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For those of you who think you can build your own parts....

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  • For those of you who think you can build your own parts....

    Read this.
    N29787
    '41 BC12-65

  • #2
    Re: For those of you who think you can build your own parts....

    That reference seems to be silent on owner produced parts. It seems to be referring to parts produced by "maintenance personell"

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    • #3
      Re: For those of you who think you can build your own parts....

      Who do you think builds and installs those owner produced parts? The owner/operator is involved in the design and manufacture and requests the part to be built but a mechanic needs to install it and sign it off as conforming to type design.

      I was at an IA seminar and a mechanic was violated for building a skin to replace one on a piper landing gear door. They used 21.303b2 as their justification. Signed it off in the logs and flew the airplane.
      21.303b2 is not a blanket approval to build a part, it is for building parts when they are not available. You are not allowed to use the above mentioned reg to build a part because the owner/operator thinks it's too expensive or does not want to wait for the approved part. You need to get the approved part and if it is no longer available, then you can build IAW 21.303b2 and this AC explains what is necessary to be able to approve the part and return the aircraft to service without a violation.
      N29787
      '41 BC12-65

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      • #4
        Re: For those of you who think you can build your own parts....

        Just a question in the case of Taylorcraft does this mean parts from the factory or part manufacturer where do used parts come in to play and how does the FAA look at them there are no factory new parts
        1940 BLT/BC65 N26658 SER#2000

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        • #5
          Re: For those of you who think you can build your own parts....

          Who is trying to "make" parts that are available? I can tell you that ALL of the parts I have made for my plane I would have been FAR ahead buying them from the "factory" (what a joke that is) or from Wag or ASS.
          As for "who" builds them, I DID,.... ALL OF THEM. I am NOT an A&P or IA but I am the owner and work under the supervision of A&Ps and IAs. I have done my best to over comply with the regs by doing all three of the required parts of an OPP. I drew the part from original failed parts or drawings, I did an analysis to insure the material was the correct size and alloy (where applicable), I built the part, performed a QA on it to insure it was correctly built (for this I usually also have an A&P and or IA ALSO check it because the person who makes it is the WORST person to check it). I then install the part and have my mechanic check my work to insure it was done correctly. HE signs it off as built and installed under his supervision, and I am VERY protective of his liability, as we all should be.
          The only complaint I have ever gotten from my mechanics or the local FAA guys is I tend to be a bit anal about compliance and safety. I take that as a compliment (although the rolling eyes tell me it might not have been meant as one). This is also probably one of the big reasons it takes me so long to get my plane back in the air.
          There is NO reason an owner can't make the part and no reason he can't put it on IF he has a mechanic who makes sure he is doing it right. WORKING on my plane is one of the great joys of life. If I had to choose working on her or flying her, I would probably get on that I could take off the rolls just to work on. When and if I ever retire I have every intention of volunteering at the Military Aviation Museum in Virginia Beach. LOTS to work on there!

          Hank

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          • #6
            Re: For those of you who think you can build your own parts....

            [QUOTE=Hank Jarrett;75708]Who is trying to "make" parts that are available? I can tell you that ALL of the parts I have made for my plane I would have been FAR ahead buying them from the "factory" (what a joke that is) or from Wag or ASS.
            As for "who" builds them, I DID,.... ALL OF THEM.

            Several years ago when Bill O'Brien was still in the FAA, I went to an IA seminar were he spoke, and it was on owner not mechanic produced parts, so he said, and it is in print, the owner "manufactures", but it is the mechanic that installs it, so the maintenance record will have two sign offs, one from the owner stating what he did, and one from the mechanic saying he installed the approved part, just something that brought back memories, what a great guy he was, I emailed him with a question once, and he got back to me in less 24 hours, us mechanics lost a great man when he left.

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            • #7
              Re: For those of you who think you can build your own parts....

              Here is an article by Bill O'brien that I re-posted on my company blog a few years ago. This is the best explanation of OPP I have seen.

              http://www.dc65stc.blogspot.com/2010...ced-parts.html
              Terry Bowden, formerly TF # 351
              CERTIFIED AERONAUTICAL PRODUCTS, LLC
              Consultant D.E.R. Powerplant inst'l & Engines
              Vintage D.E.R. Structures, Electrical, & Mechanical Systems
              BC12D, s/n 7898, N95598
              weblog: Barnstmr's Random Aeronautics
              [email protected]

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              • #8
                Re: For those of you who think you can build your own parts....

