Gear SAIB

[Guest]

4 hours ago, Sabremech said:

I reached out to the ACO Engineer listed on the SAIB because I feel they missed the most important part for the manual gear airplanes which is a worn downlock block. They didn’t seem to know anything about the downlock as the focus was on rigging and lubrication. I’m not convinced it’s really a rigging issue as much as it’s a worn block with no instructions for inspection or limits. I sent the engineer a number of pictures of worn down lock blocks for them to review. Let’s see if there’s an update to this SAIB.

David

If only we could find someone to make some new ones!

[EricJ]

3 hours ago, Mac80 said:

 

Can an experienced mechanic tell if tensions in electric M20 J main and front landing gear are correct from  jacking aircraft and doing gear swings?

Is down and locked mean you have enough preload or is mechanic suppose to measure tensions and preload  thru belly pan and near the wheels at each 100 hour or annual?

 

As mentioned, yes, there is a procedure in the maintenance manual for checking the gear rigging, and it should be done every year at annual inspection.   It isn't very difficult to do, but does require a special tool.   It essentially measures the amount of pressure (torque) on the overcenter mechanism to make sure it won't unlock when down.

[ragedracer1977]

41 minutes ago, Shadrach said:

I understood at the outset. He wishes not to discuss. I understand why. It’s likely that no one knows for sure but can speculate with a high level of confidence…that’s not the same thing as knowing and it’s not smart to speculate on social media about a matter that is ongoing.

I sure wish someone could shed a beam of light on it for us.

[kortopates]

This recent service letter from Mooney appears to be the factories response to address the apparent increased gear incidents and focused on all kinds of causes from pilot error on up. Its also a pretty good comprehensive write-up on how both manual and electric gears systems work.

David mentioned the ACO inspector didn't appreciate the worn down block issue but Mooney's SB sure does. The SAIB should have included a reference to this Mooney SB-344

 

SBM20-344.pdf

Edited March 8, 2023 by kortopates

[Sabremech]

2 hours ago, M20Doc said:

If only we could find someone to make some new ones!

I’m not done! Just in a holding pattern for a bit.

Edited March 8, 2023 by Sabremech

[Sabremech]

41 minutes ago, kortopates said:

This recent service letter from Mooney appears to be the factories response to address the apparent increased gear incidents and focused on all kinds of causes from pilot error on up. Its also a pretty good comprehensive write-up on how both manual and electric gears systems work.

David mentioned the ACO inspector didn't appreciate the worn down block issue but Mooney's SB sure does. The SAIB should have included a reference to this Mooney SB-344

 

SBM20-344.pdf 488.98 kB · 1 download

I found nothing in regards to looking at the downlock block for wear in the S/B or the limits of wear allowed. No inspection interval either for that matter on the blocks themselves. Still missing a crucial part in the gear up scenario.

[PT20J]

1 hour ago, kortopates said:

The SAIB should have included a reference to this Mooney SB-344

It did Paul, you just missed it

[Shadrach]

2 hours ago, ragedracer1977 said:

I sure wish someone could shed a beam of light on it for us.

There are only two going concerns capable of manufacturing down block. So….probably one of them.

[ragedracer1977]

17 minutes ago, Shadrach said:

There are only two going concerns capable of manufacturing down block. So….probably one of them.

Thanks for amplifying the light! Your post really stimulates the radiation!

[Shadrach]

8 hours ago, ragedracer1977 said:

Thanks for amplifying the light! Your post really stimulates the radiation!

I don’t think anyone knows for a fact beyond the FAA. So why would anyone make accusations they can’t prove on-line? 

[ragedracer1977]

42 minutes ago, Shadrach said:

I don’t think anyone knows for a fact beyond the FAA. So why would anyone make accusations they can’t prove on-line? 

I bet if you asked in FOIA, they would tell you.  

[Shadrach]

2 hours ago, ragedracer1977 said:

I bet if you asked in FOIA, they would tell you.  

That’s likely true. It’s also true that the whole kerfuffle may have started through an anonymous channel. At the end of the day, I don’t think anyone really cares that much. I think most of us just want it to go away and retain our ability to collaborate as owners to produce hard to obtain parts for our personal aircraft that are of the highest quality possible.
In my professional life I encounter loads of inefficient entities that can barely get out of their own way. If half of my vendors were as competent, communicative, organized and motivated as the folks that I worked with to fabricate my down locks, my life would be infinitely easier. 

[cliffy]

On 3/6/2023 at 10:04 AM, EricJ said:

When owners did get together to get lock blocks made a maintenance shop subsequently called the authorities on the fabricators.

