FAA takes it to mean....