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I’m going to go ahead and put this BS here again


chriscalandro
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A company whose existence is purely cosmetic seemingly has an issue with owner produced parts that meet or exceed the original specifications. 
 

when said company failed to maintain the ability to support their products owners went the right to repair/ owner produced route and now seemingly a company desperately in need of any sort of income has a problem with it. 

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6 minutes ago, chriscalandro said:

A company whose existence is purely cosmetic seemingly has an issue with owner produced parts that meet or exceed the original specifications. 
 

when said company failed to maintain the ability to support their products owners went the right to repair/ owner produced route and now seemingly a company desperately in need of any sort of income has a problem with it. 

Got it. Thank you.

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14 hours ago, chriscalandro said:

Mooney doesn’t make the parts I need, and according to the regulations I am allowed to produce a part that meets or exceeds the original. 
 

 

You are, however the FAA is clearly stating that these particular items are not compliant owner produced parts. 
 
https://www.faa.gov/sites/faa.gov/files/upn_2022-S20210727018.pdf

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15 hours ago, chriscalandro said:

A company whose existence is purely cosmetic seemingly has an issue with owner produced parts that meet or exceed the original specifications. 
 

when said company failed to maintain the ability to support their products owners went the right to repair/ owner produced route and now seemingly a company desperately in need of any sort of income has a problem with it. 

I'm confused according to the faa the company produced parts to sell to owners as "owner approved parts"

how would it make sense that the company opened this can of worms?

 

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31 minutes ago, Niko182 said:

I thought owner produced parts allows you to make a part for your airplane. Not a part for your airplane and then sell that part for profit to other owners. 

That's correct, but I don't think any owners that had parts made sold them.   The FAA doc isn't citing any owners.

An Owner Produced Part doesn't have to actually be made by the owner, as long as it has at least one of the attributes described in the FAA guidance (e.g., inspection, quality control, etc.).    So it is expected that an owner may pay someone to do the actual fabrication, and this is allowed in the FAA guidance.    For example, before McFarlane started producing Mooney engine control cables to Mooney part numbers, it was common to fill out the McFarlane spec form or just send them the old cable and pay them to make a new one as an OPP.   

If many people independently ask the same place to make the same part (as I'm sure they did to McFarlane), it shouldn't matter, imho, but I've long had the sense that there is diversity of opinion about this within the FAA.    Just like some people have had bad experiences getting grounded in one FAA region for a modification approved in another, different people there interpret things differently.

Without knowing any more than what's come out here and elsewhere and in the documents so far I suspect this is more of an FAA issue than a Mooney owner or a part fabricator issue.   Remember our friend at Gee-Bee products had a very long engagement with the FAA about his part production and ultimately came back doing the same thing he'd been doing all along.   The FAA doesn't always get this right, and there's definitely been more than one way for them to interpret their own rules.

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39 minutes ago, Niko182 said:

I thought owner produced parts allows you to make a part for your airplane. Not a part for your airplane and then sell that part for profit to other owners. 

What Eric said. 
 

If 15 people with identical part numbers do the work to measure and recreate a part, those 15 people should come out with identical parts. 
 

When 15 people all need the same identical part and as a group work together to recreate that part, it’s still an owner produced part. 
 

when the owner produced part requires a process like cnc, it makes sense for those owners to band together and use the same machinist to lower costs. 
 

Either that or you had better also ground all those airplanes with those Lasar 6pack replacement panels also being sold as owner produced parts at a hefty profit as well.

Edited by chriscalandro
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People who actually manufacture an OPP are certainly allowed to make a profit doing so just as people who install an OPP are allowed to make money from doing so.

While it may seem silly to some, but the Owner MUST be the manufacturer, I’m sure that came about as a liability concern, plus a way the FAA could allow an non PMA or TSO airworthy part to exist.

I’m pretty sure the rules were written for Commercial operators as a way they could keep their aircraft in service and we benefitted from it, but can’t prove that and it doesn’t matter anyway.

They in my opinion set out VERY lenient definitions of what instances the owner could become the manufacturer, pretty much all they have to do is participate in the manufacture of the part, this can be as simple as handing a machinist a piece of metal and say make it out of this. But ordering and paying for a part isn’t participating.

