BAS inertia reel system

[futr_alaskaflyer]

Jim,

You're right on. I would contact BAS and buy a new unit.

I've just been on EBay looking for FLACK jackets and BS detectors.

Maybe a new Discussion index is in order: FACT FREE ZONE moderator=Foghorn Leghorn LOL

So, I'm curious. Do you think the FAA policy statement that I linked earlier does not apply somehow? That they went through the process to issue it and release it in the Federal Register for no reason? What date was it released, and what is the date on the last revision to the AC, and when was the last revision to 43.13?

I'm just curious, because if there are hundred of airplanes flying around in annual with shoulder harness installations installed under a logbook signoff which are apparently unairworthy under your interpretation I would like to at least notify those owners who I am friends with.

BTW that is how my old shoulder harnesses were installed (previous to my current ones which were bought new from BAS earlier this year and installed pursuant to the STC. It was annualed by three or four different shops previously, who presumably knew about them.)

I also want to hear more about how an aircraft-specific STC copy, listing the aircraft serial number and registration number can somehow be transferred to another aircraft. What are you going to put on the 337, as the A&P?

[GAHorn]

...
Another copy of the entire FAA Opinion Letter is in the Mx Library:
http://www.cessna170.org/forums/viewtopic.php?f=6&t=8

FAA opinion is not regulatory, FAR's are regulatory. Pay particular note to paragraph (b) of this FAR.....

That was an unfortunate choice of words. It is not an "opinion letter". It is a Policy Letter, and it is binding until revised or revoked.

I understand what you are saying Metal Master and I understand your concern.

Who is to say the list never existed? YOUR logbook entry providing the date of the list and your copy of the list proves that, if it's ever req'd. (Until the next inspection or sign off of those discrepancies supercedes the list.)

But the responsibility for operating the aircraft belongs to the operator, not the inspector. The inspector is not the flying-police. (If you intend to keep the owner from flying it then it'd be even more effective to chain it down, right? That has at least as much authorization as making log entries not authorized by the FAR's.)
While it may make an inspector feel "powerful" to indelibly enter into the logs a list of discrepancies... that action is not authorized by the FAR's. The inspector who does so takes upon himself responsibilities for which he has no authorization.... the very same sort of activity that inspector is condemning of the operator.

The protection for the inspector is illustrated by the very example you just gave: A subsequent inspection having been performed without previously-found discrepancies recorded as being satisfied.

"What I have seen though is an annual inspection completed signed of with the note that discrepancies were found and a separate signed list given to the owner. and then later another annual signed of with no record of work having been performed either at the new annual or since the old annual. Something is wrong here."
...NOT NECESSARILY. It's possible the first inspector's discrepancies were found to be not valid, and a subsequent inspection proved the aircraft airworthy. In any event, the first inspector (having kept a copy of the discrepancies he'd found) is protected. The second inspector is the one "on the hook" so to speak.

In any case, writing the discrepancies into the logbooks (permanent record) is not authorized by the regulation. IMO

[futr_alaskaflyer]

In any case, writing the discrepancies into the logbooks (permanent record) is not authorized by the regulation. IMO

I'm not sure that an A&P or IA is going to write *anything* in the logbooks of my plane without my authorization. I can't force him to write anything against his will, and he can't hijack my airframe or engine logbook and write anything that I disagree with.

Which might get at the heart of the issue of what an IA's authority actually is.

[n2582d]

As far as the BAS harness goes, I would contact them and I would expect to pay a small fee for the paperwork (just to remove any doubt and that's only what I would do if I was in this situation).

I agree. Here is a copy of what I got from BAS for some tail pull handles. I think he charged me $50 for the STC paperwork. He even included a couple of rivets to attach the handles. My PMI said I could either send the paperwork directly to the FAA in OKC or, if I wanted to go the field approval route, that he would have no problem signing off on the 337.

Click to Enlarge

I've found on some used stuff, P-ponk gear reinforcement for example, it is not worth the hassle to buy from someone other than the STC holder. The cost was about the same to just buy new rather than buying used equipment (or NOS) from one person and then buying the required paperwork from the STC holder.

Why the cover-up on where these tail-pull handles came from? The owner has some BAS inertia reels for sale that I may buy!

[GAHorn]

[...I've found on some used stuff, P-ponk gear reinforcement for example, it is not worth the hassle to buy from someone other than the STC holder. The cost was about the same to just buy new rather than buying used equipment (or NOS) from one person and then buying the required paperwork from the STC holder...

