Can a non FAA shop make cables and or fluid lines to be used on aircraft.They are only made to customers samples. They supply material certs,and test results.And they use calibrated gauges.This question has come up many times.I guess my question is could they be an Approved vendor?
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Cables and Hard Fluid Lines
- Thread starter Datech
- Start date
The answer is yes, you can do anything with enough money. This comes up very frequently, someone trying to save a nickel by making cable assemblies at the local marina or a hose at the tractor supply. The swaging dies and other tooling are so expensive that it is driven to centralized shops. Seriously consider whether your arrangement is any cheaper than having Loos or Aviall make it for you.
Subcontract work and outside services are such common features of Quality manuals nowadays. If that is not written into yours, hire a manufacturing DAR to guide you through it. Throughout aviation, it is not the guy who runs the press or CNC mill that gets into trouble, it is the guy who signs it off (or ships it, or otherwise places the article into the stream of commerce.
Your post is not detailed enough to tell whether you are making new parts, replacing old ones, following a maintenance manual, etc., so I can't advise on what level of design data you need to have ("made to customers samples"). You might be stepping into PMA territory, and no matter what, you need to be cautious about SUPS (suspected unapproved parts). Again a manufacturing DAR would be more helpful than an engineer.
Hope this helped a little, if not, more detail on your situation can lead to better advice.
Subcontract work and outside services are such common features of Quality manuals nowadays. If that is not written into yours, hire a manufacturing DAR to guide you through it. Throughout aviation, it is not the guy who runs the press or CNC mill that gets into trouble, it is the guy who signs it off (or ships it, or otherwise places the article into the stream of commerce.
Your post is not detailed enough to tell whether you are making new parts, replacing old ones, following a maintenance manual, etc., so I can't advise on what level of design data you need to have ("made to customers samples"). You might be stepping into PMA territory, and no matter what, you need to be cautious about SUPS (suspected unapproved parts). Again a manufacturing DAR would be more helpful than an engineer.
Hope this helped a little, if not, more detail on your situation can lead to better advice.
I'm not sure what you mean by an FAA shop.
There are a couple ways I'm familiar with.
If they obtain FAA PMA approval, I believe those parts can be sold as aircraft replacement parts.
They could also manufacture the parts under an air carrier's 121 authority for use by them on their aircraft but they cannot be sold on the open market as aircraft parts.
No doubt there's other permutations.
I believe there's times when a manufacturer may be supplying the airframer with parts, but only the airframer can sell them as replacement parts, not the manufacturer.
As many times as I have been through training on this subject, it's always like the first time when I have to deal with it.
There are a couple ways I'm familiar with.
If they obtain FAA PMA approval, I believe those parts can be sold as aircraft replacement parts.
They could also manufacture the parts under an air carrier's 121 authority for use by them on their aircraft but they cannot be sold on the open market as aircraft parts.
No doubt there's other permutations.
I believe there's times when a manufacturer may be supplying the airframer with parts, but only the airframer can sell them as replacement parts, not the manufacturer.
As many times as I have been through training on this subject, it's always like the first time when I have to deal with it.
- Thread starter
- #4
Thanks der8110 and kontiki99.
To answer your questions.The parts are replacing used parts,and nothing is made for resale. The shop in question is not a FAA repair station. It has been in business many years but is running into problems recently.They have an extensive knowledge of the standards and processes involved.
They have been questioned about their athority to manufacture parts.If you install ends on a tube or cable to match the customers part .Would that be considered manfacturing?
To answer your questions.The parts are replacing used parts,and nothing is made for resale. The shop in question is not a FAA repair station. It has been in business many years but is running into problems recently.They have an extensive knowledge of the standards and processes involved.
They have been questioned about their athority to manufacture parts.If you install ends on a tube or cable to match the customers part .Would that be considered manfacturing?
Datech.
Read up on AC43-18.
Here is an excerpt from that: Subcontractor. A person providing parts, materials, or related services (welding, plating, machining, etc.,) to the certificate holder responsible for fabrication of the part. The subcontractor must be subject to control and surveillance by that certificate holder who is ultimately responsible for the airworthiness of the part and its fabrication processes.
