1 Making Part? Eliminating The Confusion! By Don Dodge The Grass Roots Program

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Making Part?Eliminating The Confusion!

Making Part?Eliminating The Confusion!

By Don DodgeBy Don Dodge

The Grass Roots Program

Tel: (803) 765-5931 Tel: (803) 765-5931

EXT.EXT. 145 145

FAX (803) 253-3999FAX (803) 253-3999

[email protected]@faa.

govgov

Don DodgeDon Dodge

South Carolina FAA Flight Standards South Carolina FAA Flight Standards

Airworthiness Aviation Safety Program ManagerAirworthiness Aviation Safety Program Manager

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Making PartsMaking PartsWhy Take On That Liability?Why Take On That Liability?

Making PartsMaking PartsWhy Take On That Liability?Why Take On That Liability?

FACTSFACTS The average age of GA piston single-The average age of GA piston single-

engine aircraft is 32 years old.engine aircraft is 32 years old. The average age of GA piston multi-The average age of GA piston multi-

engine aircraft is 27 years old.engine aircraft is 27 years old. The average age of GA turbine The average age of GA turbine

powered twinpowered twin engine aircraft is 19 years engine aircraft is 19 years old.old.

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Making PartsWhy Do We Do It?

Making PartsWhy Do We Do It?

The aircraft is old, or an orphan.The aircraft is old, or an orphan. No product support. (Or)No product support. (Or) Parts are available, in about 6 months.Parts are available, in about 6 months. We are not going to talk about the price.We are not going to talk about the price.

I can make the part, right?I can make the part, right?

What does the rule say? What does the rule say?

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What does the rule say about me manufacturing parts?

What does the rule say about me manufacturing parts?

M echanic Airfram eFAR 65.85

M echanic Pow erplantFAR 65.87

IAFAR 65.95

Repair S tationFAR 145.51

FAR 65.81, T he privileges and lim itations sections of the rule governing m echanics and FAR 145.51, privileges and lim itiatons of repair stations

do not perm it the m anufacture of parts.

An A&P Technician can maintain, repair An A&P Technician can maintain, repair and modify parts. But an A&P cannot make and modify parts. But an A&P cannot make

a brand new part and call it a repair.a brand new part and call it a repair.

FARFAR

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If I Can’t Make A Approved Part, Who Can?

If I Can’t Make A Approved Part, Who Can?

There are ten ways that There are ten ways that an approved part can be an approved part can be made.made.

PMA PMA TSOTSO TC or STCTC or STC TC with an APISTC with an APIS PCPC

Bilateral AgreementBilateral Agreement Acceptable to the Acceptable to the

AdministratorAdministrator Standard partsStandard parts Parts Produced Per STC Parts Produced Per STC

InstructionsInstructions Owner ProducedOwner Produced

Parts may also be made as part of a repair per FAR 43. (Patch Plate)

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Owner Produced Parts FAR 21.303 (b) 2

Replacement And Modification Parts

Owner Produced Parts FAR 21.303 (b) 2

Replacement And Modification Parts

FAR 21.303 (b) 2, permits an aircraft owner FAR 21.303 (b) 2, permits an aircraft owner or operator to produce parts for maintaining or operator to produce parts for maintaining or altering his own product.or altering his own product.

An Owner Produced Part can only be An Owner Produced Part can only be installed in the aircraft owned or operated installed in the aircraft owned or operated by that person. by that person.

An Owner Produced Part cannot be An Owner Produced Part cannot be produced for sale to others. produced for sale to others.

FARFAR

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Owner Produced Parts? Owner Produced Parts?

How is it that the How is it that the rule allows an rule allows an

aircraft owner or aircraft owner or operator to produce operator to produce parts for his aircraft, parts for his aircraft,

but not an A&P?but not an A&P?

(Simple)(Simple)

The responsibility The responsibility follows the money!follows the money!

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How Does This “Owner Produced Parts” Rule Work?

How Does This “Owner Produced Parts” Rule Work?

The Assistant Chief Counsel for Regulation The Assistant Chief Counsel for Regulation Memorandum dated August 5, 1993.Memorandum dated August 5, 1993.

This memorandumThis memorandum states that a part does not have states that a part does not have to be solely produced by the owner to be considered to be solely produced by the owner to be considered an owner produced part. an owner produced part.

The owner must participate in at least The owner must participate in at least oneone of of fivefive ways for it to be considered an owner ways for it to be considered an owner produced part. produced part.