The issue here is the "manufacturing for sale" of parts for certified aircraft.

No one can  manufacture and sell parts for certified aircraft unless they have the proper licenses and paper work signed off.

PMA. STCs  quality control  procedures, etc all have to be approved by the FAA before sale  to the public.

ANY owner can "make" a part for his airplane under OPP BUT OPP has 4 legs to comply with and all 4 legs

have to be accomplished.

Its all in doing the proper way.  The paper work trail is vitally important

IF the blocks had been done in compliance with OPP then all the owners could have " designed" them and purchased them.

No different than buying a throttle cable from Mc Farland under OPP. 

The owner has to have a well documented input in the design or manufacture   of the part

The hardest part is finding qualified data to make the part correctly. Or have the blessing of a DER for the design and then OPP.

You just can't make 50 of them and then go out and sell them to the public at large with no input from the owner except for writing a check.

[Sabremech]

58 minutes ago, cliffy said:

The issue here is the "manufacturing for sale" of parts for certified aircraft.

No one can  manufacture and sell parts for certified aircraft unless they have the proper licenses and paper work signed off.

PMA. STCs  quality control  procedures, etc all have to be approved by the FAA before sale  to the public.

ANY owner can "make" a part for his airplane under OPP BUT OPP has 4 legs to comply with and all 4 legs

have to be accomplished.

Its all in doing the proper way.  The paper work trail is vitally important

IF the blocks had been done in compliance with OPP then all the owners could have " designed" them and purchased them.

No different than buying a throttle cable from Mc Farland under OPP. 

The owner has to have a well documented input in the design or manufacture   of the part

The hardest part is finding qualified data to make the part correctly. Or have the blessing of a DER for the design and then OPP.

You just can't make 50 of them and then go out and sell them to the public at large with no input from the owner except for writing a check.

You do NOT have to comply with all 4 parts of OPP. You need only to comply with one of them to meet the rule. You also don’t need qualified data. You need nothing other than an original part to make a new one. Sorry Cliffy, but you don’t seem to understand OPP rules. 

[ragedracer1977]

1 hour ago, cliffy said:

The issue here is the "manufacturing for sale" of parts for certified aircraft.

No one can  manufacture and sell parts for certified aircraft unless they have the proper licenses and paper work signed off.

PMA. STCs  quality control  procedures, etc all have to be approved by the FAA before sale  to the public.

ANY owner can "make" a part for his airplane under OPP BUT OPP has 4 legs to comply with and all 4 legs

have to be accomplished.

Its all in doing the proper way.  The paper work trail is vitally important

IF the blocks had been done in compliance with OPP then all the owners could have " designed" them and purchased them.

No different than buying a throttle cable from Mc Farland under OPP. 

The owner has to have a well documented input in the design or manufacture   of the part

The hardest part is finding qualified data to make the part correctly. Or have the blessing of a DER for the design and then OPP.

You just can't make 50 of them and then go out and sell them to the public at large with no input from the owner except for writing a check.

Eh, I asked the FAA about this today.  Said if a bunch of owners decided they need a part, can they get together and get someone to make a run of “owner produced” parts for them.

FAA- “Yes. That would be fine.”

Edited March 10, 2023 by ragedracer1977

[Shadrach]

1 hour ago, cliffy said:

You just can't make 50 of them and then go out and sell them to the public at large with no input from the owner except for writing a check.

Do you really believe that this is how things transpired? It’s not and suggesting it is does not serve anyone…

[Shadrach]

13 hours ago, ragedracer1977 said:

Eh, I asked the FAA about this today.  Said if a bunch of owners decided they need a part, can they get together and get someone to make a run of “owner produced” parts for them.

FAA- “Yes. That would be fine.”

Some regions are infinitely more reasonable than others. Some folks just love reading regulations in the most impractical and burdensome way possible.   “This all would have been perfectly fine if you all had just submitted 40 different drawings to the fabricator.” Or “It would have been fine for you all to share drawings as long as you went to 40 different fabricators.”
It’s really difficult to wtite regulations well, there will always be unintended consequences. Interpretation will almost always be necessary. What’s fascinating to me is that the focus is not at all on the parts’ physical airworthiness but the subjective analysis of what constitutes sufficient owner participation prior to fabrication.  

