 Savvy
Owner Notebook:
Car Parts For Spam Cans?
Is it legal to install a Ford alternator in
a Cessna? What about a Ford door handle? Can you legally have your
Cessna alternator repaired by the local automotive alternator shop?
And even if it's legal, would it be smart? The answers aren't as
black-and-white as you might think.
by Mike Busch,
A&P/IA (mike.busch@savvyaviator.com)
 Most
of these monthly Savvy Owner Notebook columns are inspired by
emails or phone calls I get from aircraft owners, and this one is no
exception. This month's column was triggered by an interesting email
exchange between two brothers named Mark and
Scott—both sons of an aircraft owner and both aircraft owners
themselves.
Theirs is clearly an ecumenical family: Mark owns
a Bellanca Super Viking, Scott owns a Cessna Cardinal, and their dad
owns a Piper Dakota. As the curtain went up on this little drama, brothers Mark and Scott were
engaged in an apparently long-running
argument about a subject that comes up with some regularity: the use of
automotive parts and services in maintenance of certificated
aircraft.
Mark's view
I first heard from Mark:
Mike:
I've been reading your columns on aircraft
maintenance since you started and have enjoyed them very
much. A subject has popped up on my radar recently about
which I would welcome your opinion.
Recently, my father and brother were flying in my
father's Dakota at night and the alternator quit taking
the rest of electrical system with it, it was as if the
master switch was turned off. The particulars of that
problem aren't relevant to this discussion. The good
news is that both my dad and my brother are good pilots
and landed without incident.
 Subsequently, my father's A&P (a long time family
friend) removed the alternator and took it to an
automotive alternator shop for rebuild. I haven't seen
the log books, but I'm under the impression that no log
book entry was made. When I questioned this procedure my
brother told me that everybody knows a lot of airplanes
use car parts. He pointed out that the alternator in his
Cessna Cardinal is from a 75 Ford Galaxy. He said that
you pay a huge premium to have your alternator done at
an aviation shop for the same work and the same parts.
So here is where the story gets interesting. After
the alternator rebuild I flew my Dad's Dakota. There was
a noticeable whine in the headsets that varied with
engine RPM. I told my father I thought there was
something wrong with his alternator. He dismissed my
concern, saying that it was impossible because his
alternator had just been rebuilt. A few weeks later my
brother was flying the Dakota on an IFR flight plan in
actual when the alternator failed again. Fortunately my
brother was able to descend to VFR and land normally on
battery power with everything turned off but the #1 comm
radio.
Is there something wrong with this picture? I own
a Bellanca Super Viking and I pay dearly to have it
maintained by the best guy around to the highest
standard I can afford. I believe my airplane is 100%
legal and my log books are completely accurate. It makes
me feel like a chump to think I'm paying a lot more than
everyone else-- but on the other hand in the 160 hours
I've owned my plane I haven't had any significant
problems either. I'd welcome your thoughts.
--Mark
Scott's view
Mark cc'd his brother on his email to me, and within a few hours
Scott's reply was in my email inbox:
Mark,
I'm not suggesting automotive parts are appropriate for
aircraft. What I am saying is that for such items as alternators
they are nearly identical to those used in cars. In the case of
a Cardinal, for example, the alternator is nearly identical to
the 75 Ford Galaxy. The "nearly identical" characterization is
not mine, by the way—it came from
the Cardinal Flyers website.
I did not advocate installing a 75 Ford alternator,
despite the fact is they are nearly identical. My Cardinal
alternator is "aircraft grade," yellow tagged, and legal. For
this dubious distinction, I paid some stupid amount of money to
a shop whose primary business is automotive alternator
overhauls. Since I overhauled all accessories at once at engine
overhaul, I chose to pay this premium for the same work as I
would normally have had done for much less.
Normally I don't care about a yellow tag for such items
and use a quality shop for the work. I've gotten yellow tagged
item which were garbage in the past. Over the years I've had
regular occasion to rework the poor "aircraft quality" parts I
have received from FAA-PMA parts suppliers. That is to say,
often aircraft parts are of poor quality and I refused to
install them without repairing them. It would have been
perfectly legal to install those parts, but that doesn't mean
much when those parts pose a hazard to safe operations. It is
our responsibility as Pilots-In-Command to determine if the
airplane is airworthy, not the parts supplier.
I do have some auto parts on my plane because the original
parts from Cessna were not available. It is no coincidence those
parts have the same Cessna part number as the auto part, or that
the purchase price was $39 (rather than $500-$600 that Cessna
quoted while informing me that the parts were not available).
 BTW, Cardinal fuel pumps, door handles, window cranks,
voltage regulators, head rests, and more are directly taken from
auto suppliers. I believe many of these parts were also used on
boats, tractors, trains, trucks, and more. I think you'll find
the same with Bellancas, and that you've told me about this in
the past.
The Cirrus people talk about attaining "automotive
quality" for fit, finish, and reliability of their airplanes.
This is a great target to shoot for.
Evidently the recent electrical problem with Dad's Dakota
was due to some improper wiring work before he took ownership of
the airplane. In our old airplanes unknown wiring from previous
ownership is fairly common. (I bet there's a bunch of spaghetti
behind the panel of your Viking.) The installation of the
overhauled alternator on the Dakota was properly signed off and
legal. Because the alternator continues to work properly we
cannot classify the recent incident as an alternator failure at
all.
You should take Mike's' course—I
would like to do so as well. Mike advocates owner involvement in
maintenance, and encourages owners to turn wrenches and get
their hands dirty to the extent they are willing and interested.
