I have a question for the A&P/A&I's out there.
Can I make a bushing for a flap and install it on a certified plane?
How about a bushing on my landing gear.
I can't find the reg that I'm looking for and would like to find it if someone knows where to look.
It seems like I can but not sure of what?
Have looked?
Thanks In Advance
GT

In general that rule is supposed to provide relief for owners that are unable to procure parts for their airplane, i.e. They don't make 'em anymore! If a part is readily available one should go through regular channels.

To answer your question more directly yes, you may make parts. Someone with more patience will find the reference hopefully but the gist is you, the aircraft owner, can fabricate a part that you are able to prove is as good or better than the original. Most common examples would be formed sheet metal bits of a known alloy that matches the original.

Many have been known to take this a step further and authorize a third party to fabricate parts and install them, like a warbird shop, or Kenmore Air.

Again tho, if Univair has the bushings and the Feds ever ask why you didn't get them there well...


Sent from my iPad using Tapatalk

Yo GT, Mike Busch did a EAA webinar all about owner produced parts. It is really good and I think anyone that is thinking about making a parts should watch it.

The gist; you can make whatever part you want as long as you follow some simple steps and your IA is willing to install it.

FAR 21.303 (b) (2) is what you are looking for.

Here is an interesting read from some time ago on the subject;



"I" versus "We"


by Bill O'Brien

Along with the pilot shortage and the mechanic shortage, there is also a parts shortage that plagues the general aviation industry. Because supply and demand are out of balance the cost of new and used parts seem to increase every day. Let's examine the reasons why this is so.

First, we have an old fleet. The average general aviation (GA) single engine airplane is approximately 32 years old. The average age of GA multi-engine reciprocating aircraft is close to 27 years old. The average age for the turbine powered multi-engine propeller driven aircraft average out around 19 years of age. So because of long term wear and tear the demand for replacement parts and large sub-assemblies is much greater today than it was even 10 years ago.

The second reason is our general aviation fleet has been well maintained over the years. So well maintained in fact, the average GA aircraft with a mid-time engine and decent avionics has appreciated to two or three times its original purchase price and is still climbing. Yet even in that land of many zeros the older aircraft are still substantially lower in price than the cost of a brand new aircraft with similar performance numbers and equipment. So the value of older aircraft in good shape are proven investments that over time have beaten the DOW JONES average. So we have an economic imperative on the part of the owners to keep maintaining older aircraft in flying condition which increases the demand for replacement parts.

The third reason is the increasing production costs to make a part. Today aircraft manufacturers are not making makes and models of aircraft in the same quantity they made them back in the Seventies. So the production runs for parts are not as frequent and not as many parts are produced. In addition, it is not cost effective for a manufacturer to make a lot of parts even if the unit price for each part is out of this world because taxes on maintaining a large inventory of parts would eat all of the profits. This low parts production keeps the supply of replacement parts low.

The fourth reason is that some manufacturers would prefer that their older makes and model aircraft-made a million years ago-would quietly disappear from the aircraft registry. This retroactive birth control on the part of the manufacturers may seem not to make any sense until you look at aircraft market dynamics of creating demand and reducing costs. First, each older aircraft that is no longer in service creates a demand for a new, more expensive aircraft to take its place. Second, despite some tort claim relief granted to GA manufacturers in the early Nineties, the fewer older aircraft there are in service, the manufacturers of those aircraft enjoy reduced overall liability claims and ever decreasing continuing airworthiness responsibilities.

So how are we going to maintain these older aircraft with an ever dwindling parts supply when Part 21, section 21.303 Replacement and modification of parts, requires us to use the Parts Manufactured Approval (PMA) parts on a type certificated product? Well, the same rule grants four exemptions to the PMA requirement.

