BAS inertia reel system

[minton]

Well, Let's see you market my Chevy harnesses for use in your 170. FAA will be all over you like a nylon jump suite.

Sorry George,

We are not, nor have we ever been talking about what can be installed. But if it is, it has to comply with standards weather they are the newer or older. The reasons for standards are to ensure the installation and part is safe. AND Does'nt compromise the aircraft structure. I challenge you to tye your rope around your carrythrough spar and pass annual. If it's an automotive part it probably could be installed in your part 91 170. But if it's not installed to meet standards put forth in FAA publications my name won't be on the sign off! Would you sign it off??

So, In closing this blog for my last time, I would refer you to your own words refering to people who send you (PM's) Are we here for education of members or to argue over symantics and shame them into NEVER getting involved?

In closing:

Don't buy parts that you can't trace. Don't buy parts from strangers (EBAY) (or take candy). Don't buy planes with questionable or incomplete records. Don't buy airplanes or engines with reconstructed logs. And if you climb into your next ride and see Gomer sitt'in next to you with his green teeth a grinn'in et ya. Go home (not with Gomer) and have a cool one.

[minton]

WAIT A MINUTE!! You are saying to me if that a harness has installation issues that compromise the structure I can't down the plane??

Can you operate your plane with outstanding items not complied with? If they relate to airworthiness, I think not!

I'm done with this. You should be to!

Lets go have a beer sometime.

[GAHorn]

Well, Let's see you market my Chevy harnesses for use in your 170. FAA will be all over you like a nylon jump suite.

Sorry George,

We are not, nor have we ever been talking about what can be installed. But if it is, it has to comply with standards weather they are the newer or older. The reasons for standards are to ensure the installation and part is safe. AND Does'nt compromise the aircraft structure. I challenge you to tye your rope around your carrythrough spar and pass annual. If it's an automotive part it probably could be installed in your part 91 170. But if it's not installed to meet standards put forth in FAA publications my name won't be on the sign off! Would you sign it off??

So, In closing this blog for my last time, I would refer you to your own words refering to people who send you (PM's) Are we here for education of members or to argue over symantics and shame them into NEVER getting involved?....

I'm certainly NOT trying to "shame" anyone or discourage anyone from participating in the conversation. After all....that's why we're discussing THIS subject, right?

As for installing your Chevy harness in a 170... I'd certainly recommend you read the entire FAA position letter and associated materials available from FAA on this subject before continuing to opine repetitiously.

Directly from the FAA statement:
"Regarding these rules we conclude
that if a shoulder harness is not required
equipment, it is not essential to the safe
operation of the airplane."

Minton, if a piece of equipment is not essential, then it's "non-essential equipment' and does not have to be in airworthy condition for flight.
Now my comment regarding the "rope" was tongue-n-cheek, but if you read the FAA position on materials you'll find they happily endorse (since, by virtue of the minor alteration they cannot dis-approve of) any harness which meets common automotive harness standards in this application.
Quote: " Regarding these rules we conclude that if a shoulder harness is not required equipment, it is not essential to the safe operation of the airplane. Therefore, CAR 3.652 and § 23.1301, before
Amendment 23–20, should not be used as a basis to prohibit shoulder harness installation by minor change." While they originally insisted that only harnesses meeting SAE STd 8083 would be "approved"...they later came to realize, by virtue of their own "approval not required" position/policy, ...that they cannot prevent or disapprove of ANY harness that is not required equipment. They eventually resorted to simply making the recommendation to install equipment meeting the minimum standards of the automotive industry. (But still, that was only a recommendation.)
So your Chevy harness is just fine. (And if I install a piece of rope that does not alter the airframe then it's simply a piece of upholstery and you cannot "unapprove" my rope which requires no approval. I can run a #10 MS-screw thru it and into the rear spar #10 nutplate (factory installed) and my rope does not make my airplane unairworthy. I can hang a piece of soap on it, or I can tie it around my shoulders if I want.)

WAIT A MINUTE!! You are saying to me if that a harness has installation issues that compromise the structure I can't down the plane??....

