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Installation Certification by AD 3
- Thread starter kontiki99
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thruthefence
Aerospace
Is the new part number TSOed?
Is it approved for the application by the OEM?
Is it approved for the application by the OEM?
it sounds to me as though you want to replace a piece of equipment (on a plane that isn't covered by the AD) with the new (AD'd) piece of equipment ?
it's easy to say that if the equipment p/n is installed already then why not. but maybe there are secondary issues involved with the substitution (a different software). maybe ask the OEM why your s/n isn't covered by the AD ? (that sounds like an innocent enough question)
it's easy to say that if the equipment p/n is installed already then why not. but maybe there are secondary issues involved with the substitution (a different software). maybe ask the OEM why your s/n isn't covered by the AD ? (that sounds like an innocent enough question)
- Thread starter
- #4
The proposed AD says you must incorporate a certain manufacturers Service Bulletin (software upgrade) that rolls the P/N of the unit to a new number.
The unit currently currently installed on the aircraft is certified for use on the aircraft by an STC.
The new post mod P/N is not listed on the aircraft's TC and is not listed on any of the STCs that were the original approval basis for their installation.
This particular OEM does obtain FAA TSO approvals for their units.
The unit currently currently installed on the aircraft is certified for use on the aircraft by an STC.
The new post mod P/N is not listed on the aircraft's TC and is not listed on any of the STCs that were the original approval basis for their installation.
This particular OEM does obtain FAA TSO approvals for their units.
- Thread starter
- #5
thruthefence
Aerospace
I would contact the FSDO and the FAA guy listed on the AD as a point of contact, explain the situation, and ask for an AMOC letter. ("Alternate means of compliance"). Make sure you have the SB info & so forth in front of you.
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If your make, model and aircraft serial number is not listed in the AD, then the new part number is not normally eligible for installation. Now, if the OEM feels the new part number is ok for installation on your aircraft, they can make it eligible for installation through the minor change process for the STC. There are other ways to have the new part number added; for example, they can generate a Service Bulletin.
What is the AD number?
What is the AD number?
thruthefence
Aerospace
The STC holder is not normally the OEM.
As I understand the OP, the component was ADDED to the aircraft in question, by the STC process.
I would be surprised if the holder of the STC has not developed a revision to the ICAW to reflect the new,improved version of the component (by p/n)and mod status.
After all, they are now holders of an STC that involves installing a component that has a "drop dead" airworthiness directive on it.
Not much money making potential in that!
As I understand the OP, the component was ADDED to the aircraft in question, by the STC process.
I would be surprised if the holder of the STC has not developed a revision to the ICAW to reflect the new,improved version of the component (by p/n)and mod status.
After all, they are now holders of an STC that involves installing a component that has a "drop dead" airworthiness directive on it.
Not much money making potential in that!
thruthefence, you are correct.
The OEM isn't always the STC holder. Where I said "they" I should have said the STC holder.
I am assuming when you say ICAW, you mean instructions for continued airworthiness (ICA). See FAA Order 8110.54 for further clarification. Regarding installation approval, you should see Title 14 Code of Federal Regulations, part 21 for the requirements for installation eligibility on a type certificated product. Installation eligibilty for an STC holder, not a Production Certificate (PC)holder, requires Part Manufacturing Approval(PMA)for the part number in question. The PMA supplement lists the eligible aircraft models. While ICA should reflect the part numbers as you have indicated, the approval basis is the PMA supplement.
Cheers
The OEM isn't always the STC holder. Where I said "they" I should have said the STC holder.
I am assuming when you say ICAW, you mean instructions for continued airworthiness (ICA). See FAA Order 8110.54 for further clarification. Regarding installation approval, you should see Title 14 Code of Federal Regulations, part 21 for the requirements for installation eligibility on a type certificated product. Installation eligibilty for an STC holder, not a Production Certificate (PC)holder, requires Part Manufacturing Approval(PMA)for the part number in question. The PMA supplement lists the eligible aircraft models. While ICA should reflect the part numbers as you have indicated, the approval basis is the PMA supplement.
Cheers
thruthefence
Aerospace
As The developer of an STC, You do not need a PMA, if you do not manufacture the part. If, for example you wish to install a 100 Amp alternator on a small aircraft that is currently approved, under it's type certificate, for a 60 amp alternator, you merely have to work out the installation to insure the airworthiness of the aircraft is not affected. You source "your" alternator from an approved vendor. They have done the legwork on the approval of the alternator itself. Any bracketry, fittings, or wiring harnesses would in fact have to be PMAed, with attendant traceability on materials, approved drawings, and inspection of the final product. Your job is to design & carry out an installation, that does in fact meet part 21 requirements, among others.
I feel the problem facing the original poster can only be resolved by amending the paperwork issued by the holder of the STC, to approve the installation of the "new, improved" model.
The problem may be the STC holder is no longer available,ie gone out of business, or has "sold" the stc to a another party, Or surrendered it.
I feel the problem facing the original poster can only be resolved by amending the paperwork issued by the holder of the STC, to approve the installation of the "new, improved" model.