1. You can use parts produced under a type or production certificate such as a Piper, Cessna, or Mooney produced part;

2. A owner or operator produced part to maintain or alter their own product;

3. Parts produced under a Technical Standard Order (TSO) such as radios, life vests and rafts, and GPS; or,

4. A standard aviation part such as fasteners, washers, or safety wire.

Before I segue into the subject of "owner produced parts" as called out in section 21.303, which is the purpose of this article. I would like to create a small uproar with this statement: "FAA Airframe and Powerplant rated mechanics can maintain, repair, and modify parts, but they cannot make a brand new part and call it a repair." Before you accuse me of losing dendrites by the minute, check out section 65.81 General privileges and limitations. The section talks about maintenance, preventive maintenance, and alterations, but not the manufacturing of parts. Nor is it an implied privilege in Part 65, because Part 21 section 21.303 says "no person" may make a replacement part for a type certificated (TC) product unless that person has a PMA, etc.

While I write this I can remember 25 pounds ago and when I had hair, I worked in the real world and I specialized in making engine baffles for Lycoming engines. Before someone accuses me of bureaucratic ventriloquism which is roughly translated as "talking out of both sides of my mouth." My weak defense is, I made the parts because I thought I could." It never dawned on me that I could not legally make a part. Some of you may be astounded that I make this confession freely. It's no big thing because I know the statue of limitations has run out years ago and a jury of my peers would never look me in the eye and convict me.

So here is our problem that we must solve. Since mechanics cannot legally make parts for aircraft and aircraft need replacement parts, how are we going to keep the fleet flying? If we cannot find PMA, TSO, standard, or production holder replacement parts, we are left to make the part under the owner-produced option under section 21.303(b)(2). However, we must remember that the part is for the owner/operator's aircraft only and is not manufactured for sale to other TC aircraft.

To get through confusing regulatory policy with our pride intact, let's try the question and answer routine. (Note: This policy is taken from FAA 's AGC-200 policy memorandum to AFS-300 on the definition of "Owner-Produced Parts" dated August 5, 1993)

Question 1: Does the owner have to manufacture the part him or herself in order to meet the intent of the rule?

Answer 1: No, the owner does not have to make the part him or herself. However to be considered a producer of the part he/she must have participated in controlling the design, manufacturer, or quality of the part such as:

1. provide the manufacturer with the design or performance data from which to make the part, or

2. provide the manufacturer with the materials to make the part, or

3. provide the manufacturer with fabrication processes or assembly methods to make the part, or

4. provide the quality control procedures to make the part, or

5. personally supervised the manufacturer of the part.

Question 2: Can the owner contract out for the manufacture of the part and still have a part that is considered "owner-produced?"

Answer 2: Yes, as long as the owner participated in one of the five functions listed in Answer 1.

Question 3: Can the owner contract out the manufacture of the part to a non-certificated person and still have a part that is considered "owner-produced?"

Answer 3: Yes, as long as the owner participated in one of the five functions listed in Answer 1.

Question 4: If a mechanic manufactured parts for an owner, is he/she considered in violation of section 21.303(b)(2)?

Answer 4: The answer would be no, if it was found that the owner participated in controlling the design, manufacture, or quality of the part. The mechanic would be considered the producer and would not be in violation of section 21.303(a). On the other hand, if the owner did not play a part in controlling the design, manufacture, or quality of the part, the mechanic runs a good chance of being in violation of section 21.303 (b)(2).

Question 5: What kind of advice can you give on how a mechanic can avoid even the appearance of violating section 21.303(b)(2)?

Answer 5: First, a mechanic should never make a logbook or maintenance entry saying that he/she made a part under his certificate number. This foopah will send up a flare and get you undue attention from your local FAA inspector, which you could do without. However, the mechanic can say on the work order that he helped manufacture an owner-produced part under section 21.303 (b)(2).

Second, the owner or operator should be encouraged to make a log book entry that is similar to section 43.9 maintenance entry that states: The part is identified as an owner produced part under section 21.303 (b)(2). The part was manufactured in accordance with approved data. The owner/operator's participation in the manufacturer of the part is identified, such as quality control. The owner must declare that the part is airworthy and sign and date the entry.

