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

[chriscalandro]

1 hour ago, Pinecone said:

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.

Incorrect. the rule is owner produced part. Not owner manufactured part. 
 

in this case everyone in the pool was kept in the loop and supervised the manufacture of the part, which was based on the design data of the original. A drawing was then provided so when the part was received, quality control could be tested against the new part and measured against the drawing and the old part. 
 

mat least two of those were followed. Only one is required. 

Edited January 26, 2023 by chriscalandro

[1980Mooney]

17 hours ago, Pinecone said:

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.

Don't take this personally but if I were buying a Mooney that you or any Owner that has "a TIG welder and (thinks they) know how to use it." went the OPP route to repair, replace or remanufacture any control rod (brakes, flight surfaces or landing gear) I would deduct the cost to properly source and replace (parts and labor) those approved parts from the purchase price. I don't want to be a test pilot for someone's amateur welding ability.  If I were wanting to buy amateur built parts/plane I would be going Experimental.

[EricJ]

2 hours ago, Pinecone said:

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.

Verifying that the part meets the drawing and specifications can also serve as supervision and/or quality control.   

[1980Mooney]

40 minutes ago, EricJ said:

Verifying that the part meets the drawing and specifications can also serve as supervision and/or quality control.   

Verification by whom?  Are you suggesting that the Mooney factory will be proving certified factory drawings and material specs free as well as verification?  

[chriscalandro]

14 minutes ago, 1980Mooney said:

Verification by whom?  Are you suggesting that the Mooney factory will be proving certified factory drawings and material specs free as well as verification?  

By the owner with the blessing of the A&P/IA. That’s the regulation. 

[Pinecone]

1 hour ago, EricJ said:

Verifying that the part meets the drawing and specifications can also serve as supervision and/or quality control.   

But that they did so was not clear.

That is why there is an investigation.

If they provide the info that shows they met the requirements, then the FAA should be happy.

As the situation was stated, it did not meet the requirements.

[Pinecone]

1 hour ago, 1980Mooney said:

Don't take this personally but if I were buying a Mooney that you or any Owner that has "a TIG welder and (thinks they) know how to use it." went the OPP route to repair, replace or remanufacture any control rod (brakes, flight surfaces or landing gear) I would deduct the cost to properly source and replace (parts and labor) those approved parts from the purchase price. I don't want to be a test pilot for someone's amateur welding ability.  If I were wanting to buy amateur built parts/plane I would be going Experimental.

I  understand your concern.  But I know my welding skills, so fine with it.

Actually, looking at the Mooney produced part, I am not impressed with the welding.

[Sabremech]

4 minutes ago, Pinecone said:

But that they did so was not clear.

That is why there is an investigation.

If they provide the info that shows they met the requirements, then the FAA should be happy.

As the situation was stated, it did not meet the requirements.

These parts were made IAW the FAA OPP rules as they are currently written. 

[EricJ]

54 minutes ago, 1980Mooney said:

Verification by whom?  Are you suggesting that the Mooney factory will be proving certified factory drawings and material specs free as well as verification?  

This is for Owner Produced Parts, so the owner can verify that the part was built to their own drawing or matches the part that was provided for duplication.    This is consistent with the OPP guidelines as published by the FAA, and described in ACs, etc.

[1980Mooney]

1 hour ago, EricJ said:

This is for Owner Produced Parts, so the owner can verify that the part was built to their own drawing or matches the part that was provided for duplication.    This is consistent with the OPP guidelines as published by the FAA, and described in ACs, etc.

 

2 hours ago, Pinecone said:

I  understand your concern.  But I know my welding skills, so fine with it.

Actually, looking at the Mooney produced part, I am not impressed with the welding.

In general as you get farther from the OEM there is a natural tendency for specification, quality and especially traceability to suffer.  Before everyone blows yes there are great PMA'ed third party suppliers.  But OPP is at the other extreme. 

I understand the FAA Guidelines - I am sure that they keep the "honest pilot/owners honest" (like Basic Med).  And an individual may have great skill and is willing to take the risk of a problem from a part that they produced/manufactured that is installed on their own plane.  But what about when they sell their plane with OPP?  There will be ongoing liability to the former Owner for the OPP part.  The traceability will go back to the Owner at the time of the OPP - it has to be logged in the maintenance logs. The attached FAA PowerPoint on OPP has a slide "Making Parts Why Take On That Liability?". 

There is liability - probably small.  If a question of liability does arise, it doesn't sound like the Mooney Factory will have any desire to help you prove you produced an equivalent part to spec and material.  As @GeeBee pointed out on the prior page "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"  And Jonny, the CEO, is a lawyer so I suspect he knows exactly what he is doing re: PMA and OPP.