The problem may be the STC holder is no longer available,ie gone out of business, or has "sold" the stc to a another party, Or surrendered it.
Interesting perspective.
But, the only acceptable methods for producing parts to be installed on a type certificated product are as follows:
First, it can be an owner produced part (but not sold over the counter). For this, you won't need to produce the part under an FAA approved quality system.
Second, the part is produced and "sold over the counter". The second method requires an FAA approved quality system (AKA a PMA part).
Third method is to produce a TSO'd part and then receive a TSOA ( FAA approval for the part).
Fourth, produce the part under an FAA approved production certificate (PC). This would apply to OEM's such as Cessna, Boeing .......
In a nutshell, if you produce a part for installation on a TC'd product and intend to sell it on the street, you must have some form of FAA approval.
Now, for the original question that started this thread, it seems to me that the person was purchasing the part (not owner produced). Thus, the part will need to be produced under an FAA approved quality system. He indicated that he was unsure of the installation eligibility for a certain aircraft. An AD does not automatically approve parts for installation on aircraft not listed in the AD. He would be well advised to talk to the OEM or STC holder to verify installation eligibilty.
But, the only acceptable methods for producing parts to be installed on a type certificated product are as follows:
First, it can be an owner produced part (but not sold over the counter). For this, you won't need to produce the part under an FAA approved quality system.
Second, the part is produced and "sold over the counter". The second method requires an FAA approved quality system (AKA a PMA part).
Third method is to produce a TSO'd part and then receive a TSOA ( FAA approval for the part).
Fourth, produce the part under an FAA approved production certificate (PC). This would apply to OEM's such as Cessna, Boeing .......
In a nutshell, if you produce a part for installation on a TC'd product and intend to sell it on the street, you must have some form of FAA approval.
Now, for the original question that started this thread, it seems to me that the person was purchasing the part (not owner produced). Thus, the part will need to be produced under an FAA approved quality system. He indicated that he was unsure of the installation eligibility for a certain aircraft. An AD does not automatically approve parts for installation on aircraft not listed in the AD. He would be well advised to talk to the OEM or STC holder to verify installation eligibilty.
thruthefence
Aerospace
We are exactly on the same page.
However, I don't think the OP wants to "manufacture", or certify, a part.
As I understand the OP's question, he has a component, installed under an stc, ie not original, OEM installation.
Let's assume, for the sake of argument, the equipment is a "Whiz-Bang Navmaster 500" PFD, p/n 500-1; a cutting edge product of the giant "Navmaster corp". This model & p/n Navmaster PFD is original equipment, and supported by an OEM (and the vendor, Navmaster) in several models of the oem's Certificated, current production aircraft.
A large avionics shop, "Peckerwood Avionics" sees the popularity & usefulness of the new "Whiz-Bang Navmaster 500", and approaches the vendor (Navmaster corp) for ten ship sets of TSO'ed PDF's, p/n 500-1. Business is business, after all, so the deal is closed. "Peckerwood" puts it's guys to work, for a STCed installation on a "Belchfire Flite-King" a popular, but out of production aircraft. They see a market for replacing the "steam gauges" in this fleet of 5000 "still on the books" aircraft. Peckerwood's engineering dept makes up the drawings, their on staff DER signs off on the changes to the Instrument Panel, it is approved by the Feds, and an STC issued. They sell eight STC'ed installations, and are preparing to order ten more shipsets.........
Then Navmaster issues a mandatory service bulletin. There have been "Ghost images" when operating in the night vision mode, and false altitude readings. They send out SIM cards with software updates,to all operators, but in 15% of the fleet, the errors remain. One aircraft, an OEM installation, has a near-miss due to bad altitude information. The OEM, who has aircraft in production, insists the vendor fix the problem. Lot's of bad publicity affecting sales. The vendor, now decides to recall all units from the field, upgrade some hardware as well as software, re flash the chips, whatever; & rigoriously test the units, and send them back under a new P/N, 500-3........
In the meantime, another Navmaster equipped aircraft, while busting minimums takes out the approach lights at BMF, in a "reportable accident" The NTSB & the FAA are now involved, and after being satisfied Navmaster is on the right track, issue an AD note, requiring the "-3"
Meanwhile times are bad at "Peckerwood" avionics, the crash of '09 has hit them hard. They have laid off half their staff, and worse, they are on COD with the Navmaster Corp!!
The operators with the "Peckerwood STC" are left out in the cold. They can't even pay out-of-pocket for a p/n -3, and legally install it!! The AD note is very specific!
The operators all get together, (one of the operators has a "Blog", "Peckerwood STC sucks") and they retain council, who sues "Peckerwood Avionics".
To Late!! They have declared bankruptcy, and the disgruntled, laid off employees have stolen all the shop equipment and supplies!
And that's why I think the AMOC letter from the Feds, would be a good idea.
Happy New Year, everyone!!
However, I don't think the OP wants to "manufacture", or certify, a part.
As I understand the OP's question, he has a component, installed under an stc, ie not original, OEM installation.
