When is a TSO required?

[BEEZERBOY]

we are essentially saying the same thing, and I agree... a PMA part is acceptable if it is appropriate for the installation, and properly installed & logged.

EDIT.... sorry, the FAR was changed a couple years ago, I was quoting from the earlier version of 21.303 when that was the official reference. the new regulation says much the same thing though, but more concise, and more restrictive.....

§ 21.9 Replacement and modification articles.

(a) If a person knows, or should know, that a replacement or modification article is reasonably likely to be installed on a type-certificated product, the person may not produce that article unless it is—

(1) Produced under a type certificate;

(2) Produced under an FAA production approval;

(3) A standard part (such as a nut or bolt) manufactured in compliance with a government or established industry specification;

(4) A commercial part as defined in § 21.1 of this part;

(5) Produced by an owner or operator for maintaining or altering that owner or operator's product; or

(6) Fabricated by an appropriately rated certificate holder with a quality system, and consumed in the repair or alteration of a product or article in accordance with part 43 of this chapter.

(b) Except as provided in paragraphs (a)(1) through (a)(2) of this section, a person who produces a replacement or modification article for sale may not represent that part as suitable for installation on a type-certificated product.

(c) Except as provided in paragraphs (a)(1) through (a)(2) of this section, a person may not sell or represent an article as suitable for installation on an aircraft type-certificated under §§ 21.25(a)(2) or 21.27 unless that article—

(1) Was declared surplus by the U.S. Armed Forces, and

(2) Was intended for use on that aircraft model by the U.S. Armed Forces.



From FAR 21.1..... "(6) Production approval means a document issued by the FAA to a person that allows the production of a product or article in accordance with its approved design and approved quality system, and can take the form of a production certificate, a PMA, or a TSO authorization"

type certificate parts are "OEM", so..... OEM, TSO, PMA..... for the big parts, instruments, etc thats it folks.

I seriously doubt the FAA will grant a PMA for something like an airspeed indicator when the TSO already exists as the known standard.

[BEEZERBOY]

and just so there is no confusion, from 21.1

"3) Commercial part means an article that is listed on an FAA-approved Commercial Parts List included in a design approval holder's Instructions for Continued Airworthiness required by § 21.50"


an "owner produced part" is typically a simple part made by a mechanic from known materials with acceptable information to repair or alter ONE airplane. it may require further approvals to install

a "certificate holder with a quality system" is typically a 121 airline with heavy maintenance capability or a 145 Repair Station

[T. C. Downey]

and just so there is no confusion, from 21.1

"3) Commercial part means an article that is listed on an FAA-approved Commercial Parts List included in a design approval holder's Instructions for Continued Airworthiness required by § 21.50"


an "owner produced part" is typically a simple part made by a mechanic from known materials with acceptable information to repair or alter ONE airplane. it may require further approvals to install

a "certificate holder with a quality system" is typically a 121 airline with heavy maintenance capability or a 145 Repair Station

Where did this thread take the turn to owner produced parts.

there isn't a thing in the instrument panel as requested by the op that is TSO required other than the stated equipment the ELT, transponder, seat belts, and the equipment stated.

[BEEZERBOY]

I thought the thread took a turn to describe what constitutes an "aircraft" part. FAR 21 has the answer as far as the FAA is concerned. there is usually confusion as to what an owner produced part is.... it is the least clear of the items on the list. this is the reg that lets your mechanic can fabricate a brake line, a control cable, a fuel hose, or even a wing skin as long as known materials and methods are used, and only one is made to repair one aircraft (you can't make 2 & sell the other).

as for the OP..... the original engine instruments are Cessna (OEM).... replace with OEM part numbers.

an aftermarket engine package is prolly a PMA and installed by an STC. that would also be an acceptable replacement for the originals

the horizon, altimeter, airspeed..... all have a TSO. replace with TSO or a Cessna part number. you might be able to make a case for RTCA/DO-160 spec equipment or something meeting a JAR accepted standard.

if you have doubt call the local FSDO and ask a PMI (you decide if you want to tell him your real name)

yea, I have a AI. close to 40 years A&P, 36 as Inspector, I taught in an A&P school for 20 years, still do a class once in a while but retired from my faculty position 3 years ago. during the summers, I maintained my own small business doing inspections, maintenance and Alaskan mods on Suoercubs and 180/185s primarily. I am semi-retired.... have cub on floats. I build hovercraft for a hobby.

