On Tue, 08 Jul 2003 12:08:22 GMT, Sydney Hoeltzli
wrote in Message-Id:
:

Larry Dighera wrote:

How would the FAA issue an AD against defective parts that lack an
official paper-trail documenting the materials, processes, and
companies involved in their manufacture?

How does the CPSC (or the mfrs) issue a recall against consumer
goods that lack the FAA's mandated paper-trail?

They seem to manage. The companies involved even seem to do
more for the consumer.

Let's take an example. I purchased a baby swing at a garage
sale. A few months later, I was checking the CPSC web site
and saw a recall on what looked like my make and model of swing.
I called the mfr's 800 number given in the recall notice.
They asked me for the product numbers and told me where they
would be marked on the swing. These numbers enabled them to
determine that my swing indeed was involved in the recall.

They then took my name and address and sent me, at no charge,
a kit to modify my swing which IMHO actually did make it a better,
safer, more useable product.

Gosh -- no expensive FAA mandated official paper trail, and this
recall bit still worked.

If the FAA mandated paper-trail from raw material to finished part is
unnecessary, why do you think it was made it a requirement?

Now let's take the pending Superior air parts piston pin AD which
was pending a few years back when we bought our plane. Per engine
log, the relevant part had been installed in my plane during engine
overhaul 7 years ago. But for various reasons, I had my doubts.

I called the engine overhauler, who by FAA mandate is required to
maintain a paper trail, and asked about the overhaul records. They
weren't very willing to talk to me, and finally allowed as how the
FAA only requires the records to be kept for 3 yrs so those records
were gone. (They claimed flood damage after a hurricaine. FL company.
Maybe).

Here's the punch line: when one of the cylinders was pulled due to
a valve problem, *the piston pin which came out was made by an entirely
different manufacturer*. Since then we've lost 2 more cylinders
(Nuchrome Cermicrap), and each one has a different piston pin.

Once bitten by such a lack of records, an aircraft owner soon learns
to obtain copies of repair records AT THE TIME OF INSTALLATION, and
files them with the aircraft log books. The IA is required by FAA to
document all the parts used.

Wow, that FAA mandated paper trail really helped me out, heh heh.

If you (or the previous owner of your airplane) had kept a record of
the parts installed, it would have been possible for you to KNOW if
they were among those that were recalled. I fail to see how your
failure to keep a copy of the records reflects poorly on the FAA
mandated record keeping practices.