With an OPP, a new owner of the plane does not know the skill level of the owner that made it, know if the owner had factory drawings/specs or the integrity of whoever signed off on it - it might have been just be a "paperwork" exercise.  A buyer might be ok taking that risk but as time goes on these planes with OPP become more "experimental" and less "certified".  Price needs to reflect that.

https://www.csobeech.com/files/FAA-OwnerProducedParts-DonDodge.pdf

[EricJ]

1 hour ago, 1980Mooney said:

 

In general as you get farther from the OEM there is a natural tendency for specification, quality and especially traceability to suffer.  Before everyone blows yes there are great PMA'ed third party suppliers.  But OPP is at the other extreme. 

I understand the FAA Guidelines - I am sure that they keep the "honest pilot/owners honest" (like Basic Med).  And an individual may have great skill and is willing to take the risk of a problem from a part that they produced/manufactured that is installed on their own plane.  But what about when they sell their plane with OPP?  There will be ongoing liability to the former Owner for the OPP part.  The traceability will go back to the Owner at the time of the OPP - it has to be logged in the maintenance logs. The attached FAA PowerPoint on OPP has a slide "Making Parts Why Take On That Liability?". 

There is liability - probably small.  If a question of liability does arise, it doesn't sound like the Mooney Factory will have any desire to help you prove you produced an equivalent part to spec and material.  As @GeeBee pointed out on the prior page "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"  And Jonny, the CEO, is a lawyer so I suspect he knows exactly what he is doing re: PMA and OPP.

With an OPP, a new owner of the plane does not know the skill level of the owner that made it, know if the owner had factory drawings/specs or the integrity of whoever signed off on it - it might have been just be a "paperwork" exercise.  A buyer might be ok taking that risk but as time goes on these planes with OPP become more "experimental" and less "certified".  Price needs to reflect that.

https://www.csobeech.com/files/FAA-OwnerProducedParts-DonDodge.pdf

As described in Don Dodge's presentation, which often gets presented at IA conferences (I've seen the FAA present it at least twice), the installer (typically an A&P) has the responsibility to determine suitability for installation.   This includes, imho, assuring that the part has been properly documented and recorded.   At the next annual, and every subsequent annual, an IA determines that the aircraft conforms to its TC and is safe for operation.   If those things have happened there's no reason to believe that the aircraft is any more unsafe or unairworthy than any other airplane.   Many airplanes have crashed after installation of OEM, PMA, STC, TSO parts, too, and somebody who's going to be flying themself and their family and friends might be reasoned to take the task as seriously as anybody else.   The installer's (A&P's) responsibility is the same regardless of whether it is an OEM, PMA, STC, TSO, or OPP part, and the opportunity to make an unsafe installation is there regardless of where the part came from.

So the liability isn't strictly on an owner, and probably not much on an owner for installing an OPP part.   Airlines install OPP parts all the time, and that's actually where the process came from.

There is an FAA legal opinion letter on this topic as well (Byrne) that goes into more detail with examples of third parties producing parts.   The gist is still that as long as the owner participates as guided by the FAA in the various relevant ACs and the part meets the required specifications and is safe for installation, third parties, PMA or not, can be involved in the fabrication of the part.

There are a lot of airplanes and makes and models of airplanes that would no longer be flying at all without OPP.   Mooney is headed that way (or already there) and we already see many difficulties in maintaining some models due to chronic part unavailability.   When I've seen Dodge's slides presented by the FAA it was stated specifically in the context of slide 4 that long lead times or excessive parts price were justification for OPP.   So even if the part is "available" (in 6 months, as shown on the slide, as an unacceptable down time), or even "don't talke about the price" territory, OPP is an acceptable path to the FAA.   The OEM's opinion isn't even considered in the process.

[glbtrottr]

Where’s Johnny in all this?

I remember him posting with a lot of enthusiasm some time back while asking for support …


Sent from my iPhone using Tapatalk

[N201MKTurbo]

6 hours ago, 1980Mooney said:

Don't take this personally but if I were buying a Mooney that you or any Owner that has "a TIG welder and (thinks they) know how to use it." went the OPP route to repair, replace or remanufacture any control rod (brakes, flight surfaces or landing gear) I would deduct the cost to properly source and replace (parts and labor) those approved parts from the purchase price. I don't want to be a test pilot for someone's amateur welding ability.  If I were wanting to buy amateur built parts/plane I would be going Experimental.

