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


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1 hour ago, A64Pilot said:

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

Wow, crazy someone would take on that liability. Nvm the fact that it’s a crummy move. 

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26 minutes ago, ragedracer1977 said:

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.

 

No others outside of the group were produced or sold. 
 

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I personally doubt the FAA has any interest in perusing this further. I think Mooney bitched to the FAA so they did what was required. I think Mooney did it to keep it from happening again. If someone pushes back, lawyers will get involved and the outcome may end up being worse than it is now.

At this point it is a disagreement about the regulation, not anybody intentionally trying to break it.

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35 minutes ago, N201MKTurbo said:

. I think Mooney bitched to the FAA so they did what was required. I think Mooney did it to keep it from happening again.

Highly doubt anyone at Mooney knew or cares.  What are there six people there?  

More than likely was somebody here or a pilot who heard about it.  Either way it doesn’t really matter. 

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1 hour ago, goodyFAB said:

Wow, crazy someone would take on that liability. Nvm the fact that it’s a crummy move. 

It’s not a lot of liability for someone to ask a shop capable of making a part for them to make a part for them. 
 

manufacturing and producing are different things. 
 

it’s not against the regs to have someone manufacture a part you produced all the data for based on an existing part. 

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1 hour ago, N201MKTurbo said:

I personally doubt the FAA has any interest in perusing this further. I think Mooney bitched to the FAA so they did what was required. I think Mooney did it to keep it from happening again. If someone pushes back, lawyers will get involved and the outcome may end up being worse than it is now.

At this point it is a disagreement about the regulation, not anybody intentionally trying to break it.

I wonder when McFarland is gonna get a notice.. I remember ordering a throttle cable from them. I had to provide them the length etc of my old cable so they could “produce” it.  The new one arrived in a bag with a manufacture date from before mine had even broken…

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28 minutes ago, chriscalandro said:

It’s not a lot of liability for someone to ask a shop capable of making a part for them to make a part for them. 
 

manufacturing and producing are different things. 
 

it’s not against the regs to have someone manufacture a part you produced all the data for based on an existing part. 

In the instance I commented on, your saying it’s not a lot of liability to copy someone else’s engineered spar cap and sell them without a pma ? 
yeah ok, let someone kill themself and a lawyer get ahold of that.

 

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40 minutes ago, M20F said:

Highly doubt anyone at Mooney knew or cares.  What are there six people there?  

More than likely was somebody here or a pilot who heard about it.  Either way it doesn’t really matter. 

Mooney issued the Special Letter 22-06 parroting the FAA document two days ago, so apparently they care enough to do that.    I don't know what the motivation is to duplicate an already-published FAA document from the day before, other than to put a stamp on it that they want to make sure people see it.    Usually it goes the other way.

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29 minutes ago, ragedracer1977 said:

I wonder when McFarland is gonna get a notice.. I remember ordering a throttle cable from them. I had to provide them the length etc of my old cable so they could “produce” it.  The new one arrived in a bag with a manufacture date from before mine had even broken…

Maybe they have. I notice McFarlane seems to be doing a lot more PMA parts nowadays.

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1 hour ago, N201MKTurbo said:

It is possible that there may be an AC or revision in the law to clarify the interpretation of the regulation.

Has anybody from this side written or talked to the FAA about this?

There have been a number of conversations between people from this side and the FAA, mostly just the MIDO making accusations and demands. 

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3 hours ago, goodyFAB said:

Wow, crazy someone would take on that liability. Nvm the fact that it’s a crummy move. 

See that’s just it, he wasn’t.

He bought the spar caps himself but fabricated the rest of the kit, but when he put the wings together he signed off signing off installation of CK-AG41, the Custom kit we had designed and tested to prove it was fail safe, if your interested I’ll give you a link that explains the problem and the kits etc.

https://thrushaircraft.com/support/technical-publications/Service Letters/sl-ag-110 WING SPAR STATUS UPDATE.pdf

So Thrush assumed the liability for parts they didn’t even make. He was counterfeiting parts.