[ragedracer1977]

26 minutes ago, Shadrach said:

Some regions are infinitely more reasonable than others. Some folks just love reading regulations in the most impractical and burdensome way possible.   “This all would have been perfectly fine if you all had just submitted 40 different drawings to the fabricator.” Or “this all would have been fine for you all to share drawings as long as you went to 40 different fabricators.”
It’s really difficult to right regulations well, there will always be unintended consequences. Interpretation will almost always be necessary. What’s fascinating to me is that the focus is not at all on the parts physical airworthiness but the subjective analysis of what constitutes sufficient owner participation prior to fabrication.  

The main takeaway from everything I heard today from the symposium was this “airworthiness is in the eye of the beholder”.

they even gave an example of an IA declaring an airplane un-airworthy, even though the mod was installed prior to the FAA issuing the airworthiness certificate.

 I’m a licensed FFL (firearms dealer and manufacturer) and I left today thinking that the paperwork and rules I have to follow are pretty reasonable in comparison. 
Of course if I screw up, I can actually go to federal prison.

Edited March 10, 2023 by ragedracer1977

[cliffy]

I respectfully disagree-

Somewhat lengthy but definitive---  I know of nothing that has modified this process since it came out 

https://www.aviationpros.com/home/article/10387511/owner-produced-parts-how-they-affect-maintenance

[ragedracer1977]

19 minutes ago, cliffy said:

I respectfully disagree-

Somewhat lengthy but definitive---  I know of nothing that has modified this process since it came out 

https://www.aviationpros.com/home/article/10387511/owner-produced-parts-how-they-affect-maintenance

I have to respectfully ask: did you actually read the article you linked? It doesn’t agree with you.

[cliffy]

OK Im confused now    In what way?

[ArtVandelay]

I respectfully disagree-
Somewhat lengthy but definitive---  I know of nothing that has modified this process since it came out 
https://www.aviationpros.com/home/article/10387511/owner-produced-parts-how-they-affect-maintenance

The easiest way to comply with the rules is provide quality control of the manufactured part, each person receiving the part can verify quality when they receive it. I would make log entry with a phrase “verified the part was exact duplicate and function“ or something similar to document you participated in the OPP process.

[Sabremech]

5 hours ago, cliffy said:

I respectfully disagree-

Somewhat lengthy but definitive---  I know of nothing that has modified this process since it came out 

https://www.aviationpros.com/home/article/10387511/owner-produced-parts-how-they-affect-maintenance

From your linked article, the owner must participate in at least ONE of the five ways to be considered owner produced. Did you miss that in your reading? I stopped reading any further after that! 

Edited March 10, 2023 by Sabremech

[Pinecone]

6 hours ago, cliffy said:

I respectfully disagree-

Somewhat lengthy but definitive---  I know of nothing that has modified this process since it came out 

https://www.aviationpros.com/home/article/10387511/owner-produced-parts-how-they-affect-maintenance

You are not reading that article carefully.  It CLEARLY says you only need to meet ONE of the requirements.

 

"The aircraft owner must participate in the manufacture of the part in at least one of five ways for it to be considered an owner produced part.
1. The owner provides the manufacturer of the part with the design or performance data.
2. The owner provides the manufacturer of the part with the materials.
3. The owner provides the manufacturer with fabrication processes or assembly methods.
4. The owner provides the manufacturer of the part with quality control procedures.
5. The owner personally supervises the manufacture of the new part."

[Shadrach]

On 3/10/2023 at 8:18 AM, bluehighwayflyer said:

As broad as that is the only way I can see the FAA winning any type of OPP enforcement action is if the only thing the owner provides the manufacturer is money.  

Even in that case, a strong case could be made that QC was performed by the owner prior to install.  The regs are actually pretty reasonably written, but you can never account for the bureaucracy for the sake of bureaucracy types. 

In my case, in addition to discussions prior to pre paying as well as updates and images of the progress, we also put micrometer to metal when the new parts arrived. We compared them to the specs and drawings used for fabrication as well as the removed OE parts. We verified the interface between the J-bar and the new sockets prior to installation.  I also consulted with my IA prior to committing to having the parts fabricated (which was months before they were completed and received).  My IA and I were both very impressed with the quality of the end product.  It was superior to the OE pieces in fit and finish and conformed precisely to the OE part. The accompanying documents and CAD drawings were complete and professionally rendered.  IA confirmed airworthiness and the the installation was flawless. 

This is very likely a case where a business that was unable to adequately serve demand is now improperly attempting to use the FAA to punish those who used the OPP process to keep their aircraft safe and airworthy.  It's a misuse of resources and the letter issued by the FAA should have never been worded as it was. It's an embarrassment.