Question 6: Is there anything else a mechanic must do?

Answer 6: The mechanic must ensure that the owner-produced part meets form, fit, and function, and, within reasonable limits, ensure that the part does meet its approved type design (e.g. like looking at the approved data used to make the part). Then the mechanic installs the part on the aircraft, makes an operational check if applicable, and signs off the required section 43.9 maintenance entry.

Question 7: What is the owner responsible for and what is the mechanic responsible for concerning owner-produced parts?

Answer 7: The owner is responsible for the part meeting type design and being in a condition for safe operation. The mechanic is responsible for the installation of the owner-produced part being correct and airworthy and for a maintenance record of the installation of the part made.


Question 8: How does the owner or operator get the approved data to make a part if the manufacturer and other sources are no longer in business?

Answer 8: For aircraft that the manufacturer is no longer supporting the continuing airworthiness of, the owner or operator can petition the FAA Aircraft Certification Directorate under the Freedom of Information Act for the data on how the part was made. Or the owner or operator can reverse engineer the part and have the data approved under a FAA field approval or, if it is a really complicated part, have the data approved by a FAA engineer or FAA Designated Engineering Representative.

Question 9: What happens to the owner-produced part on the aircraft if the original owner sells the aircraft?

Answer 9: Unless the part is no longer airworthy, the original owner-produced part stays on the aircraft.

I hope that I spread some light on the murky subject of owner-produced parts, so the next time instead of saying to the owner of an broke aircraft: "Sure, 'I' can make that part," you will now say "Sure, 'WE' can make that part."




--------------------------------------------------------------------------------
Bill O'Brien is an Airworthiness Aviation Safety Inspector in FAA's Flight Standards Service. This article also appeared in the Aircraft Maintenance Technology magazine.


--------------------------------------------------------------------------------

Another Option

Repaired IAW AS-43-1A. Or later version.

Repaired In Accordance With

Title 14 of the Code of Federal Regulations part 43, section 43.13(xx) states.....

Repaired In Accordance to Cessna C-xxx Repair Manual.

Have heard old stories of "repairing" and old rag and tube plane with little more than a Data Plate and some exquisite literary skills.

M6RV6 wrote:I have a question for the A&P/A&I's out there.
Can I make a bushing for a flap and install it on a certified plane?
How about a bushing on my landing gear.
I can't find the reg that I'm looking for and would like to find it if someone knows where to look.
It seems like I can but not sure of what?
Have looked?
Thanks In Advance
GT

I'm not an A/P or IA, but:

Owner produced parts

The FAA permits the aircraft owner or operator to produce replacement parts from scratch (using the original as a template and using the same dimensions and materials), and document it in the logbooks as an "owner-produced part" in accordance with FAR §21.303(b)(4).In doing this, the owner could enlist the aid of an A&P, a machine shop, or anyone certified or uncertified personnel and the part would still qualify as an owner-produced part. This ability is granted by the FAA to aircraft owners/operators, so long as the parts they produce are for installation on their own aircraft and not for sale or for installation on an aircraft they do not own (which would require PMA approval instead).[8] All owner-produced parts must still be considered airworthy, by conforming to the aircraft's type design. An A&P that agrees the owner-produced part is airworthy and that the installation is a considered a "minor repair" can approve the aircraft for return to service.

The FAA will consider a part to be owner-produced (and therefore legal) if the owner is meaningfully involved in its production in any of the following ways:

Provides the specifications or the part to be duplicated;
Provides the materials to make the part;
Provides manufacturing techniques or assembly methods;
Provides quality assurance; or
Supervises the manufacture of the part.

From 8110 42C: d.
Aircraft Owners or Operators.
Owners and operators may produce parts for installation on their own product without a PMA. The installation of these parts must comply
with applicable airworthiness standards. If an owner or operator intends to sell a part for installation on another owner’s aircraft, then
that owner or operator requires a PMA.

