AD's & SB's (Split from: Proposed Wing AD (NOT!)

[minton]

I am only chimming in on this because:

General aviation has for all these years NEVER been required to serialize their parts except for engine case, prop and airframe (fuselage). This has and will continue to cause major tracking/tracing issues that cause the manufactures' and FAA to have to issue "Blanket" inspection requirements. How could anyone with any certainty know whether wings, lift struts, tail feathers or any other bolt on part to be original to the airframe. (No serial numbers and in most cases no part numbers).

This causes issues to surface:

How can anyone establish the time in service on any given part? For the most part in GA you can't without a log book/Data plate specifically assigned to that part.

With only three logbooks and only a few other ID's assigned to most light aircraft, tracing origins and times on GA parts is impossible.

There are many airframe parts that accumulate stress. Wings, lift struts, carry thru spars, landing gear, ETC, ETC. Yet are not required to be tracked.

The Canadians have a better system given these circumstances. They just life limit (Either time or calendar) the whole airframe/engine/prop in alot of cases. Guess where those planes and parts end up?? The USofA!!

The last issue is that GA for the most part is treated as the "bastard child". Requiring blanket anything is very costly to us as a group. In very few cases does the MFG pick up the cost for at least the parts.

GA is broken and with every "Patch" it gets worse. The FAA has for the most part left GA on it's own. Except when things go wrong and then all hell breaks loose and usually lands in the deep pockets. The only issue is they go through your and my pockets on the way to resolution.

This has caused the product liability and personal insurance costs to go out of sight and all manner of recertification requirements.

So, When you screw yourselves into the ceiling over these AD's and service bulletins, remember who brought them to your door step. Our friendly FAA who is not happy til we're not happy

[voorheesh]

I am not sure where this post is coming from but here is my 2 cents. First of all, the components such as wings and struts do have to be tracked. We are supposed to keep maintenance records for our aircraft regardless of which country we operate in. If I change a wing for example, there should be a record of when I did it and where the new wing came from. The whole concept of airworthiness is based on trust that pilots and mechanics who have taken the trouble to become "certificated" maintain "certificated" products and record their actions so that future pilots and mechanics will know the status and history of these as they deal with them down the road. Unless I am missing something, it seems that the rules we live under rely almost entirely on voluntary compliance and perhaps a mistaken assumption that aviators are an honest and intelligent bunch.
My Cessna 170 is turning 60 on January 19, 2010. I have owned it for about 8 of those years and I have maintenance records back to its test flight but with some fairly large gaps. I had to really go through this old airplane to verify it was safe and I can only assume that the wings and struts are the ones that left the factory back in 1950 because there is no record to indicate otherwise. I did find many bogus components in that airplane that had to be replaced and there was no record anywhere to tell me where they came from either. Surprise. The airplane is now my responsibility and I am not bothered in the least by the prospect of having to make inspections and spend money from time to time to make sure it continues to be safe. As I listen to pilots and read posts on the internet, I regularly hear talk about using parts that are not certificated and boasts of "beating the system". It really makes me wonder about ever buying a used airplane again.
Regarding ADs. With the exception of emergency ADs, all have to be published in advance and the "public" is entitled to make responses as to whether or not they should be enacted. The FAA has to consider every comment from the public and provide a written analysis. Once an AD is final, it has the weight of a regulation. I kind of like ADs because I believe that more often than not, they are based on legitimate in service data and they save lives. There are no cops coming around forcing us to comply with the AD. Compliance is entirely up to us. Does anyone out there have a better idea for how to deal with this issue?

[minton]

Haven't seen one yet that has attempted to really track their parts. About all I see is documented removal/replacements, not where the new or old part came from or ended up. Thats where the problems begin. And that is why the system is broken. AD's are what we are left with. Doing the best with what we have to work with. 135 / 121 somewhat better. Go online @ Ebay/Barnstormers or our own "Trade Mart" and look at what is for sale. It's EZ to see the problem. Just be careful out there! Ask probing questions when buying used parts.

[GAHorn]

Haven't seen one yet that has attempted to really track their parts. About all I see is documented removal/replacements, not where the new or old part came from or ended up. Thats where the problems begin. And that is why the system is broken. AD's are what we are left with. Doing the best with what we have to work with. 135 / 121 somewhat better. Go online @ Ebay/Barnstormers or our own "Trade Mart" and look at what is for sale. It's EZ to see the problem. Just be careful out there! Ask probing questions when buying used parts.

I am not disparaging "minton's" remarks, or necessarily disagreeing with him.... but only pointing out that: What is being offered "For Sale" ...has virtually nothing to do with what "is being/was-found-to-be-installed" without proper documentation and traceability. It is the installing-repairman who is responsible for documenting the traceability information.

If a baggage door (wing, flaps, etc.) is purchased from the salvage yard to be intalled upon another airplane, the source....all the way back to it's birth....should be documented by the installer and the paper-trail included in the aircraft records.

For example:

bagdoor1.jpg

bagdoor2.jpg

[DWood]

I would have thought you would need a field approval to put a 172 baggage door on a 170?

[GAHorn]

I would have thought you would need a field approval to put a 172 baggage door on a 170?

