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Strut Airworthiness Directive (AD) (merged VI)

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  • #91
    Re: Strut Airworthiness Directive (AD)

    Originally posted by Ragwing nut View Post
    That is correct. Struts are available through Univair and soon the factory so they can't be produced under 21.303. As long as it is not being produced you can make it under 21.303 for your own use.
    Mike, I don't see that in the regulation. I included the reg below. Show me where you read that. Dave

    § 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 produced pursuant to a Parts Manufacturer Approval issued under this subpart.

    (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 operator 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 industry or U.S. specifications.

    (c) An application for a Parts Manufacturer Approval is made to the Manager of the Aircraft Certification Office for the geographic area in which the manufacturing facility is located and must include the following:

    (1) The identity of the product on which the part is to be installed.

    (2) The name and address of the manufacturing facilities at which these parts are to be manufactured.

    (3) The design of the part, which consists of—

    (i) Drawings and specifications necessary to show the configuration of the part; and

    (ii) Information on dimensions, materials, and processes necessary to define the structural strength of the part.

    (4) Test reports and computations necessary to show that the design of the part meets the airworthiness requirements of the Federal Aviation Regulations applicable to the product on which the part is to be installed, unless the applicant shows that the design of the part is identical to the design of a part that is covered under a type certificate. If the design of the part was obtained by a licensing agreement, evidence of that agreement must be furnished.

    (d) An applicant is entitled to a Parts Manufacturer Approval for a replacement or modification part if—

    (1) The Administrator finds, upon examination of the design and after completing all tests and inspections, that the design meets the airworthiness requirements of the Federal Aviation Regulations applicable to the product on which the part is to be installed; and

    (2) He submits a statement certifying that he has established the fabrication inspection system required by paragraph (h) of this section.

    (e) Each applicant for a Parts Manufacturer Approval must allow the Administrator to make any inspection or test necessary to determine compliance with the applicable Federal Aviation Regulations. However, unless otherwise authorized by the Administrator—

    (1) No part may be presented to the Administrator for an inspection or test unless compliance with paragraphs (f)(2) through (4) of this section has been shown for that part; and

    (2) No change may be made to a part between the time that compliance with paragraphs (f)(2) through (4) of this section is shown for that part and the time that the part is presented to the Administrator for the inspection or test.

    (f) Each applicant for a Parts Manufacturer Approval 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 part conforms to the drawings in the design; and

    (4) That the fabrication processes, construction, and assembly conform to those specified in the design.

    (g) The Administrator does not issue a Parts Manufacturer Approval if the manufacturing facilities for the part are located outside of the United States, unless the Administrator finds that the location of the manufacturing facilities places no burden on the FAA in administering applicable airworthiness requirements.

    (h) Each holder of a Parts Manufacturer Approval shall establish and maintain a fabrication inspection system that ensures that each completed part conforms to its design data and is safe for installation on applicable type certificated products. The system shall include the following:

    (1) Incoming materials used in the finished part must be as specified in the design data.

    (2) Incoming materials must be properly identified if their physical and chemical properties cannot otherwise be readily and accurately determined.

    (3) Materials subject to damage and deterioration must be suitably stored and adequately protected.

    (4) Processes affecting the quality and safety of the finished product must be accomplished in accordance with acceptable specifications.

    (5) Parts in process must be inspected for conformity with the design data at points in production where accurate determination can be made. Statistical quality control procedures may be employed where it is shown that a satisfactory level of quality will be maintained for the particular part involved.

    (6) Current design drawings must be readily available to manufacturing and inspection personnel, and used when necessary.

    (7) Major changes to the basic design must be adequately controlled and approved before being incorporated in the finished part.

    (8) Rejected materials and components must be segregated and identified in such a manner as to preclude their use in the finished part.

    (9) Inspection records must be maintained, identified with the completed part, where practicable, and retained in the manufacturer's file for a period of at least 2 years after the part has been completed.

    (i) A Parts Manufacturer Approval issued under this section is not transferable and is effective until surrendered or withdrawn or otherwise terminated by the Administrator.

    (j) The holder of a Parts Manufacturer Approval shall notify the FAA in writing within 10 days from the date the manufacturing facility at which the parts are manufactured is relocated or expanded to include additional facilities at other locations.

    (k) Each holder of a Parts Manufacturer Approval shall determine that each completed part conforms to the design data and is safe for installation on type certificated products.

    Comment


    • #92
      Re: Strut Airworthiness Directive (AD)

      I just got my AD in the mail. It effectively grounds all Taylorcrafts as of Aug 20.