And, the specific FAR:

Federal Aviation Administration, DOT
§ 21.303
§ 21.303 Replacement and modification
parts.
(a) Except as provided in paragraph
(b) of this section, no person may
produce a modification or replacement
part for sale for installation on a type
certificated product unless it is pro-
duced pursuant to a Parts Manufac-
turer Approval issued under this sub-
part.
(b) This section does not apply to the
following:
(1) Parts produced under a type or
production certificate.
(2) Parts produced by an owner or op-
erator for maintaining or altering his
own product.
(3) Parts produced under an FAA
Technical Standard Order.
(4) Standard parts (such as bolts and
nuts) conforming to established indus-
try or U.S. specifications.

But, be careful out there.....

MTV

MTV

Twice in your post above the term PRODUCT is used where I would expect aircraft or airplane.

Any explanation or definition for PRODUCT?

Like you said: "Be careful out there."

FAA and their funny words...
https://www.law.cornell.edu/cfr/text/14/21.1

" Product means an aircraft, aircraft engine, or propeller; "

Thanks All
GT

Whee

Thanks a bunch for finding that. Even so I still stumbled a bit over mixing the term document and (article) in the same section. Ahh - but they solved that for me/us in the next line. I have always considered an ARTICLE to be a written document. Only took one of my dictionaries to see Definition-1 was ITEM, as in an item of clothing.

Found PRODUCT down at #6.

Trim

FWIW, my first encounter with the "owner produced part" issue was caused by my disappointment at the anemic heater on my airplane, the first winter after I'd bought it. At +20F ambient, I was cold with a light jacket on. I was cold with a heavy jacket on. I was just plain COLD! So I had this wacko idea that maybe a gas heater was the answer. My IA, who is mucho smarter than I am in the airplane business, discouraged me from thinking "gas heater". He looked at the way the heat muff's air was distributed, and said, "we can do better".

Long story short, he and I redesigned the heat distribution box, which he then built, so that more heat could be funneled to the cabin, and still plenty of heat to the carburetor when necessary. The result has been that as long as the cowl flaps are closed, the heater is efficient enough to keep the cabin light jacket warm down to about -20F, a magnificent improvement. With the cowl flaps open, it's still anemic but passable.

I should add that my IA is a wizard with sheet metal; not all mechanics are. What he creates looks like OEM items.

Cary

So, can this be tied in with our non STC'D avionics discussion? If I were to write up a quality control document and ship it to say dynon, and they ship me a product that meets my QC but is not certified for my aircraft, can I install it?

Good point!

Cary wrote:FWIW, my first encounter with the "owner produced part" issue was caused by my disappointment at the anemic heater on my airplane, the first winter after I'd bought it. At +20F ambient, I was cold with a light jacket on. I was cold with a heavy jacket on. I was just plain COLD! So I had this wacko idea that maybe a gas heater was the answer. My IA, who is mucho smarter than I am in the airplane business, discouraged me from thinking "gas heater". He looked at the way the heat muff's air was distributed, and said, "we can do better".

Long story short, he and I redesigned the heat distribution box, which he then built, so that more heat could be funneled to the cabin, and still plenty of heat to the carburetor when necessary. The result has been that as long as the cowl flaps are closed, the heater is efficient enough to keep the cabin light jacket warm down to about -20F, a magnificent improvement. With the cowl flaps open, it's still anemic but passable.

I should add that my IA is a wizard with sheet metal; not all mechanics are. What he creates looks like OEM items.

Cary

Cary,

What you describe does NOT fit the category of "Owner produced parts". Note in the above descriptions that the owner produced part must precisely duplicate the OEM part.....no modifications allowed.

As I said, be careful out there, and read ALL the verbiage on this topic.