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The Five Ways to Participate The Five Ways to Participate

1 The owner provides the manufacture The owner provides the manufacture with design or performance data.with design or performance data.

2 The owner provides the manufacture The owner provides the manufacture with materials.with materials.

3 The owner provides the manufacture The owner provides the manufacture with fabrication processes or with fabrication processes or assembly methods.assembly methods.

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4 The owner provides the manufacture The owner provides the manufacture with quality control procedures. with quality control procedures.

5 The owner personally supervises the The owner personally supervises the manufacture of the part.manufacture of the part.

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The memorandum also states that The memorandum also states that the FAA would not construe the the FAA would not construe the

ordering of a part, standing alone, ordering of a part, standing alone, as participating in controlling the as participating in controlling the design, manufacture or quality of design, manufacture or quality of

a part.a part.

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Summary:Summary:

The owner does not need to be The owner does not need to be the sole producer of the part, the sole producer of the part,

but the owner must participate but the owner must participate in its manufacture.in its manufacture.

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Owner Produced Parts? Approved Parts?

Questions?

Owner Produced Parts? Approved Parts?

Questions? The part is an “Owner Produced Part.” Is it also a FAA The part is an “Owner Produced Part.” Is it also a FAA

approved or airworthy part?approved or airworthy part? Can I install it in the owner’s aircraft?Can I install it in the owner’s aircraft?

The Answer:The Answer:

If an “Owner Produced Part” meets all the requirements If an “Owner Produced Part” meets all the requirements of an Approved Part than it is considered a FAA of an Approved Part than it is considered a FAA

Approved Part.Approved Part.

Lets look at the four characteristics of an approved part.Lets look at the four characteristics of an approved part.

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The Four Characteristics of an Approved Part.


Properly designed Properly designed

Properly produced to Properly produced to conform to the designconform to the design

Properly documentedProperly documented

Properly maintained for Properly maintained for as long as it is in serviceas long as it is in service

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Approved PartApproved Part

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1. Properly Designed1. Properly Designed

A properly designed part means A properly designed part means that the parts design is that the parts design is

FAA approved.FAA approved.

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2. Properly Produced2. Properly Produced

Properly produced, means the part is Properly produced, means the part is produced in accordance with a FAA produced in accordance with a FAA

approved design and conforms to approved design and conforms to that design.that design.

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3. Properly Documented3. Properly Documented

Properly documented means that Properly documented means that there is a statement of there is a statement of

conformity by the part producer conformity by the part producer memorializing the parts memorializing the parts

production.production.

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4. Properly Maintained4. Properly Maintained

Properly maintained means that Properly maintained means that the part is maintained in the part is maintained in

accordance with FAR 43 .accordance with FAR 43 .

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Approved Parts?Owner Produced Parts


There are 10 ways that a There are 10 ways that a new part can be produced. new part can be produced.

Remember it does not Remember it does not matter if the part is matter if the part is produced under the produced under the authorization of a PC, authorization of a PC, PMA, TC, or Owner PMA, TC, or Owner Produced, the part must Produced, the part must have all 4 elements of an have all 4 elements of an approved part before it approved part before it

qualifies for installation.qualifies for installation.

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““Summary” Summary” The part may meet the The part may meet the

criteria of an owner criteria of an owner produced part, but if any produced part, but if any of the four elements of an of the four elements of an approved part are missing approved part are missing than the part will not be a than the part will not be a FAA approved part and FAA approved part and

cannot be installed in the cannot be installed in the owners aircraft.owners aircraft.

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Case History Owner Produced? Approved?

Case History Owner Produced? Approved?

Aircraft nose strut was Aircraft nose strut was pitted.pitted.

New strut available for New strut available for $750, used $350.$750, used $350.

Owner had strut Owner had strut locally manufactured.locally manufactured.

Result: strut folded Result: strut folded during first operation during first operation $7500 + damage.$7500 + damage.

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Was This A Owner Produced Part?

Was This A Owner Produced Part?

Yes this was a owner Yes this was a owner produced part.produced part.

The owner did participate The owner did participate in the manufacture.in the manufacture.

The owner supplied the The owner supplied the design for the part. design for the part.

He gave the manufacture the He gave the manufacture the old part and told him to old part and told him to

duplicate it.duplicate it.

Owner Owner Produced Produced

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Was This a FAA Approved Part?