The crumbling GA maintenance infrastructure makes such
owner involvement imperative. Paying top dollar or being legal
is no guarantee of safety. Increased owner involvement is the
best solution.
--Scott
Classic dilemma
I found this exchange between Mark and Scott to be both
interesting and thought-provoking. It clearly illustrates the
classic dilemma that every aircraft owner faces from time to time when
the dictates of common sense and practical necessity wind up at odds
with the dictates of FAA regulations and "doing it by the book."
It's not just aircraft owners who are afflicted by such dilemmas—they're
also the things that cause indigestion and hair loss among career
A&P/IAs.
There's huge difference FAR-wise between installing an automotive
alternator on a certificated airplane and having an automotive
alternator shop do repairs on an aircraft alternator. The former—installing
a Ford alternator on a Cessna—is usually against the rules
and probably not a great idea unless there's absolutely no
alternative. (If there is no alternative, there are some ways to get
around the prohibition that I'll discuss shortly.)
The latter—having an approved aircraft
alternator repaired by an unapproved shop—is an entirely
different matter. It's absolutely legal if your A&P is comfortable
with it and willing to sign it off. That's because Part 43 allows
anyone to do maintenance and repair of a certificated aircraft so
long as the work is done under the supervision of an A&P mechanic.
In other words, if an A&P is allowed to overhaul an alternator
(which he is), then he's also permitted to supervise someone else
overhauling the alternator. Part 43 also makes it clear that the amount of supervision required
is completely up to the discretion of the A&P. Any amount of
oversight that makes him comfortable—even "call
me when it's done"—is perfectly legal. Naturally, if something goes
wrong later, the FAA will hold the A&P who signs off the work
accountable for the consequences.
 Many career A&Ps refuse to install any
repair part on a certificated aircraft unless it comes from an
approved source (e.g., the aircraft manufacturer, a FAA-PMA
supplier, or a certified repair station) and comes with proper
documentation (a yellow tag or an FAA Form 8130-3). Aircraft owners
often wind up with the notion that it's illegal to install any part
that doesn't have such documentation, but that's simply not so. The
only real effect of the yellow tag or 8130-3 is to shift the burden
of responsibility for assuring that the repair part is airworthy
from the installing mechanic to the part vendor. Since career A&Ps
tend to be very concerned about liability (and rightly so), they
much prefer to install fully documented parts rather than
undocumented ones. But it's certainly not a requirement, at least
for Part 91 aircraft.
As Scott appropriately points out, an
undocumented part (say, from a salvage yard) may be superbly
airworthy, and one with a yellow tag or 8130-3 could be a hunk of
junk. I can tell you for a fact that one of the world's largest FAA-PMA
suppliers of aircraft alternators has been shipping a lot of really
awful alternators lately. But all were perfectly documented.
Car parts for spam cans
If you absolutely positively must install an automotive part on a
certificated aircraft—perhaps because the part
is simply unavailable from an approved source or is impossibly
costly—there are two possible ways to do it legally. The first way
is to persuade an FAA inspector at your local FSDO that it's okay
and get him to sign an FAA Form 337 granting you a field approval.
Unfortunately, FAA headquarters issued new guidance last year that
makes it much more difficult for FSDO inspectors to grant field
approvals than it used to be. Under the new policy, it's often
necessary to involve a Designated Engineering Representative (DER)
or an FAA Aircraft Certification Office (ACO) to obtain a field
approval. Hiring a DER can be an expensive proposition, and
obtaining help from an ACO can take months or years.
The second method is to install the
automotive part as an "owner-produced part." FAR 21.303(b) gives
aircraft owners the authority to produce parts for their own
aircraft (but not for sale), and such parts can be perfectly legal.
Furthermore, the FAA lawyers have published a letter of
interpretation that defines what "owner-produced" means, and it's
surprisingly liberal. To "produce" a part, the owner need not
manufacture it himself. It's sufficient for the owner to furnish the
specifications for making the part, furnish the materials from which
the part is made, or provide quality assurance for the part. Thus,
if the owner of a Bellanca finds a Ford door handle that he
determines to be identical to the original Bellanca door handle in
terms of form, fit, function and other factors affecting
airworthiness, the owner may deem it to be an owner-produced part
(since he provided quality assurance for it) and document it
in the aircraft logbooks as such. Of course, if the part is one that
must be installed by an A&P, the mechanic must also be satisfied
that the part is airworthy and willing to sign off the installation.
So while it generally does not make sense to
install an automotive part rather than an aircraft part just to save
a few bucks (or even a few hundred bucks), it can be done legally
when necessary if you jump through the right hoops. Most of the
time, however, the juice isn't worth the squeeze and the best course
is to bite the bullet and buy the approved part.
I agree with Scott when he says that "paying top dollar or being
legal is no guarantee of safety." I'm obsessive about not wasting
money on maintenance, and a major theme of my seminars is how to
accomplish that. On the other hand, I'm also pretty obsessive about
staying legal—not because legal is
necessary safer, but because if you do something that's not legal
you never know when it's going to catch up with you during an annual
inspection or ramp check when some A&P/IA or FAA inspector asks you
"what's the approval basis for THAT?"
| Do you have a maintenance-related
"war story" that you'd like to share with fellow
aircraft owners? If you do, I'd
love to hear from you. The most interesting stories
I receive each month will be rewarded with highly prized Savvy
Aviator coffee mugs, so please include your
shipping address. Also be sure to let me know if you'd like
me to "change the names to protect the innocent"
when sharing your story. |
|
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