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


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1 hour ago, EricJ said:

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.

I believe so. My IA recently had them make a throttle cable for a Musketeer. They didn't have any drawings and he had to send them the cable and then they made drawings and he had to approve them. Then they made the part. Beech didn't have stock and wanted $2,000 to make one.

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2 hours ago, EricJ said:

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.

What part of the OPP rules is McFarlane complying with? I know plenty of vintage Mooney owners who’ve called them up and ordered a cable and then installed it via OPP. What did the owner do to comply with the rules of OPP in this case? They didn’t! Are the rules being applied the same to everyone? The answer is no. 

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Just now, Sabremech said:

What part of the OPP rules is McFarlane complying with? I know plenty of vintage Mooney owners who’ve called them up and ordered a cable and then installed it via OPP. What did the owner do to comply with the rules of OPP in this case? They didn’t! Are the rules being applied the same to everyone? The answer is no. 

It's up to the owner to assure proper participation in the OPP process, not the fabricator, but McFarlane seems to know the process and facilitates it reasonably well.   They work from a drawing that needs the critical dimensions filled in, so you can either provide the design data by filling in the parameters in the drawing, or sending them a part to duplicate, and McFarlane fills them in and has you verify it.   Either fits the requirement to provide design data as described by the FAA and detailed in the Byrne (FAA legal opinion) memorandum on OPP.   Verifying the design data can also be seen as providing supervision, which is another one of the possible requirements.

If you check the dimensions when you receive the article to verify that they are correct, that is also a supervision step to facilitate qualification as an OPP part.
 

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13 minutes ago, Sabremech said:

What part of the OPP rules is McFarlane complying with? I know plenty of vintage Mooney owners who’ve called them up and ordered a cable and then installed it via OPP. What did the owner do to comply with the rules of OPP in this case? They didn’t! Are the rules being applied the same to everyone? The answer is no. 

No one has complained about McFarlane is I think your answer.

The FAA isn’t like the cops, they really don’t show up for unannounced inspections and or watch ADSB tracks to violate people etc. Except when it’s either so obvious they just can’t ignore it, or this is key, if someone makes a complaint they will investigate it, apparently they have to, it’s in some kind of rule they have.

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1 hour ago, Shadrach said:

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. 

 

 

They did infer that they don’t meet OPP, but as the whole thing was done, in my opinion it meets both the letter and spirit of the law.  They were never offered for sale to individual owners.  They were ordered by owners, to a spec provided by the owner.  

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17 minutes ago, EricJ said:

It's up to the owner to assure proper participation in the OPP process, not the fabricator, but McFarlane seems to know the process and facilitates it reasonably well.   They work from a drawing that needs the critical dimensions filled in, so you can either provide the design data by filling in the parameters in the drawing, or sending them a part to duplicate, and McFarlane fills them in and has you verify it.   Either fits the requirement to provide design data as described by the FAA and detailed in the Byrne (FAA legal opinion) memorandum on OPP.   Verifying the design data can also be seen as providing supervision, which is another one of the possible requirements.

If you check the dimensions when you receive the article to verify that they are correct, that is also a supervision step to facilitate qualification as an OPP part.
 


I had to laugh when I read this. No offense to you and your thought process as I agree with it. As things are currently being applied, McFarlane should be receiving a letter as well. I’ll leave it at that for now. 

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22 minutes ago, ragedracer1977 said:

They did infer that they don’t meet OPP, but as the whole thing was done, in my opinion it meets both the letter and spirit of the law.  They were never offered for sale to individual owners.  They were ordered by owners, to a spec provided by the owner.  

They didn’t infer anything. They stated clearly “The production of these parts does not meet the FAA requirements for “Owner-Produced Parts.”

From the statement above, I am inferring that the parts are in limbo. We understood they were not PMA pars at the outset. Why PMA status is such a large focus of a notification regarding OPP parts is not clear.  What is even less clear is how/why the FAA has determined OPP ineligibility. They simply made a blanket statement with no qualification. The statement below seems to indicate that eligibility for airworthiness is yet to be determined.
“the FAA recommends that they be quarantined to prevent installation or use until a determination can be made regarding their eligibility for installation, or replaced with FAA-approved parts.”

It’s a goat rope in my opinion.

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43 minutes ago, A64Pilot said:

No one has complained about McFarlane is I think your answer.

The FAA isn’t like the cops, they really don’t show up for unannounced inspections and or watch ADSB tracks to violate people etc. Except when it’s either so obvious they just can’t ignore it, or this is key, if someone makes a complaint they will investigate it, apparently they have to, it’s in some kind of rule they have.

 investigation is one thing.  Issuing documents with unqualified statements presented as a final ruling is quite another. 

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38 minutes ago, Shadrach said:

They didn’t infer anything. They stated clearly “The production of these parts does not meet the FAA requirements for “Owner-Produced Parts.”

From the statement above, I am inferring that the parts are in limbo. We understood they were not PMA pars at the outset. Why PMA status is such a large focus of a notification regarding OPP parts is not clear.  What is even less clear is how/why the FAA has determined OPP ineligibility. They simply made a blanket statement with no qualification. The statement below seems to indicate that eligibility for airworthiness is yet to be determined.
“the FAA recommends that they be quarantined to prevent installation or use until a determination can be made regarding their eligibility for installation, or replaced with FAA-approved parts.”

It’s a goat rope in my opinion.