Nope, definitely NOT saying THAT! If the installation has issues that compromise the airframe then that's certainly not something you can approve for return-to-service. The ACE-letter specifically states that in addition to approved methods (STC, Field Approval, etc.) that in these aircraft a non-approved harness may be installed by "minor" alteration, which by definiiton makes no structural alteration and therefore requires no approval.

(But, YES...I AM saying you cannot "down the airplane!" Now this is only a discussion among friends, about "opinions" we obviously both feel strongly about it. I am not trying to butt-heads....I just feel strongly you misunderstand your authority. In my opinion you may either approve the aircraft for return to service.... or you may refuse to approve it. (But you do not have the authority to write in it's mx records that it is unairworthy...you merely don't sign off an approval. You enter that you completed the inspection and gave the list to the owner.) You don't have the authority to DOWN a person's airplane unless you are the Fed.

[minton]

Please define return to service. Might it say that I as the A&P that by signing the log book the aircraft, I was, in my opionion rendering it airworthy? That specific language has to state "FOUND TO BE IN A AIRWORTHY CONDITION" and withholding my signature leaves the aircraft unairworthy in a sense. Am I in the ball park so far? If I find unairworthy items attached to the airplane is it now unairworthy? If I remove those items is it now airworthy? IF I deem it so I guess it is. I can't just hand a guy a list of items. I have to note in the log book that an inspection took place and the craft had some unairworthy items outstanding that required attention and a return to service sign off. In other words it is now unairworthy and NOT good to go. If those items are ignored, well in a sense I rendered the craft unairworthy. You go over to the FEDs and get them to release it in that condition and they will tell you "It's unairworthy" get an AI/A&P to return it to service, deem it "Airworthy". Viola! I was just empowered to render an aircraft unairworthy by withholding my signature. I'd be willing to buy you a doughnut if you could get one of "THEM" to sign it off! They'd be diving for their fox holes!

So, Getting back to BAS and their inertia harness. They hold an STC issued and approved by the FAA. It contains specific requirements for installation. That is the only method approved for installation unless you get further FAA approvals. Those instructions require methods that are more complex than "Minor" in nature. So this requires the installer to be at least under the supervision of an A&P and signed off by the A&P. Owners are not authorized to sign this one off in the logbook. My installation signatory statement has to contain wording that the item will be inspected and conform to continueing airworthiness standards. They can't have it both ways. Get them (FAA) to not require that statement and I'll gladly never inspect another harness for correct installation and airworthiness again!

Don't make another left turn and state that you are using an exhisting fixure or anchor point to mount your rope. Lets keep the apples and oranges separated. If you drill new holes or attach it to a newly installed anchor point using more than "minor methods" you just shot yourself in the foot. You are mixing the mounting methods with the device that you are mounting. The methods are what will hang you. Safe operation has to include the operator deeming the aircraft to be in a safe condition. The FAA issueing these these renditions of their requirements are based more on FAA legal keeping them out of potential hot water since they have not put into place a reliable way of tracking these webbed nightmares they call restraints than any other issues that I'm aware of. I sure can't tell what's good and bad by their standards other that good old 43.13.

And where it all BEGAN! Check with your FEDS. My FED sez I can sell an STC'd item and thus transfer ownership without notifying the STC holder, As long as I'm not using the data for manufacting any more of the item.

Now lets be friends. I'll be the commentator and you act as the Moderator. I prefer to get my official guidance from those guys that are'nt happy til I'm not happy.

[GAHorn]

Please define return to service. Might it say that I as the A&P that by signing the log book the aircraft, I was, in my opionion rendering it airworthy? That specific language has to state "FOUND TO BE IN A AIRWORTHY CONDITION" and withholding my signature leaves the aircraft unairworthy in a sense. Am I in the ball park so far? If I find unairworthy items attached to the airplane is it now unairworthy? If I remove those items is it now airworthy? IF I deem it so I guess it is. I can't just hand a guy a list of items. I have to note in the log book that an inspection took place and the craft had some unairworthy items outstanding that required attention and a return to service sign off. In other words it is now unairworthy and NOT good to go. If those items are ignored, well in a sense I rendered the craft unairworthy. You go over to the FEDs and get them to release it in that condition and they will tell you "It's unairworthy" get an AI/A&P to return it to service, deem it "Airworthy". Viola! I was just empowered to render an aircraft unairworthy by withholding my signature. I'd be willing to buy you a doughnut if you could get one of "THEM" to sign it off! They'd be diving for their fox holes!....