However there are logbook entries also that are required to be made, and I suspicion that some don’t want to make those entries on the basis of it could reduce resale value maybe.

But skilled people with the equipment and training are allowed to do the work in making an OPP, but the owner must accept the liability and they do so by becoming the manufacturer and they become that by participating in the manufacture of the part.

A&P’s and IA’s have been making parts since time began, taxi into a post and one will sit down and make ribs and cut a skin doing the repair, the line has always been vague, left to the interpretation of the repairer as to how far they could go.

OPP has no limits that I can see, if I had some kind of antique engine from what it looks like I could have a new crankshaft made.

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21 minutes ago, chriscalandro said:

When 15 people all need the same identical part and as a group work together to recreate that part, it’s still an owner produced part. 

No it’s not, unless each of those 15 people did one of the things to participate IAW the FAA. For example in my opinion if each of those 15 people sent the metal the part was made from, then it’s an OPP, or any of the other ways they could participate, but one person doing all the research and work and a group buy set up doesn’t cover it.

On edit I don’t think they each have to accomplish a different task, an OPP is not a group effort, so 100 Owners could in my opinion accomplish the same task, apparently you can order throttle cables by specifying measurements or something that are OPP.

In that instance then the one person becomes the manufacturer not the 15, and then the one person needs a PMA.

So if 15 people all want the same part, then each one of them has to participate in its manufacture, in my opinion that could be as simple as ordering the raw material and having it shipped to the machinist contracted to do the machining.

My opinion is worth what it costs, but I believe if you at least have some kind of defense your better off, and along thise lines if you have an OPP on your aircraft be sure the logbook reflects that

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So in my opinion if I wanted seat rollers for instance, all I would need to do is contact someone who knows how to make them and have the plastic drop shipped to them from Mcmaster Carr or whoever sells the raw material.

I agree many people can exceed the factories quality, I’ve seen seat rollers built to internal engine component tolerances, where I would likely have cut them with a band saw

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I paid for the analysis of the metal of my blocks, paid to have a CNC drawing, chose the material to be used -- which was FAA approved, evaluated the CNC results and had it compared to my original. I'd say I complied with the spirit of OPP. I happened to work with a resource who had connections to get this done. Others who participated also paid for the drawing and analysis of the block and chose the new block's material.

That was for my old B.

AS a note, I have Lasars blocks in my C...

-Don

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1 hour ago, goodyFAB said:

maybe a little clarification. 

how does this escalate to the FAA ? 

 

There's a formal methodology via Form 8120-11, Suspected Unapproved Parts Report, which allows people to report suspected counterfeit parts.   This has been important on commercial carriers where there has been a history of small industries selling counterfeit approved parts that have created safety issues.   It is possible it was reported to the FAA by somebody in this manner.

https://www.faa.gov/documentLibrary/media/Form/FAA_Form_8120-11.pdf

 

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47 minutes ago, goodyFAB said:

maybe a little clarification. 

how does this escalate to the FAA ? 

 

I would assume by filing an SUP complaint, SUP is Suspected Unapproved Parts, used to be you could call them in, now a form has to be filled out.

In other words, someone most likely made a complaint, I can think of a couple possible scenarios that could trip filing an SUP complaint.

Been years ago, but I filed one when I found out an individual was making parts that had an AD applied to them, long story short a few main spar caps had failed in flight, of course killing the pilot. After investigation the FAA issued an AD that required the main spar caps to be replaced at a set hour interval, we did a lot of Engineering and developed a kit to both replace the main spar cap but also to strengthen the part of the main spar that was breaking so that if a main spar cap were to fail the wing wouldn’t come off.

An individual bought a kit and started having the pieces of the kit manufactured as he was replacing the spar caps as a business. The main spar cap was too difficult to make or I’m sure he would have had them made too.

So I turned in an SUP

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n. 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.
 

this is from the AC on approving parts. Since everyone who got one of these parts participated in providing design data and QC at a minimum, I can’t see how they don’t meet the standard.  
 

Now, it’s possible the company offered these for sale to others who didn’t participate at a later date, and that’s where the problem lies.

 

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