When is a TSO required?

[GAHorn]

OK....well.....there is some pretty wildly differing opinions going on here and the only way to resolve the issue about "belts" is to visit the FARs again...AND the ACE issued by FAA regarding SHOULDER HARNESSES....(different item than seat belts.)

SHOULDER HARNESSES in a Cessna 170 do NOT require ANY STC, PMA, TSO, or other approval than described in A.C.E. 00-23.561-01.

Don't take my word for it. Read all about it at: http://www.cessna170.org/forums/viewtop ... er+harness

[T. C. Downey]

OK....well.....there is some pretty wildly differing opinions going on here and the only way to resolve the issue about "belts" is to visit the FARs again...AND the ACE issued by FAA regarding SHOULDER HARNESSES....(different item than seat belts.)

SHOULDER HARNESSES in a Cessna 170 do NOT require ANY STC, PMA, TSO, or other approval than described in A.C.E. 00-23.561-01.

Don't take my word for it. Read all about it at: http://www.cessna170.org/forums/viewtop ... er+harness

That speaks to the installation, not the quality of the belts.

this statement is addressed to the minor modifications, which the FAA does not suggest we use.

but it does say

" We also agree that we should allow minor change installations that use non-TSO-C114 harnesses. However, apart from TSO-C114 harnesses, we will accept only those harnesses that meet the Society of Automotive Engineers Aerospace Standard 8043,
harnesses produced under a Parts Manufacturer Approval (PMA) or harnesses that meet aircraft military specification requirements. We have revised the policy statement to include these other harnesses."

Remember this FAA public announcement addresses retro fit shoulder harness, not the OEM equipment, already installed in our 170s.

[BEEZERBOY]

small point.... the original Cessna belts would not be legal unless they were metal to metal... part 91 changed that. all belts since the mid 50s are TSO (though the TSO changed several times... like 7x?)

shoulder harness was not required in the 170, but I'm pretty sure there is a nut plate installed in the rear spar as an attachment point... I know 180's have them & Bas uses that as part of the attachment.

and ya, the FAA was encouraging owners of older aircraft to install harness & were pretty light on the requirements. 337 only required if you were drilling holes, welding, etc

another "small" point.... your airworthiness certificate.... if you have one of the old ones that is pre-FAA, like from the CAA days, it was supposed to be turned in for a new one about 25-30 years ago. the old ones have blue circle on the front about the size of a teacup. the "new" ones say on the back that the aircraft will be maintained in accordance with CFR 14, FAR Parts 91, 21, and 43. that is how they hold your feet to the fire on current regs.

also.... "production certificate" aircraft.... only big manufacturers got production certificates. it simply means they had staff on hand that could do the final acceptance of the aircraft (engine or propeller... the type certified products). they could issue the airworthiness certificate themselves. manufacturers without a PC had to have each aircraft inspected by the FAA. all the other rules are the same

[T. C. Downey]

small point.... the original Cessna belts would not be legal unless they were metal to metal... part 91 changed that. all belts since the mid 50s are TSO (though the TSO changed several times... like 7x?)

They were, but none the less any belt in the aircraft when it was produced became approved by either the production certificate or the inspector in the factory.


also.... "production certificate" aircraft.... only big manufacturers got production certificates.

Cessna was a pretty big manufacturer in the 50s

and…. you will have a difficult time getting by the 91.205 requirements with any FAA inspector.
and… you will have a difficult time getting approval on a 337 for any thing but TSO'ed belt. simply because you will be required to prove it meets any of the required compliance rules.

[BEEZERBOY]

agreed.... any part approved at certification of the product is ok... unless there is an AD, or another regulatory change (ADs are amendments to Part 39).

Part 91 was changed in the early 80's to make all belts metal to metal clasps and to conform to a TSO (that was the intent).

because your aircraft MUST be maintained AIW FAR21, 43, and 91, those rules are in effect no matter the certification basis. are the original belts from 1950 metal to metal? if yes and they are in good condition they are still OK.

this whole thread is really about a more important issue. condition is pretty easy to check.... there are definitions (147 app A).... and there are plenty of checklists that meet 43.15 and 43 App D... the hard part is conformity, the other half of "airworthy".

read 43.15. when a mechanic performs an inspection.... annual, 100 hr, progressive.... he must assure the aircraft meets "ALL" airworthiness requirements... thats a big deal.

will it still fly with undocumented repairs or alterations? NAPA parts? ya, probably, but your mechanic is risking his license if he doesn't find it, or worse yet, lets it go.