Nope, Naw, and No.
Firstly, you do not have the choice to "withhold" your signature. If you withhold your signature after performing any type of work or any portion of any inspection, you do not "render" the aircraft unairworthy. (It is or it isn't based upon it's condition, not your failure to follow the FARs by signing your work/inspection as FARs require.) If you perform any portion of any work or inspection of an aircraft you MUST ENTER INTO THE MAINTENANCE RECORDS of the aircraft what work/inspection you performed AND YOU MUST SIGN THE ENTRY. If you don't....then it is YOU who are violating the FARs, not necessarily the owner/operator who may take his airplane somewhere else.

Define "return to service"? Ok. Here's my definition, and one I believe is supported by FAA: A mechanic/inspector does his work/inspection and enters the information describing his task and signs his work. In his entry he must "approve for return to service"...or he must "provide a list of discrepancies to the owner" immediately prior to his signature.

If you remove items you think are "unairworthy"... NO you don't make it "airworthy". Why? Because you removed installed items and did not sign your work. (I.E. log it and revise the wt/bal and equipment list and approve return to service.)

"I can't just hand a guy a list of items." YES! YOU CAN! In fact, YOU ARE REQUIRED TO DO SO.

"I have to note ... the craft had some unairworthy items outstanding that required attention and a return to service sign off." NO! YOU DON'T! What you do is simply log the work/inspection and note that a list of discrepancies has been provided the owner. Sign it. PERIOD! (You DON'T "approve for return to service"...nor do you specify that it is not approved. You simply don't "approve for RTS." (You keep a copy of the list for your own records. You do not list them in the mx logs. The owner takes the list, satisfies it, and then when those outstanding items are satisfied in accordance with (IAW) FAR's the person satisfying the list "approves for RTS"

Who actually "returns the aircraft to service?" The pilot or owner/operator does that task. Hopefully after the discrepancy list is satisfied. (He did so either WITH or WITHOUT "approval".)

"If those (unairworthy) items are ignored, well in a sense I rendered the craft unairworthy." Nope. YOU did not render it unairworthy. You may have FOUND it unairworthy, but your inspection does not "render" it unairworthy as long as you perform the work correctly. (An inspection is only that...an inspection. The inspection "finds" airworthy or unairworthy conditions. If essential items are airworthy then the inspector may "approve" for RTS. If he finds essential/required equipment unairworthy...he withholds approval. (But he signs the fact he performed the inspection.)

...So, Getting back to BAS and their inertia harness. They hold an STC issued and approved by the FAA. It contains specific requirements for installation. That is the only method approved for installation unless you get further FAA approvals. ...

Again, ....NOPE! You can install the harness under the terms and instructions of the STC. OR...you may install it as a "minor alteration" IAW a field approval or with ACE–00–23.561–01 , (the latter provided no major structural alterations are made to the airframe.) Just because you purchase a harness from someone who has a particular approved method of installation, does NOT force you to install it only that way...at least not in the front seats of a pre-1978 airplane like a Cessna 170.

" Don't make another left turn and state that you are using an exhisting fixure or anchor point to mount your rope. Lets keep the apples and oranges separated. If you drill new holes or attach it to a newly installed anchor point using more than "minor methods" you just shot yourself in the foot." Actually I didn't think I was mixing things., but I think maybe you are in wording your argument this way. I didn't drill new holes when I installed my shoulder harnesses. Used an existing hole to install my non-PMA, non-TSO, non-STC's shoulder harnesses. Quite legally. I could probably have even used rope if I'd wanted to.

We agree on two things completely: I think the advice you previoulsy suggested (to attend a refresher course for AP/IA's) is great advice. And, "Now lets be friends. ...I prefer to get my official guidance from those guys that are'nt happy til I'm not happy."

