LASAR Recall

[tony]

I thought the yellow tag (return to service) did

[PT20J]

1 minute ago, tony said:

Do you think they are they working to a repair spec?  

The paperwork probably weighs more than the part

[EricJ]

On 8/16/2024 at 1:31 PM, tony said:

I thought the yellow tag (return to service) did

Not sure what you were replying to, but for us (Part 91) a yellow tag is just an informal method to provide some usually marginally useful information.   8130-3s aren't really even required for very much, mostly if you are exporting a part.   They can be useful to the installer to help determine airworthiness, condition, and suitability for installtion, but the installer has to do that with or without any of that paperwork, and the paperwork isn't required.   

For example, if somebody gets some new tires, throws away or loses the paperwork, and they wind up being surplus, if they're the proper tires for your airplane and are in good condition for safe use, there's nothing stopping anyone (including an owner) from installing them on their airplane.    This happens all the time, and usually verification of proper part number, general condition, functional test after installation, etc., is commonly what is done.   We are a bit lucky that we're not as subject to the counterfeit parts problems as the airlines, since we have a small market supported by CBs. 

[1980Mooney]

20 hours ago, TCW3 said:

Who is liable for the labor/time of removal/install/test process?

Unless there is a class action lawsuit, I believe that you are liable to your mechanic to pay for all those expenses. And you remain liable for all the fixed costs while your plane sits idle on jack stands. Did they send you a prepaid mailer or did you incur the cost of shipping it back to them?  

[PT20J]

1 hour ago, 1980Mooney said:

Unless there is a class action lawsuit, I believe that you are liable to your mechanic to pay for all those expenses. And you remain liable for all the fixed costs while your plane sits idle on jack stands. Did they send you a prepaid mailer or did you incur the cost of shipping it back to them?  

You mean like house paint. If it fails, the manufacturer will replace the paint. The labor is on you.

[philiplane]

On 8/14/2024 at 8:02 PM, kortopates said:

They knew they would have to be re-approved under the new FSDO. I thinks it simply they underestimated the effort and had no prior experience with the process.


Sent from my iPhone using Tapatalk

Therein lies the problem. Why is moving a shop from one FSDO to another such a difficulty? The FAA exists to ensure that safety is assured. But it often results in completely unreasonable costs and delays, without ensuring or improving safety. 

This has to change.

[PT20J]

21 minutes ago, philiplane said:

Therein lies the problem. Why is moving a shop from one FSDO to another such a difficulty? The FAA exists to ensure that safety is assured. But it often results in completely unreasonable costs and delays, without ensuring or improving safety. 

This has to change.

It’s because FAA HQ delegates authority to the regions. But in the case of LASAR, if everyone that had institutional knowledge is gone and the new mechanics are just learning by reading the old paperwork, I might not want to be first in line to have them rebuild my parts. There’s an old saying, “The pioneers get the arrows.”

[EricJ]

40 minutes ago, philiplane said:

Therein lies the problem. Why is moving a shop from one FSDO to another such a difficulty? The FAA exists to ensure that safety is assured. But it often results in completely unreasonable costs and delays, without ensuring or improving safety. 

This has to change.

Offices are responsible for the authorizations that they do and appropriate oversight, so asking one office to be responsible for oversight of something authorized by another creates a conflict potential.   There's a potential for getting stuck with a steaming pile of crap that somebody else authorized, as well as companies office-shopping to get authorized under one office and then operate under another.   Definitely not a perfect system, but I understand the logic behind it.

 

[Hank]

1 hour ago, EricJ said:

Offices are responsible for the authorizations that they do and appropriate oversight, so asking one office to be responsible for oversight of something authorized by another creates a conflict potential.   There's a potential for getting stuck with a steaming pile of crap that somebody else authorized, as well as companies office-shopping to get authorized under one office and then operate under another.   Definitely not a perfect system, but I understand the logic behind it.

So change the screwball setup, and have each office process authorizations to the same standard! Then when aircraft owners install STCs and later relocate, the new FSDO cannot "disallow" or unapprove the equipment / changes that have been flying safely for years . . .

[1980Mooney]

If your favorite restaurant moves to a new location with new cook and employees and gets a "F" rating from the Health Department, who do you blame?  The Health Inspector or the restaurant?  Do you keep eating there?