One of the hanger rods in my landing gear got cracked when I first got my plane because it wasn't put together right. I repaired it according to 43-13,1b. I double dog dare you to tell me which one I fixed.

[Pinecone]

4 hours ago, EricJ said:

This is for Owner Produced Parts, so the owner can verify that the part was built to their own drawing or matches the part that was provided for duplication.    This is consistent with the OPP guidelines as published by the FAA, and described in ACs, etc.

This is the issue I see.  The drawing was supplied to the owner by the maker of the part.  Not the other way around.

They may be perfectly within the requirements, but it looks like there may be an issue, so FAA investigates.  

Explaining exactly how you meet the requirements should clear things up.

[N201MKTurbo]

I went to a seminar before COVID with the PMA lady from the MIDO. She talked about the process and what you can and cannot do. Mooney saying that nobody else can manufacture the ir parts is simply not true. She gave many examples of acceptable ways to reverse engineer parts for PMA. I believe she said you have to prove that they are the exact same design and materials, or prove that they equivalent or better than the original design in form fit and function. This usually involves having the materials metallurgically analyzed to determine their strength and hardness along with dimensional drawings. It can also be the opinion of a DER that the PMA part is adequate for the job. Of course this depends heavily on what kind of part it is. The bottom line is you can get PMA on a part without the OEM supporting you.

[EricJ]

26 minutes ago, Pinecone said:

This is the issue I see.  The drawing was supplied to the owner by the maker of the part.  Not the other way around.

They may be perfectly within the requirements, but it looks like there may be an issue, so FAA investigates.  

Explaining exactly how you meet the requirements should clear things up.

My limited understanding of the contextual issue is not what the individual owners did, but that the fabricator made multiple copies of the part.    This may look to somebody like manufacturing, but there don't seem to be any stated limitations on multiple people asking the same fabricator to make the same part under OPP, especially if it is known that the fabricator has the capability and can make a safe part.   McFarlane has been doing this for years for engine control cables, but each owner approves a separate drawing.  Gee Bee has been doing the same with baffles for a long time, and apparently already went through the wringer with the FAA and came out the other side still doing the same thing.  Disallowing a fabricator who has demonstrated the ability to make a safe part from doing the same for another individual seems counterproductive to me.

[Igor_U]

20 minutes ago, N201MKTurbo said:

The bottom line is you can get PMA on a part without the OEM supporting you.

And LASAR is a good example for years selling PMA'd parts that are similar (or even identical) to Mooney OEM parts...

[Fly Boomer]

34 minutes ago, N201MKTurbo said:

One of the hanger rods in my landing gear got cracked when I first got my plane because it wasn't put together right. I repaired it according to 43-13,1b. I double dog dare you to tell me which one I fixed.

Reminds me of a master woodworker I know.  His daughter asked him to duplicate a bedside table so she could have one on each side.  When he finished, he made the same challenge you did:  "I dare you to figure out which one is the original".

[EricJ]

Just now, Igor_U said:

And LASAR is a good example for years selling PMA'd parts that are similar (or even identical) to Mooney OEM parts...

In some cases better!   Many people prefer the Lasar nosegear over the OEM.

[Fly Boomer]

1 hour ago, N201MKTurbo said:

Of course this depends heavily on what kind of part it is.

That makes sense.  A gear door rod end isn't quite as critical as a forged connecting rod in your engine.

[Sabremech]

40 minutes ago, Pinecone said:

This is the issue I see.  The drawing was supplied to the owner by the maker of the part.  Not the other way around.

They may be perfectly within the requirements, but it looks like there may be an issue, so FAA investigates.  

Explaining exactly how you meet the requirements should clear things up.

The owners have complied with at least one of the OPP requirements.

 

[Sabremech]

Can anyone provide the definition of quality control in regards to owner produced parts? The FAA is yet to provide the definition in all of the regulations, AC’s or legal opinions that they’ve sent me. 
 

Edited January 26, 2023 by Sabremech

[N201MKTurbo]

1 hour ago, Fly Boomer said:

That makes sense.  A gear door rod end isn't quite as critical as a forged connection rod in your engine.

Yep, but Superior will sell you a Lycoming connecting rod. And look at how many companies make cylinders.  

[Canadian Gal]

Way back in this thread someone brought up Mooney.

Patents don't last forever, so even if they once upon a time had a patent on a part, it very likely ended by now since most Mooneys are older.

[EricJ]

11 minutes ago, Canadian Gal said:

Way back in this thread someone brought up Mooney.

Patents don't last forever, so even if they once upon a time had a patent on a part, it very likely ended by now since most Mooneys are older.

TCs and STCs never expire, though.