For pictures of the installation I've described which I made to my airplane:
http://www.cessna170.org/forums/viewtop ... ner#p44051
Tell me, on what basis would you "disapprove" of returning my airplane to service should you be performing my annual and found this un-required equipment which is properly logged into the records and equipt. list? (Hint: At least 4 different inspectors have found it airworthy and one FAA-type from the very picky SAT-FSDO has conducted a check-ride in the airplane while using them.)

[minton]

George,

I showed this drivel to my POI. All me could do is laugh and told me to tell you to get a life. You can't argue with a guy that presents such a moving target that you fall off of your chair! Let him have the last word.... Well I can't.

You are not the authority that you profess to be. Don't put yourself out there as such. You could mislead someone into doing something they have no business doing.

And when addressing a subject as moderator it is your task to keep whatever discussion on task and not ricocheting around like a shot inside a barrel.


Folks: refer to 43.13 Appendix D, Item J, relating to should harness installation and inspection. And while your nose is in the bible look up what is authorized under "routine maintenace".

Second, your aircraft can be noted as unairworthy after inspection and providing you a list of items deeming the aircraft "Unairworthy". Until those items are corrected and signed off by at least a A&P your airplane is unairworthy. If I am the guy asked to correct those items and refuse I'm not breaking any regs by witholding by signature.. and until those items are corrected and signed off the craft is still unairworthy by way of my pen. If though I did the work and refused I might have some problems. Who made it unairworthy? My AI inspection and log book statement saying so.

What I can't do is walk up to your plane and give it a look and make some statement to you that I'm downing your plane. I might give your friendly FSDO a call though.

We as AI's don't just shoot from the hip. When we have questions we consult our Principal Maintenance Inspector for guidance not George Horn.

So, I downed your aircraft per my authority granted to me by the FAA.

If you want my POI's phone number contact me through a PM. He said he'd be glad to chat with you. Be prepared to stay on subject.

[minton]

Tell you what George, This March when we have our annual AI meeting, I'll bring this text along for all to comment on. We began this with a (I thought) simple statement about STC sales. It at your direction morphed into me trying to torpedo some guy trying to help someone else and interjecting the advisor circular crap. If you would take the time to read the entire text you might detect a constant nudging the discussion towards other subjects and others (myself) trying to keep it on track. Well that went to hell in a hand basket! How did we get from there to me having my head up my A__ on airworthiness?? Not by my key strokes! I did'nt start the finger pointing! Have you gotten my nudges on keeping the discussion on track?? If these discussions have to always end on your note maybe a little reflection is in order by both of us.

What I have come away with? Well, not to enter into ANY discussions after certain persons chime in. You might also look up Moderator in the dictionary, does'nt seem to match your interpretation. I'm not going to waste my time trying to keep the discussion on track. I chime in say my piece and don't expect to get thrown into the shreader.

You did however raise a good point , 43.13 requiremets vs FAA positon letters. If in fact the position letter takes presidence I will admit my error and push to get our FSDO to retrain their troops on 43.13 Appendix D Item J. It clearly puts us AI's in a real bad position and I am certian that was not their intent. But to continue to require us to adhear to 43.13 standards really muddies the water. I however have no choice but to continue signing as I am now required. I work here in the trenches and the view is totally different when certificate action is held over your head on a daily basis.

PS. Your reference to field approvals somehow altering my sign off obligations is wrong. I am still required to offer up a continuous airwothiness plan for approval based on 43.13 App D item j and when reurning the craft to service you will see it reflected in the 337....

I prefer to take a straight on approach to my obligations to my clients, this meaning if they want me in the picture pitching their case we don't look for grey areas to pursue our ultimate ends. They seem to prefer it that way. And! come back for more.

[blueldr]

Minton,
Where are you located? I want to make sure that my sixty year old aiplane doesen't get snaged in your net.

[jrenwick]

Please, this has gone downhill far enough. Can we just make it stop now?

Thanks,

John

[minton]

Hey BL, Whats your beef?? I saved your BAS purchaser some dough and headaches by not having to deal with BAS transfer fees and paperwork. All that you had to do is give him a bill of sale referencing serial numbers, N number of aircraft removed from and hand him your copy of the STC referencing those units by serial number. Did he come for his money back or something?? Or did you and he ignor my recommendations?? Or maybe the darn serial numbers rubbed off?? If thats the case take it up with BAS and the FAA types that allowed that type of identifcation to be used. Probably no tracking requirement either. Again not my fault. I'm waiting to see the FAA send out an AD on them. I'll just look for the mushroom cloud to form over the first guy that finds no way to ID them and has to get them recertified and a real form of ID attached at his expense. Sometimes you can have a good laugh rather than screwing yourself into the ceiling.

I had no intention of Queering your deal if in fact I did..

I guess you don't remember the like new carb air box I sold to you for peanuts. Don't recall you bitching then. Did I misrepresent something to you?

I live right down the street from you in Citrus Heights.

No nets set out here just straight up dealings with clients and FAA. We can't be navigating the backwaters these days. I'd be glad to sign on as your personal FAA system navigation consultant.

[GAHorn]

I have to admit that I'm remorseful for the down-hill slide of this discussion, and I wish it hadn't occurred. Perhaps I should have withdrawn from the discussion earlier, but I thought I was contributing to clarifying this difference of opnions.
Now it seems that instead of wholesome discussion the thread has devolved into personal name-caling and that's certainly not what we all ought to be doing. I apologize for any input of mine that allowed this. I thought I was only expressing a personal opinion which I believe to be correct.

Here's the pertinent regulation on the subject we have been discussing:

FAR 43.11 Content, form, and disposition of records for inspections conducted under parts 91 and 125 and §§135.411(a)(1) and 135.419 of this chapter.

(4) Except for progressive inspections, if the aircraft is found to be airworthy and approved for return to service, the following or a similarly worded statement—“I certify that this aircraft has been inspected in accordance with (insert type) inspection and was determined to be in airworthy condition.”
(5) Except for progressive inspections, if the aircraft is not approved for return to service because of needed maintenance, noncompliance with applicable specifications, airworthiness directives, or other approved data, the following or a similarly worded statement—“I certify that this aircraft has been inspected in accordance with (insert type) inspection and a list of discrepancies and unairworthy items dated (date) has been provided for the aircraft owner or operator.”

(b) Listing of discrepancies and placards. If the person performing any inspection required by part 91 or 125 or §135.411(a)(1) of this chapter finds that the aircraft is unairworthy or does not meet the applicable type certificate data, airworthiness directives, or other approved data upon which its airworthiness depends, that persons must give the owner or lessee a signed and dated list of those discrepancies. ...

I hope this is helpful.

As for the installation of the BAS harnesses: If it is desired that the installation be performed according to the STC, then BAS will have to be contacted and they will have to provide the installer with paperwork approving the installation. BAS will likely be very helpful in this transfer of their harnesses.
If it is desired to utilize the BAS harnesses for an installation under the FAA policy letter, then all aspects of that letter must be followed, and BAS will not be involved, and no further approvals will be necessary other than the logbook sign-off of an A&P.

Again, I hope this helps.

[minton]

Thanks George,
I appologize to you personally. Your statement as to BAS contact is not per my FSDO, VBL has every right to sell his harness reels including his paperwork. Unfortunately you as an advertised moderator have constraints placed on you the we don't. Keep that in mind.
minton

[c170b53]

You could have an u/s item that's not required for the airworthiness of the aircraft (conditional) but a u/s item that does affect airworthiness would be a show stopper.
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).
As far as this chuck and duck goes, I'm under the table now.

[minton]

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

[Metal Master]

... In such a case of the inspection dredging up something questionable the inspection is deemed incomplete (unairworthy) and is so noted in the logbook. The aircraft can be released to the owner in that condition and in some cases a ferry permit obtained but don't come away thinking it's in annual. ....

