TSO's in general
Moderators: GAHorn, Karl Towle, Bruce Fenstermacher
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GAHorn
- Posts: 21295
- Joined: Fri Apr 12, 2002 8:45 pm
It's my opinion that since the seat belt is the security and no actual modification to the aircraft occurs it qualifies as portable equipment and does not need any documentation.
'53 B-model N146YS SN:25713
50th Anniversary of Flight Model. Winner-Best Original 170B, 100th Anniversary of Flight Convention.
An originality nut (mostly) for the right reasons.
50th Anniversary of Flight Model. Winner-Best Original 170B, 100th Anniversary of Flight Convention.
An originality nut (mostly) for the right reasons.
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Bruce Fenstermacher
- Posts: 10422
- Joined: Tue Apr 23, 2002 11:24 am
Joe, I'm no authority but I see this type of thing all the time.
It sounds like you installation is safe enough and not a permanent piece of equipment as far as it "mount" is concerned. It's basically a piece of luggage.
What I wonder though is how is it powered? If from the aircraft that will be your problem area as far as legality goes.
One thing you have to consider is what is your exposure. Are you the only one using the equipment for your own personal pleasure or are you making money and selling it to others. It shouldn't but it makes a difference.
If this is a one or two shot deal that your are doing for your own home movies I'd go for it and ask forgiveness after word. If more than that is involved, and I think it is, well that is probably not the best course of action.
The real answer of course is to have a conversation with our local FSDO inspector. It doesn't make a difference what George or I think. It's unlikely your inspector will give a written opinion as to the mount but he might say verbally he sees no problem with it so I'd have a witness to collaborate what he says. Of course be prepared with your "eye ball" engineering so the FSDO guy thinks it's no big deal.
It sounds like you installation is safe enough and not a permanent piece of equipment as far as it "mount" is concerned. It's basically a piece of luggage.
What I wonder though is how is it powered? If from the aircraft that will be your problem area as far as legality goes.
One thing you have to consider is what is your exposure. Are you the only one using the equipment for your own personal pleasure or are you making money and selling it to others. It shouldn't but it makes a difference.
If this is a one or two shot deal that your are doing for your own home movies I'd go for it and ask forgiveness after word. If more than that is involved, and I think it is, well that is probably not the best course of action.
The real answer of course is to have a conversation with our local FSDO inspector. It doesn't make a difference what George or I think. It's unlikely your inspector will give a written opinion as to the mount but he might say verbally he sees no problem with it so I'd have a witness to collaborate what he says. Of course be prepared with your "eye ball" engineering so the FSDO guy thinks it's no big deal.
CAUTION - My forum posts may be worth what you paid for them!
Bruce Fenstermacher, Past President, TIC170A
Email: brucefenster at gmail.com
Bruce Fenstermacher, Past President, TIC170A
Email: brucefenster at gmail.com
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Joe Moilanen
- Posts: 605
- Joined: Sun Dec 28, 2003 5:45 am
Thanks guys,
I'm actually considering going to market with these things. I used a Fox News photographer while doing the R&D and it is works better than any of the competition out there.
If George thinks it's OK it HAS to be. I've cut and pasted his response and putting it on every page of the operators manual as a legal disclaimer with reference to his contact information and his bank acount number
Just kidding George, but thanks for the input!! A disclaimer such as " Securtiy, methods of installation, and safe operating practices are sole liability and responsibility of pilot and/or operator" probably would be a good idea though...
Joe 4518C
I'm actually considering going to market with these things. I used a Fox News photographer while doing the R&D and it is works better than any of the competition out there.
If George thinks it's OK it HAS to be. I've cut and pasted his response and putting it on every page of the operators manual as a legal disclaimer with reference to his contact information and his bank acount number
Just kidding George, but thanks for the input!! A disclaimer such as " Securtiy, methods of installation, and safe operating practices are sole liability and responsibility of pilot and/or operator" probably would be a good idea though...
Joe 4518C
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GAHorn
- Posts: 21295
- Joined: Fri Apr 12, 2002 8:45 pm
Ha!
And now, the backpeddaling: I'm pretty certain that if you are selling the device for other's use, that you'll want to include plenty of warnings for the user, such as determining that the seat belt is indeed suitable in case of a crash....i.e., the device weighs no more than a person, the device will not exceed the design loads of the seat structure, the device will not interfere with emergency exgress from the aircraft, the device will not adversly affect the aircraft operations or other onboard equipment, and so on....
(My already-expressed opinion is relative to carriage of the device as cargo or personal-equipment in a personal airplane. As Bruce so ably pointed out, it does not address device operation or serviceability issues like power useage, aircraft interface, crashworthiness, etc. My brother-in-law's second-cousin, Jose Santa Ana Miguel Portofino Albondigo is a lawyer and perhaps he can help you weeth thees new questions.)
And now, the backpeddaling: I'm pretty certain that if you are selling the device for other's use, that you'll want to include plenty of warnings for the user, such as determining that the seat belt is indeed suitable in case of a crash....i.e., the device weighs no more than a person, the device will not exceed the design loads of the seat structure, the device will not interfere with emergency exgress from the aircraft, the device will not adversly affect the aircraft operations or other onboard equipment, and so on....
(My already-expressed opinion is relative to carriage of the device as cargo or personal-equipment in a personal airplane. As Bruce so ably pointed out, it does not address device operation or serviceability issues like power useage, aircraft interface, crashworthiness, etc. My brother-in-law's second-cousin, Jose Santa Ana Miguel Portofino Albondigo is a lawyer and perhaps he can help you weeth thees new questions.)
'53 B-model N146YS SN:25713
50th Anniversary of Flight Model. Winner-Best Original 170B, 100th Anniversary of Flight Convention.
An originality nut (mostly) for the right reasons.
50th Anniversary of Flight Model. Winner-Best Original 170B, 100th Anniversary of Flight Convention.
An originality nut (mostly) for the right reasons.
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