MTV

The beginning of being careful for what you do is to start by looking at the current regulations. The defining regulation that provides the text for owner produced parts is no longer 21.303. I copied the current version of 21.303 below for reference. The regulation that now incorporates owner produced parts is 21.9, "Replacement and Modification Articles," also copied below. Another good official FAA resource is advisory circular 20-62.

The best place to search all of this information is specifically www.faa.gov and not google since it can bring up dated reg's. This was all changed in 2011 I believe. The concept is similar but the actual reg's to reference are different. Also remember that AC43.13-1B&-2B are now considered approved data so it is a valuable resource to reference for producing owner produced parts and it does not require the use of a DER.


Current 21.9
§21.9 Replacement and modification articles.
(a) If a person knows, or should know, that a replacement or modification article is reasonably likely to be installed on a type-certificated product, the person may not produce that article unless it is—
(1) Produced under a type certificate;
(2) Produced under an FAA production approval;
(3) A standard part (such as a nut or bolt) manufactured in compliance with a government or established industry specification;
(4) A commercial part as defined in §21.1 of this part;
(5) Produced by an owner or operator for maintaining or altering that owner or operator's product; or
(6) Fabricated by an appropriately rated certificate holder with a quality system, and consumed in the repair or alteration of a product or article in accordance with part 43 of this chapter.
(b) Except as provided in paragraphs (a)(1) through (a)(2) of this section, a person who produces a replacement or modification article for sale may not represent that part as suitable for installation on a type-certificated product.
(c) Except as provided in paragraphs (a)(1) through (a)(2) of this section, a person may not sell or represent an article as suitable for installation on an aircraft type-certificated under §§21.25(a)(2) or 21.27 unless that article—
(1) Was declared surplus by the U.S. Armed Forces, and
(2) Was intended for use on that aircraft model by the U.S. Armed Forces.

Current 21.303
§21.303 Application.
(a) The applicant for a PMA must apply in a form and manner prescribed by the FAA, and include the following:
(1) The identity of the product on which the article is to be installed.
(2) The name and address of the manufacturing facilities at which these articles are to be manufactured.
(3) The design of the article, which consists of—
(i) Drawings and specifications necessary to show the configuration of the article; and
(ii) Information on dimensions, materials, and processes necessary to define the structural strength of the article.
(4) Test reports and computations necessary to show that the design of the article meets the airworthiness requirements of this subchapter. The test reports and computations must be applicable to the product on which the article is to be installed, unless the applicant shows that the design of the article is identical to the design of a article that is covered under a type certificate. If the design of the article was obtained by a licensing agreement, the applicant must provide evidence of that agreement.
(5) An applicant for a PMA based on test reports and computations must provide a statement certifying that the applicant has complied with the airworthiness requirements of this subchapter.
(b) Each applicant for a PMA must make all inspections and tests necessary to determine—
(1) Compliance with the applicable airworthiness requirements;
(2) That materials conform to the specifications in the design;
(3) That the article conforms to its approved design; and
(4) That the manufacturing processes, construction, and assembly conform to those specified in the design.

mtv wrote:

Cary wrote:FWIW, my first encounter with the "owner produced part" issue was caused by my disappointment at the anemic heater on my airplane, the first winter after I'd bought it. At +20F ambient, I was cold with a light jacket on. I was cold with a heavy jacket on. I was just plain COLD! So I had this wacko idea that maybe a gas heater was the answer. My IA, who is mucho smarter than I am in the airplane business, discouraged me from thinking "gas heater". He looked at the way the heat muff's air was distributed, and said, "we can do better".

Long story short, he and I redesigned the heat distribution box, which he then built, so that more heat could be funneled to the cabin, and still plenty of heat to the carburetor when necessary. The result has been that as long as the cowl flaps are closed, the heater is efficient enough to keep the cabin light jacket warm down to about -20F, a magnificent improvement. With the cowl flaps open, it's still anemic but passable.

I should add that my IA is a wizard with sheet metal; not all mechanics are. What he creates looks like OEM items.