NO! NO! And for the And for the following reasons:following reasons:

The owner did not The owner did not provide the provide the manufacture a FAA manufacture a FAA approved design approved design

The part did not The part did not conform to the FAA conform to the FAA

approved design.approved design.

Did Not Did Not ConformConform

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The owner did not The owner did not document the parts document the parts production in the production in the maintenance records.maintenance records.

The part did not last The part did not last long enough to long enough to worry about worry about

maintenance!maintenance!

NoNoDocumentationDocumentation

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Was The Owner, Or The Technician Held Accountable?

Was The Owner, Or The Technician Held Accountable?

Owner and part’s producerOwner and part’s producer

Far 91.403 Owner is Far 91.403 Owner is

primarily responsible.primarily responsible.

91.407 No person may 91.407 No person may

operate unless operate unless

maintenance record maintenance record

required by 43.9 has required by 43.9 has

been made.been made.

Installing TechnicianInstalling Technician There was no There was no

documentation with the documentation with the part. (SUPS)part. (SUPS)

FAR 43.13 Was not equal FAR 43.13 Was not equal to its original condition.to its original condition.

FAR 43.15 Aircraft did FAR 43.15 Aircraft did not meet all applicable not meet all applicable airworthiness airworthiness requirements. requirements. (Annual Inspection)(Annual Inspection)

The Answer, The Answer, Both!Both!

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Wasteful, Tragic, Dangerous! Wasteful, Tragic, Dangerous!

How could this have been avoided?How could this have been avoided?

What would have been the right thing to do?What would have been the right thing to do?

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Owner Produced PartsIt Can Be Done


Use the manufacture’s design, it will save Use the manufacture’s design, it will save you time, money and maybe someone's life.you time, money and maybe someone's life.

Reverse engineer if you must, but do your Reverse engineer if you must, but do your research, and submit your reversed research, and submit your reversed engineered design to the FAA for approval engineered design to the FAA for approval before producing the partbefore producing the part..

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NOTE!NOTE! When a design is developed by reverse When a design is developed by reverse

engineering from an old or damaged engineering from an old or damaged part, the resulting owner’s design is part, the resulting owner’s design is

not automatically FAA approvednot automatically FAA approved.. Many factors enter into this Many factors enter into this

determination. You should determination. You should alwaysalways consult the local FSDO for guidance. consult the local FSDO for guidance.

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Produce the part to conform to the FAA Produce the part to conform to the FAA approved design. approved design. No more, no less.No more, no less.

Memorialize the production of the part with Memorialize the production of the part with a record entry. The parts Producer (aircraft a record entry. The parts Producer (aircraft owner) should make an entry indicating that owner) should make an entry indicating that the part was produced in accordance with the part was produced in accordance with 21.303 and that it conforms to the original 21.303 and that it conforms to the original manufacture’s approved design.manufacture’s approved design.

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The Owner Can Produce A Part A Maintenance Technician Can’tThe Owner Can Produce A Part A Maintenance Technician Can’t

Owner Produced Part DocumentationOwner Produced Part Documentation

DateDate Total TimeTotal Time Work AccomplishedWork Accomplished

01-01-02 9899.9 hrs. Manufactured new lower nose strut01-01-02 9899.9 hrs. Manufactured new lower nose strut

tube PN# 65280-00. The part wastube PN# 65280-00. The part was

produced per FAR 21.303 (b) 2,produced per FAR 21.303 (b) 2,

(Owner Produced) and the part (Owner Produced) and the part

conforms to the original conforms to the original

manufacture’s design.manufacture’s design.

Ima B. Good PP 123456789Ima B. Good PP 123456789

Aircraft OwnerAircraft Owner

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The Owner Operator and Maintenance Technician Responsibilities

The Owner Operator and Maintenance Technician Responsibilities

The aircraft owner or operator can produce The aircraft owner or operator can produce parts for maintaining or altering his own parts for maintaining or altering his own

product.product.

But!But!The aircraft owner or operator usually cannot The aircraft owner or operator usually cannot

install the part. The maintenance technician install the part. The maintenance technician must do that and The maintenance records must do that and The maintenance records

must reflect this.must reflect this.

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“Responsibility” “Responsibility”

YOU ARE THE GATEKEEPER!YOU ARE THE GATEKEEPER!The responsibility for making the final The responsibility for making the final

determination whether an “Owner determination whether an “Owner Produced Part” has all four elements of a Produced Part” has all four elements of a

FAA approved part and qualifies for FAA approved part and qualifies for installation rests firmly on the shoulders of installation rests firmly on the shoulders of

the maintenance technician. the maintenance technician.

