FAA legal interpretations re. fabricating parts for maintenance & IA renewal

[Guest]

I have seen posts on various forums and heard discussions that would benefit from the info contained in these responses from the FAA Chief Legal counsel.

The legal counsel trumps the local office.

IA renewal => https://www.faa.gov/about/office_org...rpretation.pdf

fabricating repair parts => https://www.faa.gov/about/office_org...rpretation.pdf

I also attached copies.

Dave R


friedman - (2017) legal interpretation-1.pdf

rhein - (1995) legal interpretation-1.pdf

[N96337]

Good stuff Dave! I've had to shake my head a lot at what people insist needs to be present to make a replacement part, and the things they say that have to be met. Thanks for that info.
John

[lawheelock]

Here is my input on this subject. 1 Bill Obrien OwnerParts.pdf
Also, here is AC_23-27 Subs. parts and mtls for vintage acft.pdf

[Guest]

Here is my input on this subject. [ATTACH]n181216[/ATTACH]
Also, here is [ATTACH]n181217[/ATTACH]

Bill Obrien's article addresses 21.303. However that section has changed since he wrote that and the current 21.303 no longer addresses owner produced parts. The new section 21.9 does allow mechanics to make a part.

I recall that prior to the new section I had to be careful to say I was repairing and part not producing it. Since the regs have changed I can't look up exactly where or why that method worked.

Bill Obrien passed away a few years ago.

[astjp2]

I moved this to the reference section, it is very good info.