Cary

Cary,

What you describe does NOT fit the category of "Owner produced parts". Note in the above descriptions that the owner produced part must precisely duplicate the OEM part.....no modifications allowed.

As I said, be careful out there, and read ALL the verbiage on this topic.

MTV

Where does it state it must be a duplicate? It says "5)produced by and owner or operator for maintaining or altering that owner or operators product" that leads me to think that as long as it is airworthy, there can be some alteration.

There is nothing that says it has to be a duplicate but it makes the MOC of similarity a no brainer.

Owners have access to a significant amount of approved data in ac43.13 but very few people utilize it or understand how to apply it.

We as DERs were grateful when they stamped it as approved data and we use it as a valuable resource for projects with the FAA.

The cool part you as the owner can use it in the same capacity. However you need to understand the bounds and how it applies to what you are trying to accomplish.

A1Skinner wrote:So, can this be tied in with our non STC'D avionics discussion? If I were to write up a quality control document and ship it to say dynon, and they ship me a product that meets my QC but is not certified for my aircraft, can I install it?

As I recall, you're in BC.
Does Transport Canada have a similar policy statement as the FAA one that has been mentioned on the electronic flight display thread?
And what about the "owner maintenance" category?

A1Skinner wrote:

mtv wrote:

Cary wrote:FWIW, my first encounter with the "owner produced part" issue was caused by my disappointment at the anemic heater on my airplane, the first winter after I'd bought it. At +20F ambient, I was cold with a light jacket on. I was cold with a heavy jacket on. I was just plain COLD! So I had this wacko idea that maybe a gas heater was the answer. My IA, who is mucho smarter than I am in the airplane business, discouraged me from thinking "gas heater". He looked at the way the heat muff's air was distributed, and said, "we can do better".

Long story short, he and I redesigned the heat distribution box, which he then built, so that more heat could be funneled to the cabin, and still plenty of heat to the carburetor when necessary. The result has been that as long as the cowl flaps are closed, the heater is efficient enough to keep the cabin light jacket warm down to about -20F, a magnificent improvement. With the cowl flaps open, it's still anemic but passable.

I should add that my IA is a wizard with sheet metal; not all mechanics are. What he creates looks like OEM items.

Cary

Cary,

What you describe does NOT fit the category of "Owner produced parts". Note in the above descriptions that the owner produced part must precisely duplicate the OEM part.....no modifications allowed.

As I said, be careful out there, and read ALL the verbiage on this topic.

MTV

Where does it state it must be a duplicate? It says "5)produced by and owner or operator for maintaining or altering that owner or operators product" that leads me to think that as long as it is airworthy, there can be some alteration.

If you MODIFY your "article" (aircraft), that's a whole different kettle of fish. And, from the FAA:

From 8110 42C: d.
Aircraft Owners or Operators.
Owners and operators may produce parts for installation on their own product without a PMA. The installation of these parts must comply
with applicable airworthiness standards.

I would assume that if it isn't part of the original design or STC'd, that it would not comply with the airworthiness standards......

Assumptions only, but as I noted, be VERY careful here. The FAA is notorious for having some "interesting" interpretations, which seem to vary wildly between offices.

MTV

FWIW, my IA is a stickler for complying with "the rules", so I'm confident that he knew what he was doing in this case. In many other situations with my airplane, he has had to get 337s approved, because my airplane is often not included on STC AMLs, since so few of the model were made. He has a pretty good relationship with the overseers at the Denver FAA office, and other than some time consumption, there haven't been any difficulties through the years. Typically delays are caused by absences--someone is on vacation, and nobody wants to sign off in the interim until the vacationer has returned. For instance, we're waiting right now for a 337 approval for a Horizon tach (the OEM tach bellied up on the way home from OSH). It's STC'd for a stock P172D, but not for the P172D with the Avcon conversion. If it were up to me, I'd just say "install it", but he's too picky to do that.

Cary