[T. C. Downey]

If it is not a stated requirement id part 91 there is no requirement for TSO'ed equipment in part 91. Any part that is FAA/PMA'ed and meets the form and fit of the OEM equipment is legal. other wise we could never use any equipment other than what was installed. Think Gyros, how many styles are used these days ? and we see how many field approvals gaining FAA approvals to install?

[BEEZERBOY]

nope.... not in 91... the requirement is in Part 21

look at the back of your Airworthiness Certificate.... it says you will maintain the aircraft per 21, 43, and 91

if you have the old CAA certificate with the blue logo.... it is obsolete & should have been replaced

[T. C. Downey]

nope.... not in 91... the requirement is in Part 21

where ?

[BEEZERBOY]

the list of acceptable aircraft parts is in § 21.9 Replacement and modification articles.

most of that used to be in the old version of 21.303, in Par (a) and (b)... those paragraphs were moved and modified a couple years ago to become 21.9. The text sounds like it is addressed to manufacturers, but that was always the reference the FAA used to approve or allow the installation of a part/appliance/article as well. the FAA up here has been telling us for 40 years (that I know of) that if a part isn't made under one of the methods on the list, it isn't acceptable on a type certified airplane

91.205(a) implies that the instruments will be approved, but 21.9 pretty much makes it certain

if and how the reg is being enforced in your area, I can't tell you. I'm pretty sure they are turning a blind eye to at least some of that. I'll make some discreet inquiries & get back to you. like most things airplane.... it's all good until you crash.

[T. C. Downey]

There is no mention of TSO in either of your references.
21.9 Replacement and modification articles.
(a) If a person knows, or should know, that a replacement or modification article is reasonably likely to be installed on a type-certificated product, the personmay not produce that article unless it is—

(1) Produced under a type certificate; Cessna can produce Cessna part for sale to you

(2) Produced under an FAA production approval; FAA / PMA

(3) A standard part (such as a nut or bolt) manufactured in compliance with a government or established industry specification; AN MS and NAS hardware built to a specifice Mil spec

(4) A commercial part as defined in § 21.1 of this part;

(5) Produced by an owner or operator for maintaining or altering that owner or operator's product; or

(6) Fabricated by an appropriately rated certificate holder with a quality system, and consumed in the repair or alteration of a product or article in accordance with part 43 of this chapter.

(b) Except as provided in paragraphs (a)(1) through (a)(2) of this section, a person who produces a replacement or modification article for sale may not represent that part as suitable for installation on a type-certificated product.

(c) Except as provided in paragraphs (a)(1) through (a)(2) of this section, a person may not sell or represent an article as suitable for installation on an aircraft type-certificated under §§ 21.25(a)(2) or 21.27 unless that article—

(1) Was declared surplus by the U.S. Armed Forces, and

(2) Was intended for use on that aircraft model by the U.S. Armed Forces.

[Doc. No. FAA-2006-25877, Amdt. 21-92, 74 FR 53385, Oct. 16, 2009; Amdt. 21-92A, 75 FR 9095, Mar. 1, 2010]

91.20591.205 Powered civil aircraft with standard category U.S. airworthiness certificates: Instrument and equipment requirements.
(a) General. Except as provided in paragraphs (c)(3) and (e) of this section, no person may operate a powered civil aircraft with a standard category U.S. airworthiness certificate in any operation described in paragraphs (b) through (f) of this section unless that aircraft contains the instruments and equipment specified in those paragraphs (or FAA-approved equivalents) for that type of operation, and those instruments and items of equipment are in operable condition.

TSO'ed instruments are not required in part 91 unless a specific instruction states they are, such as the Transponder ELT.

AS many mechanics read these instructions, they read into them what is not there.

