BAS inertia reel system

[cmsusllc]

Blueldr is sending me his BAS inertia reel system to install in my 53 B. I'm looking for instalation instructions, a copy of the STC and 337 and a single part number 2 ( maybe I can make it ). I see there is something in the library for inerita reels, is this part of what I'm looking for?
Thanks for any help.
Scott -- 53 B

[futr_alaskaflyer]

The only valid STC copy for your installation will come in an envelope from B.A.S, Inc.

However, in light of FAA guidance on shoulder harness installations that might not be an issue. I'm willing to share the installation drawings etc., if I can find them in the basement.

[GAHorn]

futr has got it right....no STC is actually necessary for a shoulder harness system....PROVIDED that no major structural alterations are required for the installation. The BAS system probably does not meet that criteria. On the other hand, BAS is a good company and will likely provide their paperwork, either free,... or for a nominal fee,... provided they know the original source of the harness being installed.
I suggest you contact them after determining the original purchaser and the aircraft serial for which the harness was originally intended.

[cmsusllc]

I don't know what is going on with BAS, I've e-mailed them twice for information on purchase of a new system, gone on to their website to find most pages can't be found by the server and what info you do find is at least five years ago. Maybe I should stop by their place one of these days and see what's happening ( only about 45 minutes by air ). Also I didn't think the STC was sr. # specific.
Scott --- 53 B

[Bruce Fenstermacher]

Scott, today most STC's are serial specific. A requirement I believe of the FAA.

[minton]

I have been told by FAA FSDO types that "IF" you remove a STC'd part from one plane and install on another as long as you obtain a bill of sale from the owner specifically mentioning transfer from one "N" number - serial number to another of like vintage you don't have to go to the STC owner for any further paperwork. The logic being that you as the seller (Owner)are not manufacturing parts or kits. There is no fraud intended. As long as the original STC that was purchased is handed over and you have access to (Current) installation instructions you are good to go. Word of warning, keep that bill of sale klipped to the STC paperwork and pass it along to any future aircraft owners. I also have talked to BAS, they only mark their reel serial numbers by magic marker (Go figure) and second, If you have had the need for that restraint to spring into action you must remove the unit and have it recertified! BAS sez it has internal parts that are for "one time" use. That is not mentioned anywhere I have found in their paperwork. So, if you have any doubts as to it's history insist that it be certified before you hand over the cash!

[blueldr]

What's all this about having the BAS inertia reel recertified after an activation? That's ridiculous. I sold that system to Scott and when it was in my airplane I tested the inertia acitvation, each time I hooked up the harness, by giving it a quick, short, pull to see that it was locking up. I do the same thing in my cars, and it is, after all, basically an automotive part.
Perhaps, in the event of a crash, body weight against the internal mechanism might be severe enough to require some sort if an inspection, though there was nothing in the original installation instructions about this that I recall.

[futr_alaskaflyer]

I have been told by FAA FSDO types that "IF" you remove a STC'd part from one plane and install on another as long as you obtain a bill of sale from the owner specifically mentioning transfer from one "N" number - serial number to another of like vintage you don't have to go to the STC owner for any further paperwork. The logic being that you as the seller (Owner)are not manufacturing parts or kits. There is no fraud intended. As long as the original STC that was purchased is handed over and you have access to (Current) installation instructions you are good to go.

Interesting. Though that might make logical sense and many of us feel that is the way it ought to be, this is 180 degrees from general understanding of policy around these parts. Not sure how the new 337 for the authorization on your plane is going to explain how the supplemental type certificate authorizing the installation/modification has information from a different plane on it At minimum you should have written authorization from the STC holder?

[GAHorn]

A similar situation occurred in my neck of the woods. A 172 owner bought Cleveland brakes (his airplane previously had McCauley) from a salvage yard and installed them, claiming he'd purchased the STC rights as well. He had the paperwork from the donor airplane. His IA refused to go along with it at the next annual and HOU-FSDO got involved.
FSDO required the owner to either recertify (Form 8110) the parts and install them under a "field approval", or obtain new paper from Cleveland authorizing the change. Cleveland refused unless the parts were returned for overhaul/recertification. Both FSDO and Cleveland maintained that a salvage airplane had unknown, potential damage which could affect the airworthiness of the parts.
He ended up buying a new STC with new parts because of the scrutiny his airplane had then come under.
Salvaged parts now require documentation for traceability and yards will happily provide that. But they will not likely attest to airworthiness of the parts-removed. If it's a simple airframe part, or a "standard part", then an A&P inspection may be all that is required. But be aware that is not always the case, especially when purchasing entire sytems, such as brakes, or propellers, etc..
AVIONICS are especially worrisome. Few A&P's have the experience/equipment to determine avionics airworthiness. (And this is a particularly foggy matter when it comes to purchasing radios from fleabay, etc.. )

Regarding the BAS shoulder harness, .... a shoulder harness was never required equipment in a 170, therefore no recertification is required for a Part 91 airplane. You could install hemp-ropes as long as you don't alter the airframe significantly.
I suspect BAS is addressing a situation such as when the harness inertia reels are subjected to the stresses of impact subsequent to an accident. Their lawyers probably want the harnesses re-certified prior to further use in aircraft which require harnesses by regulation.

[minton]

George,

You hit the nail on the head! BAS requires recertification after a incident/accident. They don't manufacture the unit so it requires recert. by the MFG. All I wanted the club members to think about is, WHERE did the unit come from?? Could past history be documented? If someone has some heart burn with that take it up with BAS and the FAA. Also the info on STC transfer was passed on to me by ANC/FSDO. I suggest that if someone wants to transfer an STC contact their FSDO for guidance first, and do it their way. Each FSDO has their own way of attacking the problem just like the IRS, and each will change their minds just as often as I change my socks.