BTW.... your insurance.... no good if the aircraft was not airworthy at the time of the indecent. I was an expert witness a couple times in airworthiness issues.

[bagarre]

Well, this want the direction I was hoping this thread would go as the seatbelt debate has been beaten enough over the years.

My REAL question was concerning gauges, radios and Nav equipment in VFR and IFR airplanes.
Maybe I should have worded my question differently.

[Bruce Fenstermacher]

Tom,

The path of least resistance is for seat belts to meet the TSO. And likely seat belts found today meet the TSO. However it is not the only way to have legal seat belts.

Seat belts are not shoulder harnesses, they are different than seat belts, specially in the 170. There where no OEM 170 shoulder harnesses prior to the B model. And then in the B model they where an option. You can and I did install shoulder harnesses in my B model under a minor alteration. I made my shoulder harnesses using material components that happened to be SAE certified and or meet a TSO. It was not a complete system that meet SAE or TSO. I did not modify the aircraft structure or the other wise required seat belt system at all as part of the shoulder hardness installation. I used Policy Statement Number ACE-00-23.561-01 http://www.faa.gov/aircraft/gen_av/harn ... policy.pdf. This policy statement, when you boil it down says than when a shoulder harness is installed under a minor alteration, which means the installation is done with certain restrictions, that the material used does not have to meet any standard because in essence anything installed has to enhance what the seat belts that are required to be installed.

As for shoulder harness installation in our 170s I do not recommend the path I took for that aircraft. For most it is simply not worth the time or effort. I just happen to have all the parts and the right set of circumstance. I do recommend one of the systems available which happen to be STC'd and also happen to meet TSO.

[Bruce Fenstermacher]

Well, this want the direction I was hoping this thread would go as the seatbelt debate has been beaten enough over the years.

My REAL question was concerning gauges, radios and Nav equipment in VFR and IFR airplanes.
Maybe I should have worded my question differently.

George answered your question here:

Short answer to OP, "No." When our aircraft were certificated there were not "TSOs" and therefore none applied. Some regulatorily req'd equipment has been invented since then (ELTs, GPS's, solid-state radios, etc.) and some of those must meet installation/performance requirements defined by their TSO's....and so must meet those standards.
Most items in our aircraft are not req'd to be TSO'd, unless they are "essential" equipment such as req'd equipment (front seat shoulder harnesses installed in aircraft built after 1978(*) such as ELTs. VFR aircraft are not req'd to have TSO'd instrumentation as long as the instruments meet another form of FAA/CAA/Military approval (i.e., AN/NAS/MS).

[T. C. Downey]

Tom,

This policy statement, when you boil it down says than when a shoulder harness is installed under a minor alteration, which means the installation is done with certain restrictions, that the material used does not have to meet any standard because in essence anything installed has to enhance what the seat belts that are required to be installed.

IOWs this sentence means nothing.

quote
We also agree that we should allow minor change installations that use non-TSO-C114 harnesses. However, apart from TSO-C114 harnesses, we will accept only those harnesses that meet the Society of Automotive Engineers Aerospace Standard 8043, harnesses produced under a Parts Manufacturer Approval (PMA) or harnesses that meet aircraft military specification requirements. We have revised the policy statement to include these other harnesses.

[Bruce Fenstermacher]

Tom, I see what your getting at. At first I thought perhaps I had an obsolete policy statement. I went back to the FAA site and searched for ACE-00-23.561-01 and found only this same policy.

The problem is the paragraph you quoted which included the words "we will accept only those harnesses that meet the Society of Automotive Engineers Aerospace Standard 8043,......" is not in the policy itself but in the part of the document where they discuss comments to the policy. It then goes on to say as you quoted "We have revised the policy statement to include these other harnesses." but this document is the only document I can find regarding ACE-00-23.561-01 and no revised statement is readily found at the FAA site. Did they ever revise it.? Saying the will doesn't make it so. Perhaps the policy was replaced with something else which would prove the missing link here.