Many are assuming that this is the fault of the big bad old FAA/FSDO. It is possible that the local FSDO is applying the regs consistently and it is the "new" LASAR that can't get their collective act together.  As @kortopates highlighted likely LASAR underestimated the task.  This is not a case of equipment/processes/suppliers/people "that have been flying safely for years...".  They don't have the same welding vendors, virtually none of the same employees (is it only one maybe?), maybe a different steel supplier, etc.  As @PT20J speculates maybe they failed the record-keeping/traceability audit.  Then again maybe LASAR F'ed up worse than just paper work  - It is easy for them to blame the FAA. 

Until LASAR explains their shortcomings we will never know how serious this is and who is at fault.

 

 

[EricJ]

1 hour ago, 1980Mooney said:

If your favorite restaurant moves to a new location with new cook and employees and gets a "F" rating from the Health Department, who do you blame?  The Health Inspector or the restaurant?  Do you keep eating there?

Many are assuming that this is the fault of the big bad old FAA/FSDO. It is possible that the local FSDO is applying the regs consistently and it is the "new" LASAR that can't get their collective act together.  As @kortopates highlighted likely LASAR underestimated the task.  This is not a case of equipment/processes/suppliers/people "that have been flying safely for years...".  They don't have the same welding vendors, virtually none of the same employees (is it only one maybe?), maybe a different steel supplier, etc.  As @PT20J speculates maybe they failed the record-keeping/traceability audit.  Then again maybe LASAR F'ed up worse than just paper work  - It is easy for them to blame the FAA. 

Until LASAR explains their shortcomings we will never know how serious this is and who is at fault.

I tend to agree.   Moving an established business to another area and not being prepared for the consequences is a business management issue, not a government issue.   

 

[philiplane]

28 minutes ago, EricJ said:

I tend to agree.   Moving an established business to another area and not being prepared for the consequences is a business management issue, not a government issue.   

 

Having dealt with six different FDSO and two different ACO offices, I can tell tell you that the problem is definitely a government issue.

They all use the same book of rules, but no two will "interpret" them the same. Even though they go to classes specifically designed to identify and prohibit "inspector's personal preferences". And over the past decade, it's increasingly difficult to get any inspector to sign off on anything new. Want a Field Approval? No, spend $$$$ and get a DER to draw up an 8110 instead. And check rides for an initial CFI was the sole province of the FSDO. Now, they're being done by DPE's. They're getting paid more and more, and putting out less than ever. Doling out what used to be FSDO core functions, to designees. I sympathize with the employees though, they waste huge amounts of time on non-productive bureaucratic chores that Washington thinks are needed. Oklahoma City has no say in the matter.

This has led to FSDO shopping, which the FAA is trying to stamp out. There are a few FSDO's that are still operating like they were 30 years ago. That will change as the oldest inspectors retire.

[PT20J]

I only have one data point: After the move to Oregon, I contacted the new owner and asked specifically if they could still rebuild nose gears and landing gear actuators and he said that they could. A year later when I needed to get a damaged nose gear leg repaired, Dan told me that they did not have FAA approval yet. Maybe the FAA is slow or maybe LASAR way underestimated the amount of work required to meet FAA requirements. But, the fact is that it took a very long time and it sounds like the bugs are not all worked out yet.

[Hank]

47 minutes ago, PT20J said:

I only have one data point: After the move to Oregon, I contacted the new owner and asked specifically if they could still rebuild nose gears and landing gear actuators and he said that they could. A year later when I needed to get a damaged nose gear leg repaired, Dan told me that they did not have FAA approval yet. Maybe the FAA is slow or maybe LASAR way underestimated the amount of work required to meet FAA requirements. But, the fact is that it took a very long time and it sounds like the bugs are not all worked out yet.

All it takes is one petty bureaucrat on a power trip, whether he is demonstrating his power to applicants or to coworkers . . . . There is no way to reign them in.

[EricJ]

50 minutes ago, philiplane said:

Having dealt with six different FDSO and two different ACO offices, I can tell tell you that the problem is definitely a government issue.

They all use the same book of rules, but no two will "interpret" them the same. Even though they go to classes specifically designed to identify and prohibit "inspector's personal preferences". And over the past decade, it's increasingly difficult to get any inspector to sign off on anything new. Want a Field Approval? No, spend $$$$ and get a DER to draw up an 8110 instead. And check rides for an initial CFI was the sole province of the FSDO. Now, they're being done by DPE's. They're getting paid more and more, and putting out less than ever. Doling out what used to be FSDO core functions, to designees. I sympathize with the employees though, they waste huge amounts of time on non-productive bureaucratic chores that Washington thinks are needed. Oklahoma City has no say in the matter.

This has led to FSDO shopping, which the FAA is trying to stamp out. There are a few FSDO's that are still operating like they were 30 years ago. That will change as the oldest inspectors retire.

That was my point.    The differences in FSDO operations is well known, and often influenced by the industries and operations that dominate the operations in each FSDO district.   In other words, you can't expect them all to be the same, because they wind up doing different things.    Since this is well known, it is a business management failure to not be prepared for this difference when moving an established business from one district to another.

It is, however, always easy and popular to blame the government. 

BTW, various FSDOs are indicating that they do field approvals now and have been doing them.   

[MikeOH]

5 hours ago, EricJ said:

That was my point.    The differences in FSDO operations is well known, and often influenced by the industries and operations that dominate the operations in each FSDO district.   In other words, you can't expect them all to be the same, because they wind up doing different things.    Since this is well known, it is a business management failure to not be prepared for this difference when moving an established business from one district to another.

It is, however, always easy and popular to blame the government. 

BTW, various FSDOs are indicating that they do field approvals now and have been doing them.   

Hmm, I'm going to try and be polite  But I find that explanation a bit of 'making an excuse' for the government.  While I grant your point that it's 'always easy and popular to blame the government' I think it is completely unreasonable to hang this on a small business' failure to anticipate this difference. The DIFFERENCE should NOT exist in the first place.  Yes, it's reality, but it should NOT be.  The whole premise of the FAA is one of standardization; in the beginning the Feds took control as airspace could NOT be regulated individually by the States for that would be anarchy!

Despite local differences in the 'influence of industries and operations that dominate the operations in each FSDO district' each and every FSDO should be BOUND to honor the decisions/approvals of any other FSDO in this kind of circumstance even if their particular local 'politics' would NOT have originally approved the request. IOW, the fact that LASER was able to obtain FSDO approval in one district should carry over to another.  They should only have to demonstrate the same process and controls exist at the new location as they did at the old; approvals should not be subject to the whim of the new FSDO.

[EricJ]

3 hours ago, MikeOH said:

 They should only have to demonstrate the same process and controls exist at the new location as they did at the old; approvals should not be subject to the whim of the new FSDO.

I don't know that that's not the case.   The PMA process is standardized, as the feds can't do anything without a formalized process, and they have to follow it.   Remember It was an entirely different set of people at LASAR that got the PMAs than are trying to get them now, so I suspect the more likely place for differences is at LASAR.

[MikeOH]

54 minutes ago, EricJ said:

I don't know that that's not the case.   The PMA process is standardized, as the feds can't do anything without a formalized process, and they have to follow it.   Remember It was an entirely different set of people at LASAR that got the PMAs than are trying to get them now, so I suspect the more likely place for differences is at LASAR.

Agreed.

If the 'new' LASAR can't establish that they have the same approved processes/procedures/QA in place then I've no quarrel with the local FSDO withholding approval.

[PT20J]

8110.42d.pdf

[N201MKTurbo]

I thought this was about repaired parts not manufactured parts. What does PMA have to do with it?

A repair station needs to have approved procedures to repair things. This seems to be where the problem lies. Haven’t you noticed that repair stations publish their capabilities list. This is a list of approved procedures they have on file. So, they didn’t have the procedures, or didn’t follow it.

[N201MKTurbo]

21 hours ago, philiplane said:

Having dealt with six different FDSO and two different ACO offices, I can tell tell you that the problem is definitely a government issue.

They all use the same book of rules, but no two will "interpret" them the same. Even though they go to classes specifically designed to identify and prohibit "inspector's personal preferences". And over the past decade, it's increasingly difficult to get any inspector to sign off on anything new. Want a Field Approval? No, spend $$$$ and get a DER to draw up an 8110 instead. And check rides for an initial CFI was the sole province of the FSDO. Now, they're being done by DPE's. They're getting paid more and more, and putting out less than ever. Doling out what used to be FSDO core functions, to designees. I sympathize with the employees though, they waste huge amounts of time on non-productive bureaucratic chores that Washington thinks are needed. Oklahoma City has no say in the matter.

This has led to FSDO shopping, which the FAA is trying to stamp out. There are a few FSDO's that are still operating like they were 30 years ago. That will change as the oldest inspectors retire.

When I talk to the inspectors at the FSDO, they are as mad about it as anybody. They say the new kids in Washington are constantly changing things and making their jobs more difficult.
 

It seems like every time I need something from the FAA the procedure has changed. Even the procedure for contacting an inspector to find out what the procedure is. 