      Chet Peek

      Comment


      • #93
        Re: Strut Airworthiness Directive (AD)

        I have tried three time to enter a comment on the web site that DannyDot gave, but I'm having problems get into the server.I've gotten up to filling in name, address, ect. but can't get to to page to enter comments.
        Any one else having problems?
        Robbie
        TF#832
        N44338
        "46" BC12D
        Fond du lac WI

        Comment


        • #94
          Re: Strut Airworthiness Directive (AD)

          Originally posted by Chet Peek View Post
          I just got my AD in the mail. It effectively grounds all Taylorcrafts as of Aug 20.

          Chet Peek
          Hi Chet,

          I don't think you'll be grounded on August 20. While Aug 20 is the effective date , there are a couple of cushions built into the AD.

          Within 5 flight hours of Aug 20, you need to do the visual inspection. The compliance section say that if the visual inspection shows no cracking or corrosion, you've got 3 months to do the eddy current or ultrasound inspection on the old style struts.

          So, you should have a little bit of breathing room...

          Dan

          Comment


          • #95
            Re: Strut Airworthiness Directive (AD)

            Originally posted by Ragwing nut View Post
            You can't build new struts or any other part under 21.303 as long as the part is being manufactured either by the manufacturer or an approved PMA process.

            Mike

            What reg says when you can utilize 21.303.B2? I have always thought that you could, you might have to provide lots of data and it would cost more than to buy the PMA'd part, but you as an owner or operator could still build a part and get it approved. Tim
            N29787
            '41 BC12-65

            Comment


            • #96
              Re: Strut Airworthiness Directive (AD)

              Originally posted by astjp2 View Post
              What reg says when you can utilize 21.303.B2? I have always thought that you could, you might have to provide lots of data and it would cost more than to buy the PMA'd part, but you as an owner or operator could still build a part and get it approved. Tim
              I posted it on the other thread as well. I have read it somewhere, but need to do some more reading and find it. It is in another part of the FAR's. AC43-18 has good info on part productions without approvals.

              Mike

              Comment


              • #97
                Re: Strut Airworthiness Directive (AD)

                Well the AC is not regulatory, and I have not found it in the REGS, if you ask a PMI to put it in writing that you as an owner or operator cannot use a part manufactured IAW 21.303.B2 on his or her own product, they would open up a can of worms for just about every field that a part is made for to modify an aircraft i.e. 3" longer gear, big baggage door, lifting eyes for float installation, etc. They could make it awful difficult to get it approved and not cost effective but it could still be done...ANY PMI's out there????.... Tim
                N29787
                '41 BC12-65

                Comment


                • #98
                  Re: Strut Airworthiness Directive (AD)

                  Originally posted by astjp2 View Post
                  What reg says when you can utilize 21.303.B2? I have always thought that you could, you might have to provide lots of data and it would cost more than to buy the PMA'd part, but you as an owner or operator could still build a part and get it approved. Tim
                  Hi Tim, did you mean can or cannot?

                  Comment


                  • #99
                    Re: Strut Airworthiness Directive (AD)

                    Whoops, mistype, cannot....Tim
                    N29787
                    '41 BC12-65

                    Comment


                    • Re: Strut Airworthiness Directive (AD)

                      Who remembers Richard Bach's "Found at Pharisee and School of Perfection?"

                      Comment


                      • Re: Strut Airworthiness Directive (AD)

                        Wasn't the 'School of Perfection' the story about a group of "outlaws" that had a mountain hideout and taught people flying and mechanical skills that exceeded the regulations? They would rebuild an engine to better than factory specs. Then drop it off at a maintenance facility in the middle of the night with no paperwork in exchange for an engine needing overhaul.... where it would then have to be torn down because there was no paperwork. The theme was about always trying to improve your skills even when they are already adequate to meet the regs. Hope I'm remembering the right one. It is still one of my favorites,
                        20442
                        1939 BL/C

                        Comment


                        • Re: Strut Airworthiness Directive (AD)

                          Originally posted by Howard Wilson View Post
                          Wasn't the 'School of Perfection' the story about a group of "outlaws" that had a mountain hideout and taught people flying and mechanical skills that exceeded the regulations?
                          "Found at Pharisee" and "Schoool For Perfection" are near and dear to my heart, thanks for reminding me There used to be a couple of guys in the FAA that knew those stories and lived by them, but I'm afraid no more. How about it, Mr. McAnaul???

                          Brother Richard, I owe you my life for helping me find my soul... thanks!

                          Rob, read the stories mentioned above before you send this post to Siberia...
                          Taylorcraft : Making Better Aviators for 75 Years... and Counting

                          Bill Berle
                          TF#693

                          http://www.ezflaphandle.com
                          http://www.grantstar.net
                          N26451 (1940 BL(C)-65) 1988-90
                          N47DN (Auster Autocrat) 1992-93
                          N96121 (1946 BC-12D-85) 1998-99
                          N29544 (1940 BL(C)-85) 2005-08

                          Comment


                          • Re: Strut Airworthiness Directive (AD)

                            I have a D model converted from a TG-6. My struts are as described earlier by an L2 owner. No drain holes anywhere, square portion where it meets the fuselage. I understand these struts to be different than the B models.