Not withstanding that a certificated mechanic can install cable ends or flare tube fittings under part 43 in accordance with the directions in 43.13 or as stated above can supervise someone else doing it.
B.E.
Read up on AC43-18.
Here is an excerpt from that: Subcontractor. A person providing parts, materials, or related services (welding, plating, machining, etc.,) to the certificate holder responsible for fabrication of the part. The subcontractor must be subject to control and surveillance by that certificate holder who is ultimately responsible for the airworthiness of the part and its fabrication processes.
Not withstanding that a certificated mechanic can install cable ends or flare tube fittings under part 43 in accordance with the directions in 43.13 or as stated above can supervise someone else doing it.
B.E.
Hi All, Don't forget the option of "Owner produced parts" per 21.303(b)(2). There is an AGC memo of 8/5/93 that clearly defines that option. I've used that to replicate a prop control cable for a P210R where Cessna wouldn't even talk to us. Send to the fab shop (which has PMA but not for the needed cable) and tell them to make a replica. The new one was back in four days, lubed for life and better than a Cessna part if it were available. But remember that the owner had it built and no A&P or IA numbers go in the logbook. Sometimes that's the only solution on these aging airplanes or in the P210R case, so few were built they are an orphan.
Also see Bill O'Briens great article in AMT mag, I think March 2005 as a guess.
JQC-DER/DAR
Also see Bill O'Briens great article in AMT mag, I think March 2005 as a guess.
JQC-DER/DAR
Can a non-certificated shop repair parts? Yes, they can under the supervision of a certificated person FAR 43.3(d) A person working under the supervision of a holder of a mechanic or repairman certificate may perform the maintenance, preventive maintenance, and alterations that his supervisor is authorized to perform, if the supervisor personally observes the work being done to the extent necessary to ensure that it is being done properly and if the supervisor is readily available, in person, for consultation. However, this paragraph does not authorize the performance of any inspection required by Part 91 or Part 125 of this chapter or any inspection performed after a major repair or alteration.
Owner Produced Parts
Does the owner have to manufacture the part himself, in order for the part to be considered an "owner produced" part? Answer: No. An owner would be considered a producer of a part if the owner participated in controlling the design, manufacture, or quality of the part. The FAA would look at many factors in determining whether a person participated in. Controlling the design, manufacture, or quality of a part. The following would tend to indicate that a person produced a part:
1. The owner provided the manufacturer with design or performance data from which to manufacture the part. {This may occur, for instance, where a person provided a part to the manufacturer and asked that the part be duplicated.)
2. The owner provided the manufacturer with materials from which to manufacture the part.
3. The owner provided the manufacturer with fabrication processes or assembly methods to be used in the manufacture of the part.
4. The owner provided the manufacturer with quality control procedures to be used in the manufacture of the part.
5. The owner supervised the manufacturer of the part.
I would caution anyone using non certificated FAA repair stations or PMA holders to manufactured parts for them. Parts on aircraft have to have a certification basic and traceability to the manufacturer/source or it may be considered a Suspected Unapproved Part.
Stache
Owner Produced Parts
Does the owner have to manufacture the part himself, in order for the part to be considered an "owner produced" part? Answer: No. An owner would be considered a producer of a part if the owner participated in controlling the design, manufacture, or quality of the part. The FAA would look at many factors in determining whether a person participated in. Controlling the design, manufacture, or quality of a part. The following would tend to indicate that a person produced a part:
1. The owner provided the manufacturer with design or performance data from which to manufacture the part. {This may occur, for instance, where a person provided a part to the manufacturer and asked that the part be duplicated.)
2. The owner provided the manufacturer with materials from which to manufacture the part.
3. The owner provided the manufacturer with fabrication processes or assembly methods to be used in the manufacture of the part.
4. The owner provided the manufacturer with quality control procedures to be used in the manufacture of the part.
5. The owner supervised the manufacturer of the part.
I would caution anyone using non certificated FAA repair stations or PMA holders to manufactured parts for them. Parts on aircraft have to have a certification basic and traceability to the manufacturer/source or it may be considered a Suspected Unapproved Part.
Stache
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