THE RESPONSIBILITY IS YOURS!THE RESPONSIBILITY IS YOURS!

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New Part? Repaired Part?New Part? Repaired Part?

Sometimes the distinction between producing Sometimes the distinction between producing a new part and a repair is hard to determine.a new part and a repair is hard to determine.

The circumstances, complexity of the part and The circumstances, complexity of the part and the availability of data are all determining the availability of data are all determining

factors.factors.

““THE TEST OF RESONABLENESS”THE TEST OF RESONABLENESS”

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The Test Of Reasonableness?The Test Of Reasonableness?

ScenarioScenario An aircraft wing is damaged. The damaged parts An aircraft wing is damaged. The damaged parts

include a rib, stringer and wing skin. The include a rib, stringer and wing skin. The maintenance manual specifies the materials that the maintenance manual specifies the materials that the stringer and wing skin are made of. The maintenance stringer and wing skin are made of. The maintenance technician purchases a new rib from the aircraft technician purchases a new rib from the aircraft manufacture, and fabricates a stringer and wing skin manufacture, and fabricates a stringer and wing skin using the damaged parts as a template and repairs the using the damaged parts as a template and repairs the

wing in accordance with the maintenance manual.wing in accordance with the maintenance manual.

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Is this a repair or did the technician produce Is this a repair or did the technician produce a new part? The stringer and wing skin a new part? The stringer and wing skin

had a manufacture’s part number.had a manufacture’s part number. The parts were simple, the processes The parts were simple, the processes

required to fabricate the parts involved required to fabricate the parts involved common tools, skills and practices.common tools, skills and practices.

Material specifications and data were Material specifications and data were published and available.published and available.

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Template for the reliable reproduction of Template for the reliable reproduction of the part was available. (Design)the part was available. (Design)

Parts were incorporated into a repair in Parts were incorporated into a repair in accordance with the manufacture’s accordance with the manufacture’s manual.manual.

““THE TEST OF REASONABLENESS”THE TEST OF REASONABLENESS”

In this case it would be considered a repair.In this case it would be considered a repair.

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Summary For Making PartsSummary For Making Parts

Under rule, aircraft owners can produce Under rule, aircraft owners can produce new parts for their aircraft, maintenance new parts for their aircraft, maintenance technicians and repair stations can’t.technicians and repair stations can’t.

The aircraft owner must participate in at The aircraft owner must participate in at least (1) of the five ways for a part’s least (1) of the five ways for a part’s manufacture to be considered “Owner manufacture to be considered “Owner Produced”.Produced”.

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An Owner Produced part must have all (4) An Owner Produced part must have all (4) characteristics of an approved part before it characteristics of an approved part before it is considered a FAA approved part and is considered a FAA approved part and eligible for installation.eligible for installation.

The part producer (aircraft owner) should The part producer (aircraft owner) should document in the aircraft records that he document in the aircraft records that he produced the part. (Conformity produced the part. (Conformity Statement)Statement)

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The aircraft owner(part producer) and the The aircraft owner(part producer) and the installing agent (maintenance technician) installing agent (maintenance technician) each have their areas of responsibility under each have their areas of responsibility under rule. rule.

Sometimes the distinction between producing Sometimes the distinction between producing a new part and making a repair is hard to a new part and making a repair is hard to determine. When in doubt call the FSDO.determine. When in doubt call the FSDO.

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Under the rule, Under the rule, YOUYOU are responsible for are responsible for determining if a “Owner Produced Part” has determining if a “Owner Produced Part” has

all the characteristics of an approved part all the characteristics of an approved part before installing it in the owner’s aircraft.before installing it in the owner’s aircraft.

It is up to us to keep unapproved parts out of It is up to us to keep unapproved parts out of the system!the system!

YOU ARE THE GATEKEEPER!

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AnyAnyQuestions???Questions???

Don’t be shy, I know Don’t be shy, I know

you have some!you have some!

FAACT

1958

FAR

FAA

SAFET

Y

P.L..103-272

ThanksThanks for Having Me!!!for Having Me!!!

Don DodgeDon Dodge

Documents

1 Making Part? Eliminating The Confusion! By Don Dodge The Grass Roots Program