                Thanks Terry!
                Dale
                T.F.# 1086

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                • #9
                  Re: For those of you who think you can build your own parts....

                  Originally posted by cvavon View Post
                  Just a question in the case of Taylorcraft does this mean parts from the factory or part manufacturer where do used parts come in to play and how does the FAA look at them there are no factory new parts
                  Used parts are checked for serviceability and then can be installed. You are confusing factory with PMA, wag aero and Univair has a PMA to build parts as replacements even though they are not the factory. If Wag or Univair have them, then you are not allowed to use 21.303b2 to save money or not wanting to wait for the pma'd part.
                  N29787
                  '41 BC12-65

                  Comment


                  • #10
                    Re: For those of you who think you can build your own parts....

                    WAIT A MINUTE -
                    There are a lot of references to 21.303b2 being thrown around here. Take note... 14 CFR Part 21 was extensively revised in 2010. The topic of Owner Produced Parts is no longer referenced in 21.303. This is now covered in a totally different sub-paragraph, 14 CFR 21.9(a)(5).

                    Take a minute and read it. NOWHERE does is say that this provision only applies if the part is unavailable.
                    Last edited by barnstmr; 03-04-2013, 12:50.
                    Terry Bowden, formerly TF # 351
                    CERTIFIED AERONAUTICAL PRODUCTS, LLC
                    Consultant D.E.R. Powerplant inst'l & Engines
                    Vintage D.E.R. Structures, Electrical, & Mechanical Systems
                    BC12D, s/n 7898, N95598
                    weblog: Barnstmr's Random Aeronautics
                    [email protected]

                    Comment


                    • #11
                      Re: For those of you who think you can build your own parts....

                      thanks Terry

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                      • #12
                        Re: For those of you who think you can build your own parts....

                        Originally posted by barnstmr View Post
                        WAIT A MINUTE -
                        There are a lot of references to 21.303b2 being thrown around here. Take note... 14 CFR Part 21 was extensively revised in 2010. The topic of Owner Produced Parts is no longer referenced in 21.303. This is now covered in a totally different sub-paragraph, 14 CFR 21.9(a)(5).

                        Take a minute and read it. NOWHERE does is say that this provision only applies if the part is unavailable.
                        Terry, it does not have to say that, it is how they apply the rule and the interpretation was similar to using a field approval in place of an STC, if the STC was available, they will never approve the field approval and tell the operator to buy the STC. Been there and done that. Tim
                        N29787
                        '41 BC12-65

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                        • #13
                          Re: For those of you who think you can build your own parts....

                          I wonder how many people on this site could have built that gear door, primed it correctly and painted it,then installed it never writing anything or mentioning it. I think quite a few could have as there is a lot of talent here. I think the difference from say 20-30 years ago is that they just did it and got on with it and went flying. These old crates were flown by people who in many cases were in rough financial shape, trying to fund a losing FBO venture, etc. they undoubtedly crafted a lot of things due to necessity and never logged it. I'm sure this still goes on to a degree. I watched a fellow do a cowling on an English wheel that was truly magnificent some years ago. The old one was done for. It was painted beautifully and installed and I know there was no paper work of any kind. It simply appeared, and flew, end of story. As my friend j. Pogue said upon reviewing my Stearman log as he annualed it, " many log books should be read to children at bed time. They are fairy tales." Unquote. I agree with jack. JC
                          Last edited by jim cooper; 03-04-2013, 22:29.

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                          • #14
                            Re: For those of you who think you can build your own parts....

                            Originally posted by astjp2 View Post

                            I was at an IA seminar and a mechanic was violated for building a skin to replace one on a piper landing gear door. They used 21.303b2 as their justification. Signed it off in the logs and flew the airplane.
                            I think we're only getting part of the whole story here...probably a quality issue, or maybe a difference in the way the skin was applied (originally bonded, now riveted, etc.).... I'm with Terry on this stuff.... don't try to make it into rocket science!
                            I'm so far behind, I think I'm ahead

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                            • #15
                              Re: For those of you who think you can build your own parts....

                              There is a big "gotcha" buried in this discussion. I just help do a seemingly benign owner produced part on a LSA. However, LSA does not fall under FARs, so 21.9a(5) has no bearing and I now have some 'splainin to do at the local FSDO. Apparently, the correct procedure for home-brewing an LSA or Experimental part is to send a letter requesting a special provision.
                              Makes my head hurt.
                              Best Regards,
                              Mark Julicher

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