In any case I should stop saying you could make a harness out of shoe strings because it's likely it at least now has to met SAE but not TSO.

[T. C. Downey]

Tom, I see what your getting at.

what you are reading is a policy that the FAA has adopted for the approval of the installation, it does not supersede the authority of FAR 91.205 (b) (13) for approved belts.

In some way shape or form you must be able to prove compliance to "approved" this policy does not do this, it only talks about the approval process and what methods of installations are acceptable, and shows what the 3 methods are. The STC which is approved data, the field approval which becomes approved data when the FAA signs block 4, and then the minor modification that you did, which must show in the log entry the method that the belts meet the quality that is required in the policy statement. I would be looking for a statement in that entry that says, " These belts meet the requirements of _____." or words to that effect.

[BEEZERBOY]

so Davids question..... "My REAL question was concerning gauges, radios and Nav equipment in VFR and IFR airplanes." is answered, though you still have to sort it out. things like radio & nav equipment have to be TSO or meet a known standard like a Mil Spec.

the trick part on instruments is things like the engine gauges. they are supposed to be a Cessna part number. Cessna didn't build the gauge though, somebody like Stewart Warner did. can you just install a S/W gauge as a replacement? technically no, not without further approval. will it work? yes. will anybody know the difference? probably not. you run into the same thing on a host of other "support" equipment like switches, relays, and push/pull controls. roll the dice.

back to instruments.... GPS is a good example. a good way to make the determination is that anything that is permanently attached and/or hard wired into the ship's electrical system is "installed" and has to be approved & documented.

[T. C. Downey]

so Davids question..... "My REAL question was concerning gauges, radios and Nav equipment in VFR and IFR airplanes." is answered, though you still have to sort it out. things like radio & nav equipment have to be TSO or meet a known standard like a Mil Spec.

the trick part on instruments is things like the engine gauges. they are supposed to be a Cessna part number. Cessna didn't build the gauge though, somebody like Stewart Warner did. can you just install a S/W gauge as a replacement? technically no, not without further approval. will it work? yes. will anybody know the difference? probably not. you run into the same thing on a host of other "support" equipment like switches, relays, and push/pull controls. roll the dice.

back to instruments.... GPS is a good example. a good way to make the determination is that anything that is permanently attached and/or hard wired into the ship's electrical system is "installed" and has to be approved & documented.

All instruments/radios/gauges are not required to be TSO compliant in part 91. Some have a TSO on them, but they are also used in part 135/125 usage where TSO compliance is required in some cases.

Replacement parts in 91 need only be FAA/PMA replacements. NO TSO needed.

[BEEZERBOY]

be careful... note that your airworthiness certificate says the aircraft will be maintained per Parts 21, 43, and 91.

read 21.303... this is the section the FAA uses to determine what constitutes an aircraft part. replacement parts must be: PMA, OEM, TSO, a piece of standard hardware, or in some cases a part that your mechanic fabricates.

of the above, only the OEM part is a direct installation with only a log book entry required (assuming it's a proper part number replacement). most OEM parts are not under any of the other standards, but are identified by part number.

some PMA parts are specific and are a straight fit (like a piston), some require a 337 (BAS handles)... heck, even a Brackett filter is supposed to have a 337. Shaden fuel flow.... PMA, comes with a STC, 337 required.

being a TSO part does not make the installation approved (like cutting a hole & making a mount, etc) it is simply a part built to a standard, and eligible for installation on type certified aircraft. accepted as a direct replacement of a like item.

replacing a required instrument with a non TSO could result in a violation (and invalidate your insurance too) unless there is a different approval, like by STC or possibly through 21.305

[T. C. Downey]

be careful... note that your airworthiness certificate says the aircraft will be maintained per Parts 21, 43, and 91.

read 21.303... this is the section the FAA uses to determine what constitutes an aircraft part. replacement parts must be: PMA, OEM, TSO, a piece of standard hardware, or in some cases a part that your mechanic fabricates.

21.303 Application.
(a) The applicant for a PMA must apply in a form and manner prescribed by the FAA, and include the following: