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


chriscalandro
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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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On 11/24/2022 at 9:27 PM, 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 parts 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.


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  • 2 months later...
On 11/24/2022 at 8:24 PM, Shadrach said:

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.

Well said. The whole thing sounds like straining out a gnat while swallowing a camel.

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On 11/24/2022 at 11:16 AM, A64Pilot said:

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

So if I can call McFarlane and tell them the length of throttle cable that I need, and presto!, they make one for me and it's OPP, why are other parts handled differently? Why do I need to ship a metal block to a machinist? Can't I just say, use Material X and make it this big, and have a PMA? 

Then again, as an owner, my participation can also be in Quality Assurance, where I check the new part and make sure that it matches my requirements. Presto, I've participated in the production, so it's OPP. Or do I need to run off everyone in Quality Control here at my (non-aviaiton) manufacturing job?

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Unless a part is made from an inferior metal, or if it needs heat treatment,  that process was done incorrectly,  say over treated, and now brittle,  I can't see how its a problem.

 

A group of us got together and had a batch of parts made years ago for our planes, which IMHO are if anything superior to the OEM part.

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On 11/24/2022 at 10:39 PM, A64Pilot said:

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.

From what I see, this is the issue.

If they had paid to get the drawing made, then each supplied the drawing, and the fabricator realized they were the same and did a CNC file to make them, that is OPP.

But it was stated that the drawing was sent to the owner with the part.  That is not the owner supplying the specs.

Sorry people, but laws and regulations ARE semantics.  And how you read laws and regulations is very specific.  

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I have to say somewhat with trepidation, I asked Jonny at Mooney Max in June 2022 if he was worried PMA manufacturers were going to "pick Mooney's bones". He answered that Mooney owns the drawings and designs and no one can produce them without Mooney's approval. To my mind, I think he and maybe others at Mooney misunderstand the process of PMA as well as  OPP. The best way to keep others out of small production run parts is to make them easily available so interlopers do not move in on your business. Maybe he misunderstood my question, I don't know but the answer was not what I was hoping it would be.

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Lol.

I just paid an insane amount of money for a fuel gasket made out of Viton.

Really?

This is why people don’t support a factory that unreasonably prices it’s goods. Viton- literally a 2 minute cut.

Sad


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I recently considered the OPP path.

I need two adjustable links for the pedals to the master cylinders.  It is a rod end bearing ($35 retail), a clevis ($19 retail) and two pieces of steel tubing, about 3 inches total.  Three welds and some paint.

Mooney charged over $600 to manufacture (LASAR had one for under $300).

I have a TIG welder and know how to use it.  I could have fabricated two for around $100 in materials.

 

HIGHLY agree that if Mooney does not have parts available at reasonable prices, people will OPP, or PMA holders will move in.

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Clearly…

We need to review the important details of what makes OPP a legal alternative…

1) When parts aren’t available… that is pretty easy.

2) Using the proper materials… pretty straight forward when using the same materials.

3) Using the proper drawing… or other tech info.  Having the drawing, or the ability to generate one always works…

4) Record keeping, lot numbers, QC practices… some MSers have these skills…

 

A few times each decade… the Mooney factory has been shut down and there were no parts available during those times…

Availability and reasonable prices… sounds like an expensive lawyer may be needed to define that… :)

 

When it comes to manufactured parts and industrial applications… a 40% mark up is common…

On parts purchased outside, the margin is typically less than half of that…. There are costs involved in handling and inventory…

A spare parts division of a manufacturing company can sustain itself with proper pricing…

Overcharge for something that can be found elsewhere… just has people go elsewhere for it… this doesn’t help the business either…

So join the modern manufacturing business… and focus on the right margin for the right parts process… not one margin calculation for everything…

Don’t get caught out by your disgruntled customers… :)

PP thoughts only, not a parts supplier…

Best regards,

-a-

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Mike Busch article on OPP - https://resources.savvyaviation.com/wp-content/uploads/articles_eaa/EAA_2011-08_owner-produced-parts.pdf

 

The key is, the owner must do one of the following:

• Provides the manufacturer with design
or performance data from which to
manufacture the part—this test would
be met if the owner provides the manufacturer with the old part and asks that
it be duplicated; or


• Provides materials to make the part; or

• Provides fabrication processes or
assembly methods to be used in making
the part; or

• Provides quality control procedures to
be used in making the part; or

• Supervises the manufacture of the part.

So, where I see the issue with the parts in question, one person sent in a part.  Drawings were made, that went directly to the company making the part and the parts, with the drawing, were sent to a number of owners.

The person who sent the original part, has an OPP.  The others do not.  IMO, if the drawing had been sent to each of them, and they each sent the drawing to the shop to have the part made, it would meet the test of OPP.

Or, they could have ordered the block of aluminum to be delivered to the shop to fabricate their part.

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17 hours ago, GeeBee said:

I have to say somewhat with trepidation, I asked Jonny at Mooney Max in June 2022 if he was worried PMA manufacturers were going to "pick Mooney's bones". He answered that Mooney owns the drawings and designs and no one can produce them without Mooney's approval. To my mind, I think he and maybe others at Mooney misunderstand the process of PMA as well as  OPP. The best way to keep others out of small production run parts is to make them easily available so interlopers do not move in on your business. Maybe he misunderstood my question, I don't know but the answer was not what I was hoping it would be.

I think Johnny has a fundamental mis-understanding of how things work. 

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