Let's assume, for the sake of argument, the equipment is a "Whiz-Bang Navmaster 500" PFD, p/n 500-1; a cutting edge product of the giant "Navmaster corp". This model & p/n Navmaster PFD is original equipment, and supported by an OEM (and the vendor, Navmaster) in several models of the oem's Certificated, current production aircraft.
A large avionics shop, "Peckerwood Avionics" sees the popularity & usefulness of the new "Whiz-Bang Navmaster 500", and approaches the vendor (Navmaster corp) for ten ship sets of TSO'ed PDF's, p/n 500-1. Business is business, after all, so the deal is closed. "Peckerwood" puts it's guys to work, for a STCed installation on a "Belchfire Flite-King" a popular, but out of production aircraft. They see a market for replacing the "steam gauges" in this fleet of 5000 "still on the books" aircraft. Peckerwood's engineering dept makes up the drawings, their on staff DER signs off on the changes to the Instrument Panel, it is approved by the Feds, and an STC issued. They sell eight STC'ed installations, and are preparing to order ten more shipsets.........
Then Navmaster issues a mandatory service bulletin. There have been "Ghost images" when operating in the night vision mode, and false altitude readings. They send out SIM cards with software updates,to all operators, but in 15% of the fleet, the errors remain. One aircraft, an OEM installation, has a near-miss due to bad altitude information. The OEM, who has aircraft in production, insists the vendor fix the problem. Lot's of bad publicity affecting sales. The vendor, now decides to recall all units from the field, upgrade some hardware as well as software, re flash the chips, whatever; & rigoriously test the units, and send them back under a new P/N, 500-3........
In the meantime, another Navmaster equipped aircraft, while busting minimums takes out the approach lights at BMF, in a "reportable accident" The NTSB & the FAA are now involved, and after being satisfied Navmaster is on the right track, issue an AD note, requiring the "-3"
Meanwhile times are bad at "Peckerwood" avionics, the crash of '09 has hit them hard. They have laid off half their staff, and worse, they are on COD with the Navmaster Corp!!
The operators with the "Peckerwood STC" are left out in the cold. They can't even pay out-of-pocket for a p/n -3, and legally install it!! The AD note is very specific!
The operators all get together, (one of the operators has a "Blog", "Peckerwood STC sucks") and they retain council, who sues "Peckerwood Avionics".
To Late!! They have declared bankruptcy, and the disgruntled, laid off employees have stolen all the shop equipment and supplies!
And that's why I think the AMOC letter from the Feds, would be a good idea.
Happy New Year, everyone!!
... LOL ...
You are probably right on the money....
The only flaw I can see is that the company (Peckerwood) who wants to buy the Navmaster upgrade doesn't have an aircraft model listed in the AD. As such, they can't request an AMOC because the AD doesn't apply to the aircraft in question.
It would appear that Peckerwood is truely up the creek without a paddle. But wait, Peckerwood hires I. R. Smart, a System and Equipment DER. Mr. Smart approaches the FAA and requests a deviation to the original STC. He demonstrates that the upgraded Navmaster is a vast improvement and enhances safety. The folks at "Fed World" are happy, Peckerwood is happy and the aircraft owner flies off into the sunset, knowing he has the safest nav system around.
Cheers
thruthefence
Aerospace
"As such, they can't request an AMOC because the AD doesn't apply to the aircraft in question"
Maybe I'm reading the wrong thing into it, but I "assumed" (you know what that means!) that the AD was against a "component" such as the silly PFD in my example, and not a specific airframe.
Like you, I'd like to know the specific AD number,to comment with a little more clarity.
"aircraft owner flies off into the sunset, knowing he has the safest nav system around."
And this is what we all strive for, for sure!!
Maybe I'm reading the wrong thing into it, but I "assumed" (you know what that means!) that the AD was against a "component" such as the silly PFD in my example, and not a specific airframe.
Like you, I'd like to know the specific AD number,to comment with a little more clarity.
"aircraft owner flies off into the sunset, knowing he has the safest nav system around."
And this is what we all strive for, for sure!!
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- #16
The op isn't giving enough info. What is the effectivity of the AD, by aircraft, or by appliance? If the AD says that the effectivity is component XYZ regardless of aircraft installed on, and to replace component XYZ with component ABC, then the AD is the approved data for the installation and since the AD is a regulation (Part 39), the installation is a minor alteration requiring only a log book entry.
David Schober
A&P, IA, DAR
David Schober
A&P, IA, DAR
Another comment, under 21.303, you only need PMA if the part is produced for SALE for installation on a cetrified aircraft. If you aren't selling the part no PMA is necessary.
Typically a piece of electronic equipment will be TSO, so again, no PMA required since TSO is both a design and production approval.
Typically a piece of electronic equipment will be TSO, so again, no PMA required since TSO is both a design and production approval.
thruthefence
Aerospace
"One other comment, since it looks like the component was installed via STC, under the requirements of Part 21, the STC holder needs to revise the STC to include the new part number in the STC and the ICAs for the STC."
Exactly so.....!
I kinda get the impression that the STC holder isn't cooperating.
Exactly so.....!
I kinda get the impression that the STC holder isn't cooperating.
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