An uncommon, but very good reason to buy from another end-user than the STC holder might be...in order to replace worn or damaged parts on a previous installation. (But the same warnings always hold true regarding "bogus" parts.)

[c170b53]

My (I think) last comment on this subject is that common sense must prevail. My signature means more to me than to the air operator, I can only do what is right for me. If someone doesn't want to consider my judgement then they don't need my signature, it is after all their airplane. I certainly don't need or want their troubles and unless they are in immediate danger, I'll not intervene in any way. What I have learned in aviation is that anything can and will happen even when there are numerous schemes and devices to prevent it from happening. My advice is to take the conservative approach. When things go wrong as some of us have found out, you're on your own, be prepared to defend yourself. When you do something you always have to think about how it will sound coming out of your mouth, in front of those who are tasked with judging the issue at hand. That's my M.O. and its the basis of what's in my signature.

[minton]

Jim,

I think you get into problematic areas when you step into the middle of an arguement that has two people argueing the same points using somewhat different language.

My point was that I accomplished a STC/parts transfer (Not the BAS) with the FAA's blessing using a FAA form 337 and logbook entry. Others may have some major heartburn over this. But the point I was trying to make was sometimes the FAA is trying to help you out believe it or not. In my case they were. And as I pointed out each PMI/FSDO is different in their approach. Mine prefers to use the 43.13 as a basis. If you are an A&P/AI you know the first guy in your line of sight is your PMI. If he is on board you are good to go and will probably never get into a bind.

I have found that if you ask before you begin your project you will be far better off than going toe to toe and getting your shorts in a knot after the fact. So, if you want to step out and try some new approach, get your A&P/AI to look. AND ask first!

The statement that you can withhold your logbooks and prevent the A&P/AI from entering a signature or information is at best NOT a good idea. But that A&P/AI has a responsibility to then notify the FAA of your actions and who knows what that could unleash. I've seen all manor of wording requiring signatures and type of inspection performed. Depending on the date of the previous sign off and type of inspection your aircraft could be out of annual or 100 hour. So be careful of witholding your log books and continueing to operate. Doing so could topedo you. And as Metal master I'll continue to list discrepancies in the logs just to cover my six (common sense).

Remember your A&P/AI DOES reveiw your entire logbook, including past entries, and any other paperwork you present him. Also he may contact OKC to search for any other records. He WILL take notice of any non A&P entries so as the owner of record be prepared to answer his questions. He may find that some previous work was not definded as "Minor" and as such may need some inspection and signatures. If they purtain to shoulder harness installations you may want to have the FAA postion letter in your aircraft files and a current copy of AC 43.13 just to back you up.

It is not your A&P/AI's responsibility to maintain your aircraft records so you might want to look into record requirements. Very few of what I see measure up. A shoe box full of papers will run my red flag up!

This has been a good exercise in differing points of view. However, no one should take any part of this as your ticket to run. Your A&P/AI and his PMI/FSDO have the final say. Many have far more restrictive policies in place.

[c170b53]

Whoops guess I came up too soon My last comment was a very specific statement about signatures and what it means to me when I sign logbooks. Everybody's methods may vary.

[minton]

Jim,

Thanks for your input. I'm glad you have a good sense of humor. I appreciate all A&P's chiming in on this as some non professionals that don't work daily in the industry seem to think their idealistic ways would prevail. We know that it's like working under the IRS where nothing they say on any daily basis can be held up to the fire in court. Thus their "guidance" must be tempered with our "common sense" to make it work.

John

[robert.p.bowen]

Despite George's perhaps assertion that a B.A.S. harness install is a minor modification, I disagree. To install the BAS kit, you have to remove two rivets and drill the former rivet holes larger. This serves as the anchor point for the inertia reel, with machine screws that go thru the external skin and a rather thick piece of structure.

I think you'll need the STC and complete a 337. This is what BAS recommends.

[GAHorn]

Despite George's perhaps assertion that a B.A.S. harness install is a minor modification, I disagree. To install the BAS kit, you have to remove two rivets and drill the former rivet holes larger. This serves as the anchor point for the inertia reel, with machine screws that go thru the external skin and a rather thick piece of structure.

I think you'll need the STC and complete a 337. This is what BAS recommends.

I did not assert the B. A. S. installation (using their instructions) was a minor modification. I suggested an installation of those harnesses under the provision of the FAA ACE letter was an approved method of installation. (If that letter is followed the installation of those harnesses must be accomplished by minor methods or by other approved methods.)