Owner Produced Parts
How they affect maintenance
By Don Dodge
The article was written to address the producing of parts by owner and operators. The article is not intended to imply that maintenance technicians or repair stations may not be able to manufacture parts in the course of accomplishing repairs or alterations. That in itself is another topic for another day.
The sun was setting on another hot August afternoon when the South Carolina Flight Standards District Office received the call from a local airport manager notifying the office that a Piper Cherokee had suffered a nose gear collapse during taxi operations. It was reported that the Cherokee suffered minor damage; the damage included a prop strike and lower cowling abrasion.
Early the next morning, the inspector assigned to investigate the incident picked up the preliminary information with one hand and his first cup of coffee with the other. As the coffee cleared the night's cobwebs from his mind, he eyeballed the incident information. As he read, he thought: "Let's see, Cherokee 140, taxi, nose gear collapse, prop, cowling, etc., etc. - wait a minute, Cherokee 140? How can a 140's nose gear collapse during taxi operations and cause this kind of damage? An Arrow, maybe, but a 140?"
Years of experience told the inspector there was more to this story than had been reported. So he headed for the airport. His investigation uncovered a classic case of an aircraft owner making parts and doing everything wrong. The issues surrounding manufacturing approved parts, who can produce these parts, what makes a part approved or unapproved, all came up in the investigation.
Time and again aircraft owners and maintenance technicians are pressured into making parts. Why do we do it? Why do we take on that liability? Let's look at the facts.
The average general aviation, piston single-engine aircraft is more than 32 years old; the average piston twin is more than 27 years old; and the average turbo prop is 19 years old. The GA aircraft fleet was never designed to last this long, and, when it comes to getting replacement parts to maintain these aircraft, here are a few of the problems we all face.
- The aircraft has been out of production for years.
- The aircraft is an orphan. No one even knows who owns the Type Certificate.
- There is no technical support. If you ask for technical assistance, you are often told that no one really knows much about the aircraft anymore. The people who were around when the aircraft was built are all retired or dead.
- Economy of scale forces aircraft manufacturers to build parts in quantities that make economic sense for the manufacturer. What this means is that parts are available, in about six or eight months!
- The price of parts is a subject that we aren't even going to talk about.
Sitting in the middle, between a tired broken airplane, its owner, and all these parts problems, is the maintenance technician. Technicians, by their nature, are "can do" people. They live by the motto the difficult we do immediately; the impossible just takes a bit longer. But when it comes to making parts, this "can do" philosophy can really get them in trouble.
Let's examine the rules governing the general privileges and limitations of a maintenance technician (or certificated mechanic as stated in FAR §65.81), and the rule governing a repair station's privileges of certificates (FAR §145.51). Under both rules a technician or repair station may perform maintenance, preventative maintenance, and alterations on an aircraft, or appliances for which he is rated. Nowhere in either rule does it say that the maintenance technician or repair station can produce new parts! However, the maintenance regulations allow the manufacture of parts for repair.
A maintenance tech or repair station can make patch plates, reinforcement splices, and incorporate them into the repair of a part. But again, a maintenance technician cannot make a brand new part for sale.
Here are some answers to those earlier questions.
Question: How is it that an aircraft owner can produce a part, but a skilled maintenance technician can't?
Answer: The responsibility follows the money. Most rules are written so the responsibility for an action is placed with the person who has the economic authority to make it happen (The Golden Rule).
Question: How does this owner-produced rule work? Does the owner have to make the part himself?
Answer: The answers can be found in a FAA Memorandum dated Aug. 5, 1993, in which the assistant Chief Counsel for Regulation makes the following interpretation:
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