Funny thing is the FAA FSDO inspector showed up at his place to investigate, he was told I can make any part I want to for my aircraft, show up here again and I’ll shoot you. FAA left and that was the end of it.

Later as he was renting a hangar from his county to run his shop I guess they locked him out for not paying rent, he broke in and trashed the place tore it up. He went to jail for that.

I don’t know what he’s doing now, I Retired out of the business.

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5 minutes ago, Skates97 said:

There have been a number of conversations between people from this side and the FAA, mostly just the MIDO making accusations and demands. 

Which MIDO?

 

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8 minutes ago, PT20J said:

Maybe they have. I notice McFarlane seems to be doing a lot more PMA parts nowadays.

I hope they still give the option to do OPP.    I got two control cables from them as OPP and one as a PMA part number, and the PMA one didn't fit nearly as well as the other two.   My preference would be to get them via the OPP process.    I suspect that'd continue since it's the same process that the experimental folks use.

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29 minutes ago, EricJ said:

Mooney issued the Special Letter 22-06 parroting the FAA document two days ago, so apparently they care enough to do that.    I don't know what the motivation is to duplicate an already-published FAA document from the day before, other than to put a stamp on it that they want to make sure people see it.    Usually it goes the other way.

They are the manufacturer they have to provide notice the same way they post SB’s, AD’s, etc.  

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8 hours 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 is not what happened. Saying so requires a number of incorrect assumptions.  
 

A more accurate statement would be that a group of owners organized to share the costs of measuring and making CAD drawings of the parts and then ordered and prepaid for their individual parts. Then and only then we’re parts produced for each individual. Nothing was sold “off the shelf”.  
 

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3 hours ago, ragedracer1977 said:

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.

 

That never happened as far as I know. We simply organized as group to streamline design and fabrication. Each participant received the parts they paid to have measured, CAD designed and fabricated and that was it. No one was selling manufactured parts, they were fabricated to order.

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I think as long as whoever made the complaint let’s it go, it’s over, no further action.

See someone made a complaint, FAA had to investigate, they find credence to the complaint, so they issue a letter, issue resolved.

Unless the complainant won’t let it go.

My opinion only of course

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59 minutes ago, Shadrach said:

A more accurate statement would be that a group of owners organized to share the costs of measuring and making CAD drawings of the parts and then ordered and prepaid for their individual parts. Then and only then we’re parts produced for each individual. Nothing was sold “off the shelf”.  
 

I don’t think that is an OPP though, an example would be the American Bonanza Society getting up a “group buy” for elevator skins and since set up and machining costs for one set would be insane, but amortized out over several may be affordable.

If the Society owned all the aircraft serial production is justifiable in my opinion

My belief is each individual owner has to participate. Can they all participate in the same way? Since the FAA doesn’t specify, then I think they can.

Its all legalities and semantics, I don’t think the quality or safety of the part is in question is it?

For instance some Airline owns a fleet of orphaned aircraft and on many the lever that holds the food carts in the galley is broken, then I think the airline can have a whole bunch of levers made as they are the owner of all the aircraft, I even think they can have a bunch made and put them in stock to replace them as they break. I actually think this is where OPP came from, I don’t think it was meant for us.

So think of it another way, a group of people decide to split the costs of making drawings or whatever, that’s fine, I think. Each individual can in my opinion contact the machinist and provide a copy of the drawing and say make me one of these, or each individual could supply a chunk of 6061-T6 if that’s what it’s made of and say make me one of those things you made for John and be legal. 

But they have to do it individually is I think the key. So does 20 individual orders any different really than one order for 20? In the FAA’s eyes I think it is.

I spoke to the guy that owns Oregon Aero one time at length, he flew his PC-12 to the factory to deliver prototype seat cushions and tour the plant. He told me about when he first started he was visited at Home by two FBI looking individuals, wearing ID cards around his neck, they pretty much started reading him the riot act telling him if he didn’t immediately stop they would take him to Federal court and imprison him, said they scared the Hell out of him.