Infer was the wrong word.  What I meant was “incorrectly state”.  Knowing exactly how the process went, I can’t understand how it could be done any better to meet the documented method of OPP.  I wonder if they know how it actually went.  The only thing the owners didn’t do was press start on the machine or supply the raw aluminum.

this whole thing meets OPP a whole lot closer than ordering a pre-fab cable from a vendor…

Also, as I understand it, it’s the owner that determines the eligibility to install and the mechanic that confirms and signs it off.  So hasn’t the eligibility been determined for those already installed and logged as OPP?

 

I do not have any of these on any airplane I own, but I do have parts on my plane that have a letter just like this floating around.  No one, including the FAA, has required removing them 

Edited by ragedracer1977
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7 minutes ago, Shadrach said:

 investigation is one thing.  Issuing documents with unqualified statements presented as a final ruling is quite another. 

From the beginning I’ve had discussions with people here about OPP.

Everybody argued with me that the shock disks made overseas were OPP parts because he would email you a spec sheet for you to sign fulfilled the OPP requirement, when if you read the FAA definition it clearly does not. Being supplied specifications for a part for you to sign clearly does not meet OPP.

The Owner has to provide specs, signing a sheet isn’t supplying specs.

It’s so easy and perfectly clear to meet OPP, there just isn’t a good reason not to. 

Easiest way to do it in a case like this from what I see is you supply the material, just drop shipping the material seems to meet the requirement.

Or I believe each individual could have ordered the part and each sent the identical drawing.

I don’t believe this will go anywhere most likely, I hope the FAA letter is a wake up call for the community, a warning if you will to follow the rules.

Unless someone gets nasty with them, or the complainer keeps complaining, but if they are in an aviation business surely they won’t. Being too much of a PIA can backfire.

Best course of action I think is to go quiet, but in the future be more careful to ensure your complying with the rules.

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18 minutes ago, ragedracer1977 said:

Infer was the wrong word.  What I meant was “incorrectly state”.  Knowing exactly how the process went, I can’t understand how it could be done any better to meet the documented method of OPP.  I wonder if they know how it actually went.  The only thing the owners didn’t do was press start on the machine or supply the raw aluminum.

The FAA doc indicates they're looking at the fabricator, not the owners.   I suspect making multiple of something looks too much like "manufacturing" or whatever to the FAA.   If so I'd question how many times somebody has to be asked to make the same part, or over what time period, suddenly creates a problem, or why multiple people going to the same fabricator proven to make safe parts should be discouraged.   

18 minutes ago, ragedracer1977 said:

this whole thing meets OPP a whole lot closer than ordering a pre-fab cable from a vendor…

My understanding has always been that McFarlane makes the custom/OPP/experimental cables to order, and given the differences between the ones I had made custom and the one I got PMA I suspect that's true.   They were significantly different.

18 minutes ago, ragedracer1977 said:

Also, as I understand it, it’s the owner that determines the eligibility to install and the mechanic that confirms and signs it off.  So hasn’t the eligibility been determined for those already installed and logged as OPP?

The mechanic determines that the part is properly designed, produced and documented (e.g., by an owner logbook entry), and appropriate for installation.   The installer has to determine suitability for installation with any part, whether it's PMA or TSO or otherwise "approved", so that's not really much different for an OPP part other than making sure the owner has properly documented production of the part.  At annual the IA then also determines that the aircraft conforms to type design with the OPP part.

As always, though, the FSDO can reach their own determination regardless of what went before.   It appears in this case that a MIDO has an issue with something, which a FSDO or whoever else may act upon.

18 minutes ago, ragedracer1977 said:

I do not have any of these on any airplane I own, but I do have parts on my plane that have a letter just like this floating around.  No one, including the FAA, has required removing them 

Yeah, we'll see if this blows over.   So far the most affected parties are the fabricators cited on the document.   If it becomes an issue for them and there's not some hidden malfeasance or something I'd put money in a gofundme or something to help defend those guys.

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I should visit more often. I miss out on all these opportunities to lay out a few overly obese challenges to Hank’s eyes.

As a long time Mooney owner, I have had to cross this chasm a number of times. By definition, an OPP is a part or component that is no longer commercially available from the manufacturer or PMA provider. I have always used the same approach to obtain these parts.

1) I verify that the component in question is no longer commercially available. This means that OEM doesn’t make or source them anymore. Sometimes this means finding an MSC who has old stock of something that the OEM no longer manufactures or sources. In the worst case scenario, it means, heaven forbid, digging one up at a salvage yard.

2) If option 1 is or isn’t available and a PMA equivalent is available, I look for the component through the PMA environment. Especially when the OEM charges way more than the PMA equivalent. This is where it can get challenging. There may be an updated version of something that is different enough in design and function but still fills the functional need of the original OEM design. This is when I engage the IA input on whether or not they feel it is compatible.

3) If the component is no longer commercially available through the OEM & PMA network, I then engage the OPP process. An old time IA helped me by saying that to comply, I needed to be the one directing the engagement of a provider to have the part made to my specification. He also said that it is important that owner documentation is provided to the manufacturer of the part to satisfy that I am directing and authorizing the manufacturing. And to this day I follow the same recipe.
> If the part can be sent to someone to be duplicated, I send it with my specific instruction to manufacture it to the exact specification of the item I sent. At times, the part needs to be made of an alternative material. An example is a component made of Bakelite. It is up to me and my IA to determine if the new material is acceptable for use and I provide a document to the manufacturer authorizing the OPP.
> If the part cannot be sent, I photo it, take measurements and call out anything specific (ex. material it is made of) and my authorization to make it.

Where things have gotten interesting is with the newer technologies like 3D printing.

As someone who has worked with government agencies on a regular basis, it is all about the paper trail.


Sent from my iPad using Tapatalk Pro

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