The International Cessna^® 170 Association

Boy do I feel sheepish, That was a BAAAAAd post. It is AC 43-18 Subject: Fabrication of Aircraft Parts by Maintenance personnel. Dated 3-24-06

Dennis Wolter operates Air Mod in Batavia, Ohio. Last year he wrote a series of articles for CPA on aircraft interior overhaul. I see that this material and some other stuff he wrote for the American Bonanza Society is availabe for free on Air Mod's website: http://www.airmod.com/articles/index.htm. While I don't agree with what he apparently said about owner produced parts there is a lot of good information in these articles.

Dave Clark wrote:...Another issue though is the interpretation of "actively engaged". The Scotsdale office is looking hard at that. I didn't make the refresher course currently going on in Phoenix so I don't have details on what their interpretation is at this point. I know they tried to get a full list of activities for the year from a full time maintenance shop here in AZ when all he put on the renewal form was four annuals and he refused saying he only needed to put down what was necessary for renewal. They backed off. I don't know where they are going with this but it doesn't look good for the part timer.

I think the answer is in the old adage, "Follow the money." Big shops see little guys as taking away business, even when it's the type of business they themselves don't normally perform.
If big business can make life difficult for the little guy, they will. Several ways to make life difficult for the little guys is to require training, records, and qualifications which they cannot afford.
I'm glad to see your local shop refused to play the unnecessary paper-work game.

To Tom Downey A&P-IA,

Tom,
You wrote: "When we reskin a 170 rudder we are replacing an item with a like item which is a minor repair. (no change to design)."

I have discussed this with a few FAA inspectors that would agree, and alot that disagree. I would like to respectfully disagree that reskinning a rudder, even with a new factory skin would qualify as a major repair because;

<FAR 43 Appendix A (b)(1) Airframe Major Repairs. Repairs to the following parts of an airframe and repairs of the following types, involving the strengthening, reinforcing, splicing, and manufacturing of primary structural members OR their replacement, when replacement is by fabrication such as riveting or welding, are airframe major repairs.>

Control surfaces are listed under (b)(1)(ii).

Because of this, any time we replace a part on an item listed here, and that replacement involves riveting, it is a major repair.

Or is it just part replacement if the old is replaced with factory new? Or a Major repair if the structure or means of attachment have been altered ? (Just asking)

c170b53 wrote:Or is it just part replacement if the old is replaced with factory new? Or a Major repair if the structure or means of attachment have been altered ? (Just asking)

Jim, I'd venture that total replacement of a rudder with a factory NEW rudder would qualify as parts replacement and only require an appropriate log/record entry. Re-skinning a rudder is a major repair and in the U.S. requires a Form 337, per FAR 43, Appdx A (b)(1)(ii) as Del pointed out.