But eventually he figured out that they didn’t care that he was fixing aircraft seats, what they were upset about was that he was advertising that he could overhaul your seat, when in fact he could only repair a seat.

Once he figured out that their concern was merely semantics he apologized and assured them he would change his advertising immediately.

FAA had no problem with what he was doing, but had serious issues with the word he used to describe his service.

Seems this is a question for AOPA legal actually or some other aviation Lawyer really. But I think the letter from the FAA lawyer spells it out pretty clearly. In it I only saw Owner not groups like type clubs etc. 

But that’s my opinion, which carrie’s no more weight than anyone else’s.

But if I had one of those parts in my aircraft, I’d make sure I had the correct entries to support it, but that should be done anyway.

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1 hour ago, A64Pilot said:

I think as long as whoever made the complaint let’s it go, it’s over, no further action.

See someone made a complaint, FAA had to investigate, they find credence to the complaint, so they issue a letter, issue resolved.

Unless the complainant won’t let it go.

My opinion only of course

Sort of.
The problem is that the FAA has released a document stating that these parts do not meet OPP requirements.  
My IA signed off on the installation based on the fact that I handed him a part that I paid to have fabricated. The company that fabricated the part referenced the CAD drawings and specs in the paper work that was supplied to me along with my finished part. My IA was happy as was I.

There is now a document stating that these parts are not OPP. Since they are not PMA (never claimed to be). They are in airworthiness limbo. The FAA even says “airworthiness to be determined” in the letter. Airworthiness was determined before installation. 

 

 

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32 minutes ago, A64Pilot said:

I don’t think that is an OPP though, an example would be the American Bonanza Society getting up a “group buy” for elevator skins and since set up and machining costs for one set would be insane, but amortized out over several may be affordable.

If the Society owned the all the aircraft perhaps serial production is justifiable.

My belief is each individual owner has to participate. Can they all participate in the same way? Since the FAA doesn’t specify, then I think they can.

Its all legalities and semantics, I don’t think the quality or safety of the part is in question is it?

For instance some Airline owns a fleet of orphaned aircraft and on many the lever that holds the food carts in the galley is broken, then I think the airline can have a whole bunch of levers made as they are the owner of all the aircraft, I even think they can have a bunch made and put them in stock to replace them as they break. I actually think this is where OPP came from.

So think of it another way, a group of people decide to split the costs of making drawings or whatever, that’s fine, I think. Each individual can in my opinion contact the machinist and provide a copy of the drawing and say make me one of these, or each individual could supply a chunk of 6061-T6 if that’s what it’s made of and say make me one of those things you made for John and be legal. 

But they have to do it individually is I think key

Seems this is a question for AOPA legal actually or some other aviation Lawyer really. But I think the letter from the FAA lawyer spells it out pretty clearly. In it I only saw Owner not groups like type clubs etc. 

the reality is that this is an issue of semantics. If it’s the job of a federal agency to use semantics to make it more difficult for owners to support aircraft that have been orphaned by the industry then so be it but I think that’s a lousy use of resources.

How ridiculous that we are in a place that these parts would be considered perfectly airworthy if we all got together to have the drawings made but then used 40 different machine shops. What if a few of us lived in the same town and went to the same machine shop? Does that cause a problem? Would I have to instruct the machine shop owner to make sure that they fabricated something else in between our orders to ensure that the CNC machine was set up separately for each fabrication so as to not show any hint of collaboration? 

This isn’t about the quality of the part. This isn’t about safety. So the question is what is it really about?

The reason why the FAA has the details of where and how the parts were fabricated and who was involved in the process is because the fabrication paperwork on the OPP was very thorough.

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4 minutes ago, Shadrach said:

This isn’t about the quality of the part. This isn’t about safety. So the question is what is it really about?

Sometimes it's about somebody's personal career advancement in an organization.   Sometimes it's just somebody being vindictive.   Sometimes it's somebody who thought they were doing the right thing but didn't have all the info.    I suspect we might never really know.

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