[BEEZERBOY]

sigh........... from a previous post:

From FAR 21.1..... "(6) Production approval means a document issued by the FAA to a person that allows the production of a product or article in accordance with its approved design and approved quality system, and can take the form of a production certificate, a PMA, or a TSO authorization"

type certificate parts are "OEM", so..... OEM, TSO, PMA..... for the big parts, instruments, etc thats it folks.
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I already said that an instrument of any purpose, that anything that came with the aircraft at certification, or that has a manufacturer's part number are legit (and probably anything with an 8130-3... with usuall caviots).

but... just where does it say in part 91, or any other FAR that TSO instruments are not required in a type certified aircraft? the "FAA approved equivelents" referenced in Part 91 are listed in 21.9

[T. C. Downey]

This thread was about TSO requirements.
Quote
but... just where does it say in part 91, or any other FAR that TSO instruments are not required in a type certified aircraft? the "FAA approved equivelents" referenced in Part 91 are listed in 21.9

You and every A&P-IA should know that the FAA does not work this way. If there is no stated requirement, there is no requirement.

[BEEZERBOY]

all I know is for the almost 40 years I've been in aircraft maintenance, the FAA would foam at the mouth over what constitutes an aircraft part.... 21 was always the reference. maybe this will make you happy....from AC20-62 E... (which is not a regulation and has no enforcement power) this a 2010 version...

"Conforming to Regulations. As part of determining whether installation of an article conforms with all applicable regulations, the installer should establish that the article was manufactured under a production approval pursuant to part 21, that an originally acceptable part has been maintained in accordance with part 43, or that the part is otherwise eligible for installation (i.e., has been found to conform to data approved by the FAA). This AC addresses means to help the installer make the required determinations.
7.
IDENTIFICATION OF REPLACEMENT PARTS. Acceptable replacement articles should be identified using one of the following methods:
a.
Airworthiness Approval Tag. FAA Form 8130-3, Airworthiness Approval Tag, identifies a part or group of parts for export approval and conformity determination from production approval holders. It also serves as approval for return to service after maintenance or alteration by an authorized part 145 repair station, or a U.S. air carrier having an approved CAMP under parts 121 and 135."

so........ if it has an 8130-3 and is appropriate for the purpose it is legit. the next question is, will a 145 issue an 8130-3 to a non-TSO instrument?

or.... has anyone purchased a non TSO instrument and had it come with an 8130??

[bagarre]

So then I DO need a TSO'd cigarett lighter?
Anyone want to put a bet on me running out and buying one of those?

This may be the first thread where I feel that I understand LESS about the topic after reading it.

[voorheesh]

I appreciate these 2 experienced IAs sharing this information and really don't care whether the exact topic is related to TSOs or approved parts. These are important issues and the rules are more legalese then straight forward language. Your references are very helpful to the average owner/pilot gaining understanding. I believe it is good for aircraft owners to have some insight on approved parts, A&Ps certainly "should" have this knowledge, and IA's "must" have it. Thanks for letting the rest of us in on this discussion!

[BEEZERBOY]

the cigar lighter would be a Cessna part number... thats the theory... but every day somebody puts in an Autozone receptacle. there are a host of small parts that fall into that area... switches, relays, etc they may even have been made by the same company that made the ones for Cessna. not 100% legal unless there is some kind of approval. on the other hand.... hard to prove that some of these parts aren't OEM. I think the FAA has turned a blind eye to some of it because of that reason. (as long as you don't crash)

but........ from AC20.62, you might be able to make a case for it only needing to be inspected prior to installation:

"Discrete Electrical and Electronic Component Parts. Electrical and electronic parts, such as resistors, capacitors, diodes, and transistors, if not specifically marked by the equipment manufacturer’s part number or marking scheme, may be substituted or used as replacement parts, provided that such parts are tested or it is determined that they meet their published performance specifications and do not adversely affect the performance of the equipment or article into or onto which they are installed. The performance of such equipment or article must be equal to its original or properly altered or repaired condition. Integrated circuits such as hybrids, large scale integrated circuits (LSIC), programmable logic devices, gate arrays, application specific integrated circuits (ASIC), memories, CPU’s etc., are not included because their highly specialized functionality does not readily lend itself to substitution."

bearing in mind that the above, like all ACs, have no regulatory power and are not approved data.... not even AC43.13. (on the other hand a good case for CAM 18 might be made... which is its predecessor & was concurrent with CARs)

trust me... it drives mechanics insane too. sometimes we know what works, but not allowed without a huge hassle. the list is long.... but thats why you'll see mechanics sticking to the known references.