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#1
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![]() I'm not sure paranoid has anything to do with it. The question was if there was any reasonable to do with with FAA blessing. Wanting FAA blessing, if possible, is not paranoid in my book. If anything, its helped me gain a better understanding of regulations with regard to non-TSO'd parts. This news group has value to some of us as a forum to share experiences relating to the rather inexact science of airplane ownership. Given an airplane's unique ability to delight, thrill, bankrupt and/or seriously kill you, the discussions are at times rather unique. In terms of a cosmetic parts swap like interior plastic, there is plenty of "gray" area in the rules to spawn a diverse response to many questions. Unlike questions about strictly procedural tasks, like "how do you change wheel bearings in a Bugsmasher 2000", this plastics discussion is less about safety and more about FAA legalities. For those who give advice like "just do it", remember, the jury is forever "out" whenever you yourself do such a thing. At any time, some A&P or FAA inspector on the ramp may tap YOU on the shoulder and say "I don't think so" to the very operation you are recommending to others. Yes, the likelihood of someone KNOWING about some of this stuff may be quite slim. But, we have all read the horror stories of what happens when someone is forced to get a "new" mechanic ("hey, nice interior plastic, where's the paperwork?????"). Remember Jay's wing tip strobe "adventure". To those considering taking the advice they receive here, remember that it is always YOUR safety and YOUR responsibility if something goes wrong. Many who post here do so with a certain zeal that might give the newbie the impression of authority or experience. That may be absolutely true or false. An A&P mechanic may say something that is completely untrue, and the non-credentialed airplane owner may say something that is spot on. Truth is in the eye of the beholder and can be quite fleeting. Again, it is up to the reader to decide. Look for patterns of rational responses. Consider throwing out the top and bottom 10% of responses ("screw the Feds, just do it" and "YOU ARE GONNA DIE MAN!!!!!!!"). Like the weather reports, you may run into serious trouble either completely believing someone, or completely disbelieving them. In the airplane world, if it sounds simple, cheap, or quick, it is likely to prove to be an unwise path. Good Luck, Mike |
#2
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![]() On 19-Nov-2005, Mike Spera wrote: For those who give advice like "just do it", remember, the jury is forever "out" whenever you yourself do such a thing. At any time, some A&P or FAA inspector on the ramp may tap YOU on the shoulder and say "I don't think so" to the very operation you are recommending to others. Yes, the likelihood of someone KNOWING about some of this stuff may be quite slim. But, we have all read the horror stories of what happens when someone is forced to get a "new" mechanic ("hey, nice interior plastic, where's the paperwork?????"). Remember Jay's wing tip strobe "adventure". I think that some common sense is in order here. Remember, the intent of the regs with respect to maintenance is flight safety, not creating a "gotcha" situation. The fact is, application of the rules regarding preventative maintenance (which can be performed by the pilot/owner) leave quite a bit of room for interpretation. Patch a hole in seat upholstery? Sure, no problem. Completely recover the seat? It seems like that would be allowed as "replacing seat parts" but you have to use parts "approved for the aircraft" whatever that is. On the other hand, one could argue that recovering a seat is "repairing upholstery" which is allowed without mention of using approved parts. My take on repair, painting, or even replacement of simple interior plastic pieces is that this falls under the category of "repair" of "decorative furnishings" even if the components in question are involved in cabin ventilation. My thinking is that such maintenance is far less likely to impinge upon safety than, say, performing an oil change, which is certainly allowed. I would hazard a guess that if some anal retentive FAA examiner wanted to, he/she could find at least one maintenance violation in just about any privately owned airplane that is more than a few years old. Here's an example from our Arrow: It came from the factory equipped with cloth curtains that could be used by rear seat passengers to shade the sun. They really don't work very well and are generally a pain in the butt, so we simply removed them. Now, since they comprise maybe a total of two ounces of the "official" empty weight and are part of the airplane as certified, and since there is no mention in the POH that they can be removed if desired, strictly speaking they have to be there for legal flight. My guess is that if we ever get a ramp check we will be given a pass on this one. -- -Elliott Drucker |
#3
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Remember, the intent of
the regs with respect to maintenance is flight safety, not creating a "gotcha" situation. As an A&P, I believe this is absolutely not true. The regs actually make it more difficult to do proper and safe maintenance, and easier to do a shoddy but approved job. The intent of the regs is exactly to create a "gotcha" situation so as to empower an FAA inspector to ground any aircraft at will. The sooner you understand that, the easier it will be to figure out what does and doesn't make sense. I would hazard a guess that if some anal retentive FAA examiner wanted to, he/she could find at least one maintenance violation in just about any privately owned airplane that is more than a few years old. Any airplane that is out of warranty - period. Only reason for the warranty exception is that the factory might fight him on it if the factory is responsible for the repair, and there's some money and clout there. They can bring in people to overrule him. You can't. I've seen it happen. I've seen airplanes grounded for illegible (supposedly) TSO tags on seatbelts and placards curled up at the corner, and the pilots written up for flying those supposedly unairworthy airplanes. The rules are the way they are so feds can do that. Safety doesn't enter into it. Michael |
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