If you'll "click" on the second jpg you'll be able to ENLARGE it sufficiently to read in the work description that Del Lehmann installed it per an existing STC. He included the parts-tag which also identified the donator-aircraft from which the parts were obtained.

MVC-050S.JPG

Fredricksburg FINISHED.JPG

I tried to get him to re-polish the entire airplane but he said I didn't bring enough beer! (It all matches perfectly now.)

[DWood]

I see that, I just didn'tthink that there was enough demand that someone would go and pursue getting an STC.
AS far as the tag history of the donor aircraft, the supplier where the door came from seems to do a good job of traceability. If someone was to buy a door from a supplier without this discipline, would it then violate an FAR if it was installed on a different airplane?

[GAHorn]

Well, if an AD note came out which applied to certain baggage door-frames from certain Cessnas in a certain serial range due to improper alloys of aluminum....it would certainly go a long ways toward solving the mystery of whether or not my bag door installation had a problem, would it not?

[n2582d]

The whole concept of airworthiness is based on trust that pilots and mechanics who have taken the trouble to become "certificated" maintain "certificated" products and record their actions so that future pilots and mechanics will know the status and history of these as they deal with them down the road. Unless I am missing something, it seems that the rules we live under rely almost entirely on voluntary compliance and perhaps a mistaken assumption that aviators are an honest and intelligent bunch.
... As I listen to pilots and read posts on the internet, I regularly hear talk about using parts that are not certificated and boasts of "beating the system". It really makes me wonder about ever buying a used airplane again.

Now this looks legal--not. Someone ought to turn this guy into the FAA. It's unfortunate that characters like this give credence to "it being a mistaken assumption that aviators are an honest and intelligent bunch." I guess he's twice as honest and intelligent as the ones who bid on this though!

[GAHorn]

Yes, FAA should severely enforce the sales of logbooks and datatags and shut this type operation down.

[DWood]

Well, if an AD note came out which applied to certain baggage door-frames from certain Cessnas in a certain serial range due to improper alloys of aluminum....it would certainly go a long ways toward solving the mystery of whether or not my bag door installation had a problem, would it not?

I am not questioning traceability and I will never question the importance of traceability. The more information about what you have the better. I am just not aware of any "requirement" for traceability of used parts with the exception of items such as engines, etc.

[GAHorn]

Well, if an AD note came out which applied to certain baggage door-frames from certain Cessnas in a certain serial range due to improper alloys of aluminum....it would certainly go a long ways toward solving the mystery of whether or not my bag door installation had a problem, would it not?

I am not questioning traceability and I will never question the importance of traceability. The more information about what you have the better. I am just not aware of any "requirement" for traceability of used parts with the exception of items such as engines, etc.

You might wish to read Advisory Circular #20-62D. It provides references to FARs which apply.
In particular ..."Acceptable Parts. The following parts may be found to be acceptable for installation on a typecertificated
product:
(1) Standard parts (such as nuts and bolts) conforming to an established industry or U.S. specification.
(2) Parts produced by an owner or operator for maintaining or altering their own product and
which are shown to conform with FAA-approved data.
(3) Parts for which inspections and tests have been accomplished by appropriately certificated persons
authorized to determine conformity to FAA-approved design data."

So basically, unless an owner can show that used parts meet the requirements of para (b) (2) or (3) above, then they may not be installed on certificated aircraft. It would behoove an owner to have documentation of that eligibility. (There's a copy in the MX Library.)

[voorheesh]

I should clarify my statement. It has been my experience that aviators are an honest and intelligent bunch. I can say that about almost every friend and aquaintance I have. We are also human and there will always be the few who are dishonest or stupid. There are also others who have lapses of judgement and make mistakes that would normally be out of character. Many of these folks learn from their mistakes and become better persons. What I meant to imply was that the rules we live under assume we are trained and honest. We don't have police in uniform regulating our actions and 99.9% of us regulate ourselves even if we don't always understand or agree with every rule. The FAA spends a very small amount of its energy finding violations if you look at the totality of its mission. For that, we in aviation should be both proud and grateful. Happy new year everyone.

[minton]

I see that this discussion has brought to the surface many issues purtaining to used parts. That was my intent. If you have a AD issued against your a/c and you have to replace some parts be sure to use due diligence in your search for replacements. It's unfortunate that in many cases the responsibility falls on the A&P's shoulders to "certify" the airworthiness of said replacement. As in the baggage door example it is impossible to determine the alloy without a laboratory getting involved.

The original discussion was about a 337 lift strut AD and my reference to accumulated stresses within the end fittings. Used struts are an option for replacement. You can see where I'm going...

One small responce to aviators for the most part being honest. I agree, but I have a few examples sitting in my "Example" pile that disputes that arguement. Ebay is the worst! Be very careful buying from those sellers. Between the newbies that know next to nothing about aircraft hawking their wares and the outright crooks selling to wet behind the ears buyers it's a real mine field.

The FAA doesn't have near the manpower to tackle this issue, but, if the system had been better designed much of this problem would'nt exist.

So, If you have an annual comming up it might behoove you to go through your logs and records some evening and read between the lines. It usually provides some good laughs! But it could also raise some flags

Be careful out there!

Another reason your poor A&P is'nt paid nearly enough.