[DRH4249]

On 8/14/2024 at 1:31 PM, Shadrach said:

Imagine if you had already installed it. What a $hit show. Are you supposed to put it up on cinderblocks while you wait?  I’m surprised the FSDO didn’t try to find a workaround. That’s quite an imposition for something that likely has nothing to do with the physical airworthiness of the part.

My A&P and I installed a rebuilt nose truss, pivot truss, NWS control horn and shock link. We found the rebuilt nose truss had a fitment issue while installing it, sent it back got another one, had the parts reassembled and then got the email. Needless to say I was not the most happy person upon opening the email. I sent them a reply email and spoke with Kyle and we have made arrangement for payment for all the time involved. They did pay for all four rebuilt parts to be sent back to them for inspection and new yellow cards for action taken as well as sent back to me second day air after being re inspected. Over all the biggest thing to me is the lost time to finish may F and get it airborne. Kyle and LASAR has been very good to work with and I'm sure at times my tone wasn't great but I really appreciate them doing their best to make it right. We mostly installed all the nose wheel assemblies this past weekend now have to get everything rerigged, again. I can see the light at the end of the tunnel. 

[Shadrach]

5 minutes ago, DRH4249 said:

My A&P and I installed a rebuilt nose truss, pivot truss, NWS control horn and shock link. We found the rebuilt nose truss had a fitment issue while installing it, sent it back got another one, had the parts reassembled and then got the email. Needless to say I was not the most happy person upon opening the email. I sent them a reply email and spoke with Kyle and we have made arrangement for payment for all the time involved. They did pay for all four rebuilt parts to be sent back to them for inspection and new yellow cards for action taken as well as sent back to me second day air after being re inspected. Over all the biggest thing to me is the lost time to finish may F and get it airborne. Kyle and LASAR has been very good to work with and I'm sure at times my tone wasn't great but I really appreciate them doing their best to make it right. We mostly installed all the nose wheel assemblies this past weekend now have to get everything rerigged, again. I can see the light at the end of the tunnel. 

My assumption that this is an FAA issue is just that, an assumption.
However, If it is indeed the case, I’m curious why they needed to inspect every part rather than a sample from the batch. If the parts are defective, then by all means, recall all of the parts and issue refunds or offer replacements inside a specified time frame.
If the parts are not defective and no physical changes/modifications are being made before returning said parts to the customer, then this looks like a bureaucratic goat rope to me…

[Shadrach]

On 8/16/2024 at 5:22 PM, EricJ said:

Not sure what you were replying to, but for us (Part 91) a yellow tag is just an informal method to provide some usually marginally useful information   8130-3s aren't really even required for very much, mostly if you are exporting a part.   They can be useful to the installer to help determine airworthiness, condition, and suitability for installtion, but the installer has to do that with or without any of that paperwork, and the paperwork isn't required.   

For example, if somebody gets some new tires, throws away or loses the paperwork, and they wind up being surplus, if they're the proper tires for your airplane and are in good condition for safe use, there's nothing stopping anyone (including an owner) from installing them on their airplane.    This happens all the time, and usually verification of proper part number, general condition, functional test after installation, etc., is commonly what is done.   We are a bit lucky that we're not as subject to the counterfeit parts problems as the airlines, since we have a small market supported by CBs. 

Years ago I bought a few NOS 10A Klixon switches from an eBay seller. He must have bought a large lot of them because he had over 50 in stock. Several years later my 10A boost pump Klixon switch developed an “auto shut off” after a few minutes in operation. There was no PMA stamp on the original switch nor was there a stamp on the NOS switch. Just the manufacturer and PN. An IA friend told me the NOS switch was a paper weight without an 8130.  I decided to take a text poll of some of the IAs in my contact list (5 IIRC). The majority of the participants (which included an FAA PMI) understood that the switch could be ops checked, installed and the aircraft returned to service. What was surprising was that 2 working IAs believed that a perfectly good, NOS part was a paperweight because traceability and airworthiness was dependent on form 8130. 

 

[1980Mooney]

1 hour ago, DRH4249 said:

My A&P and I installed a rebuilt nose truss, pivot truss, NWS control horn and shock link. We found the rebuilt nose truss had a fitment issue while installing it, sent it back got another one, had the parts reassembled and then got the email. 

What do you mean when you say that the first LASAR rebuilt nose truss had a “fitment issue” requiring you to send it back?  Are you saying that LASAR got the dimensions/ jig alignment wrong during welding?  Or did they send the wrong truss?  

Why would there be a “trial and error” fitment issue? That doesn’t sound like a bureaucratic/paperwork issue.