                            It does seem that the FAA may be confused and may think that the TG-6's were converted to B models, not D models. As far as I know, all the TG-6 converstions were D models, they would have to be.

                            It would seem that the FAA has made a mistake in including the TG-6 conversions. Those conversions are D model Taylorcraft, with the same struts as the other D models. If the other D model Taylorcraft are not affected by the AD, the TG-6 conversions should not be.

                            Am I missing something?

                            Forrest, is that an issue that you can address with the FAA?

                            Thanks,
                            Tony
                            sigpic

                            Comment


                            • This guy has the strut thing figured out. plain and simple

                              FORGIVE ME FATHER FOR I HAVE SINNED.
                              Please forgive me
                              I stole this from unknowing parties But as Mercedes Benz Said
                              " some things in life are just too important not to share"



                              This guy has always been one of my hero's After Forrest of course> Cause Forrest has a cuter tush

                              Like I always SAID making them bigger is the way to GO
                              Number 4 is my favorite


                              .
                              On the struts, don't go to general quarters just yet. I have several decades of experience doing NDI inspections using X-Ray, ultra-sonic, Eddy current, Neutron radiography, punch testing and probably many more that just don't come to mind right away. The one thing all the gang have in common is LOTS of lack of knowledge of what they are talking about. We can hope the FAA guys will get some straight skinny before they make a decision (but I'm not going to hold my breath on that either). I don't plan to jump in to the conversation because it will just be one more voice being drowned out by all the "opinions".
                              A few "facts":
                              1. NONE of the techniques listed on the Taylorcraft site are appropriate to determine corrosion!
                              2. Neutron radiography DOES detect corrosion and can tell you how thick it, and the base metal, are. Unfortunately, it is probably the most dangerous method I have ever used and I don't think it is even legal any more, much less affordable.
                              3. The ONLY way to be sure the strut is clear of corrosion (sealed or not) would be to hot dip it in solvent to remove all of the coatings and bore scope the ID and inspect the outside, noting ALL the pits. Then you would need to MEASURE the thickness in each pit. How much money do you have?
                              4. WHO CARES if there are pits and corrosion AS LONG AS THE STRUT IS CAPABLE OF CARRYING THE FULL DESIGN LOAD!!!!!
                              5. NO ONE has suggested what looks OBVIOUS to me. Clean the strut inside and out. Look for severe corrosion. Treat and paint the struts INSIDE AND OUT. PROOF LOAD the strut to design load + the safety margin. GO FLY! Do a visual borescope of the ID paint every 4 or 5 years and re-proof load if there is deterioration of the paint.
                              6. The FAA is famous for doing screw ball inspections that don't really prove anything, just so they can say they "did something". If that happens, it doesn't matter. We do what they say (and then I clean my struts, inspect, paint and proof load them, because I don't want to die).
                              The other thing is, there is a REASON there has never been a Taylorcraft lost from a strut failure. The plane was designed with pretty small struts (the original ones on our planes). When the dies wore out, the CAR (now FARs) allowed you to go UP one size for a replacement without re-doing the stress analysis. This has happened MANY times, each time with a new, larger strut. Go look at a NEW Taylorcraft and the AFT strut is BIGGER than our front struts. The front struts are HUGE! Even corroded there is a lot of excess strength. We have been lucky in our community and I suspect a big part of it is the struts are so over strength that they are pulled from service and trashed because they LOOK bad long before they are weakened enough to fail. That is why Harry has a whole storage space full of UNFAILED corroded struts. There hasn't been one broken EVEN WITH HOLES corroded through them. Notice NONE of those terrible struts was involved in a crash.
                              I have sent a lot of this to Forrest and offered to help define a realistic, safe inspection, but for now, don't panic.
                              Just keep reading and hope the FAA sees reason.

                              Name withheld unless he gives me permission to release it
                              Untill then ' "I KNOW NOTHING, NOTHING" of the Mystery writer
                              B 52 Norm
                              1946 BC12-D1 Nc 44496
                              Quicksilver AMPIB, N4NH
                              AOPA 11996 EAA 32643
                              NRA4734945
                              Lake Thunderbird , Cherokee Village
                              Somewhere on the 38° parallel in NE Arkansas

                              Comment


                              • Re: This guy has the strut thing figured out. plain and simple

                                Norm,

                                Can you define 'proof-load' for me? I don't seem to have anything nearby that can do that. Just curious as to how it is done and how 1,800 owners could do it. Maybe it is just that simple. Thanks.
                                Cheers,
                                Marty


                                TF #596
                                1946 BC-12D N95258
                                Former owner of:
                                1946 BC-12D/N95275
                                1943 L-2B/N3113S

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