The inspector MAY NOT declare the aircraft as "unairworthy".
The owner/operator may satisfy the discrepancies in any legal fashion, somewhere else if he wishes, and then the owner "returns to service" the aircraft afterwards.

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.
_I am to make an entry in to the log books of the type of inspection I am performing. When I find an aircraft does not meet the requirements of the type certificate and find discrepancies that the owner will not or can ot fix for what ever reason. it does not say to list those in the log books. It requires me (If the person performing any inspection required by part 91 or 125 or §135.411(a)(1) of this chapter finds that the aircraft is unairworthy or does not meet the applicable type certificate data, airworthiness directives, or other approved data upon which its airworthiness depends, that persons must give the owner or lessee a signed and dated list of those discrepancies).
If I do not list the discrepancies in the log books as a part of the permanent record, who is to say that the owner, lessee could not just burn the separate signed and dated list and say it never existed. If he then chooses to fly the aircraft after saying that I had performed an annual inspection (my log book entry might say I have performed a annual inspection and having found discrepancies and not declared it airworthy or unairworthy stated that I have given a signed itemized list of those discrepancies to the owner) he would be flying an unairworthy aircraft.
If on the other hand I sign of the aircraft as unairworthy with a list of those discrepancies in the logs short of tearing the page out the owner can not do anything but have those discrepancies repaired, and or a determination by another entity that I was wrong in my determination thus taking responsibility for his determination.

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.

I am not going to tell you how it should be done because the FAR does not tell us how it is to be done. But I will fill in the blanks for my self.

FAR follows


43.11 Content, form, and disposition of records for inspections conducted under parts 91 and 125 and §§135.411(a)(1) and 135.419 of this chapter.
(a) Maintenance record entries. The person approving or disapproving for return to service an aircraft, airframe, aircraft engine, propeller, appliance, or component part after any inspection performed in accordance with part 91, 125, §135.411(a)(1), or §135.419 shall make an entry in the maintenance record of that equipment containing the following information:

(1) The type of inspection and a brief description of the extent of the inspection.

(2) The date of the inspection and aircraft total time in service.

(3) The signature, the certificate number, and kind of certificate held by the person approving or disapproving for return to service the aircraft, airframe, aircraft engine, propeller, appliance, component part, or portions thereof.

(4) Except for progressive inspections, if the aircraft is found to be airworthy and approved for return to service, the following or a similarly worded statement—“I certify that this aircraft has been inspected in accordance with (insert type) inspection and was determined to be in airworthy condition.”

(5) Except for progressive inspections, if the aircraft is not approved for return to service because of needed maintenance, noncompliance with applicable specifications, airworthiness directives, or other approved data, the following or a similarly worded statement—“I certify that this aircraft has been inspected in accordance with (insert type) inspection and a list of discrepancies and unairworthy items dated (date) has been provided for the aircraft owner or operator.”

(6) For progressive inspections, the following or a similarly worded statement—“I certify that in accordance with a progressive inspection program, a routine inspection of (identify whether aircraft or components) and a detailed inspection of (identify components) were performed and the (aircraft or components) are (approved or disapproved) for return to service.” If disapproved, the entry will further state “and a list of discrepancies and unairworthy items dated (date) has been provided to the aircraft owner or operator.”

(7) If an inspection is conducted under an inspection program provided for in part 91, 125, or §135.411(a)(1), the entry must identify the inspection program, that part of the inspection program accomplished, and contain a statement that the inspection was performed in accordance with the inspections and procedures for that particular program.

(b) Listing of discrepancies and placards. If the person performing any inspection required by part 91 or 125 or §135.411(a)(1) of this chapter finds that the aircraft is unairworthy or does not meet the applicable type certificate data, airworthiness directives, or other approved data upon which its airworthiness depends, that persons must give the owner or lessee a signed and dated list of those discrepancies. For those items permitted to be inoperative under §91.213(d)(2) of this chapter, that person shall place a placard, that meets the aircraft's airworthiness certification regulations, on each inoperative instrument and the cockpit control of each item of inoperative equipment, marking it “Inoperative,” and shall add the items to the signed and dated list of discrepancies given to the owner or lessee.