337 for interior plastic

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

The company making the plastic vent is the same company who is making
the headliners. They hold a PMA for the headliner, so I assume they are
familiar with the FAA requirements for plastic interior stuff.

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.


every airplane, even one just off the line. jet or piston.


I agree completely. But, rather than use that as permission, I had a
slightly different take on it. In reality, the bigger chance of "gotcha"
is during an annual with a new wrench rather than a ramp check. The
mechanic's ticket depends on them avoiding Insurance company violations,
FAA scrutiny, and unpleasant events like crashes. They will be LOOKING
for unsafe stuff. Now, whether they also get picky about regulatory
minutia depends on the wrench and their mood that day.

So, I figure that the fewer things that are stretching the limits of the
rules (including non safety issues), the better the chance you have of
emerging with your annual signed off unscathed.

Yes, it seems intuitive that the rules were made to promote safety. But
the "pencil whip" rules have no less effect in the eyes of some IAs and
FAA folks. If you are unfortunate enough to get one of these on a bad
day, the outcome is the same (bad for you).

I think we all agree that breaking the rules that keep us safe is
something to be avoided. What is the difference between safety and
seemingly cosmetic rules designed to trip you up? THAT is the big question.

Good Luck,
Mike

Google on HED231 or go to www.trumeter.net. Last I was in contact with
them, they had a retail outlet in Florida, but the mechanisms themselves are
made in Thailand and exported by a UK company.

Jim





"Gene Kearns" wrote in message
...
On Thu, 17 Nov 2005 08:46:35 -0800, "RST Engineering"
wrote:

Sorry. I forgot my full sig line:

Jim Weir
Commercial Airplane/Glider Instrument CFI Airplane/Glider
A&P IA
Owner C-120 N2014V, C-170 N4190V, C-172 N3618S, C-182 N73CQ


Ok, then, let's check your memory......

you wrote an article a few years back about building a digital (I
think) clock. One of the guys I work with wants to build one for his
RV-4..... but Radio Shack no longer carries the "clock board." Is
there still an affordable board that can be substituted in this
application? I forgot and left the article and specs at work, but I
can get them if necessary.....
--

Homepage
http://myworkshop.idleplay.net/

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`.#####.'
/`#_#'\
O' O `O

bigger reality
Expect changes in 14CFR Part 43 that will allow many more "field
repairs/modifications" without going through the major DER/337/fieldapproval
bushwa that we are going through at the present time.

/bigger reality

Jim



reality
Expect changes in 14 CFR Part 43 that will put major restrictions on
"Preventive Maintenance" unless you have been formally trained in
same.
/reality

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

In reality, the bigger chance of "gotcha"
is during an annual with a new wrench rather than a ramp check.

Correct. Practically the only chance, in fact, unless you decide to
take your airplane to the FSDO. And there is a solution. Don't allow
random mechanics (those that don't come without a personal
recommendation) to annual your airplane. Ever.

What happened with Jay Honeck's strobes is a perfect example of how bad
an idea that is. He had a Form 337, all signed and legal. It wasn't
good enough. Nothing ever is, if you get the wrong mechanic.

Michael