P.S. Reguardless of weather a harness is required by certification requirements or not, once the harness is installed it falls under the airworthiness inspection process. (IE) I as an A&P/AI can't just inspect /certify airworthy/return to service a partial aircraft. The whole enchalada or remove the harness.

As to BL's hearthburn, thats between him and the guy who bought the harness's. As for me I'd buy new for one main reason, BAS has not been required through the STC process to afix a permanent serial number to their units. A little history, I bought a damaged 170B some years back from an insurance auction. The BAS system had been removed and the paperwork trail was left behind. I contacted FAA and BAS to report the theft. Well you can see what could occur. With the serial numbers in magic marker which I am sure were changed or outright removed there are two harness's out there that were installed in someones aircraft that was involved in an accident. Now, would you buy a used set?? Not me!!

[GAHorn]

...
P.S. Reguardless of weather a harness is required by certification requirements or not, once the harness is installed it falls under the airworthiness inspection process. (IE) I as an A&P/AI can't just inspect /certify airworthy/return to service a partial aircraft. The whole enchalada or remove the harness....

Let me say this right off: I'm not suggesting that as the inspector you have to do anything you don't want to.

But I believe this opinion you stated (above) is incorrect. If the harness is not required, then it can be installed and not require recertification. (Even if it were installed according to an STC...and you were performing an annual inspection....How would you know if it had been stressed sufficiently to require recertification???? Answer: You probably wouldn't and in fact, you may have been approving aircraft for return-to-service for years without their BAS harnesses complying with BAS requirements.)

It's not much different than the seat-covers being torn or the carpet with a hole in it. (However, as the inspector, you MAY record that you've inspected the aircraft and a list of discrepancies provided the owner, who may then take upon himself the responsibility of returning the aircraft to service. If I were the owner, I'd staple that list into the logbooks and sign it off as being "nonessential equipment".)

[minton]

First we are talking about two separtate issues

The first being installation and inspection processes. So follow along.
I've been at this for 40+ years and NEVER overlooked, ignored or turned my head while an aircraft rolled out the door less than completely LEGAL and (AIRWORTHY). I would invite you nay sayers to sit through an AI recertification class put on by the FAA. I think that those who would make the effort would will come away with a new appriciation and better understanding of the airworthiness process. There is no way that (If installed) any part of that aircraft can be overlooked during the annual or 100 hour inspection. Let me make it crystal clear. If its bolted, glued, riveted or in any other way secured to the airframe or engine it's a part of the darn plane! Not required does'nt get it! 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. I have heard of some folks that then go shopping for a more sympathetic A&P. If thats the case as an aircraft owner/passenger they had better start questioning their judgement. This is'nt the EAA. Boat owners have the same attitude. Where do you plan on pulling over when things go south?? Shoulder harnesses as addressed in FAA AC 21-34 have airworthiness requirements that address mounting, positioning, materials, construction, testing and so on. So if you want to install your ROPE go for it, and then please send me pictures of the install and your annual/100 hour sign off. They will make great wall art.

I'm starting to question why I even sign airplane off!!

Second, If we are talking about certification of harnesses lets first begin by saying that a harness system that has been laying arround the hangar and is sold for installation is in my mind a questionable unit. How do I know as a buyer the history of the unit? Unless it has a yellow tag or 8130 it's questionable. If you as an owner/operator or mechanic of said aircraft have an accident and come up hard against the hardness it requires recertification. We are talking about the inertia type. Don't think that part 91, 135 or 121 change the requirements because it does'nt. Get the tag!! Signing off the airplane annual/100 hour requires a records reveiw. That means log's, ad's,337's and oh yes maybe even lookin the airplane over. A trained eye can detect repairs. If I see indications of major damage I might require recertification of inertia harness reels.

Why are we even having is arguement? I say lets use common sense. I've detected some questionable statements that could leed me to think individuals might be thinking with their wallets.

[futr_alaskaflyer]

First we are talking about two separtate issues

The first being installation and inspection processes. So follow along.
I've been at this for 40+ years and NEVER overlooked, ignored or turned my head while an aircraft rolled out the door less than completely LEGAL and (AIRWORTHY). I would invite you nay sayers to sit through an AI recertification class put on by the FAA. I think that those who would make the effort would will come away with a new appriciation and better understanding of the airworthiness process. There is no way that (If installed) any part of that aircraft can be overlooked during the annual or 100 hour inspection. Let me make it crystal clear. If its bolted, glued, riveted or in any other way secured to the airframe or engine it's a part of the darn plane! Not required does'nt get it! 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. I have heard of some folks that then go shopping for a more sympathetic A&P. If thats the case as an aircraft owner/passenger they had better start questioning their judgement. This is'nt the EAA. Boat owners have the same attitude. Where do you plan on pulling over when things go south?? Shoulder harnesses as addressed in FAA AC 21-34 have airworthiness requirements that address mounting, positioning, materials, construction, testing and so on. So if you want to install your ROPE go for it, and then please send me pictures of the install and your annual/100 hour sign off. They will make great wall art.

Second, If we are talking about certification of harnesses lets first begin by saying that a harness system that has been laying arround the hangar and is sold for installation is in my mind a questionable unit. How do I know as a buyer the history of the unit? Unless it has a yellow tag or 8130 it's questionable. If you as an owner/operator or mechanic of said aircraft have an accident and come up hard against the hardness it requires recertification. We are talking about the inertia type. Don't think that part 91, 135 or 121 change the requirements because it does'nt. Get the tag!!

Maybe you know this already - it's hard to tell from your posts - but the policies contained in AC21-34 were modified by subsequent policy statement ACE–00–23.561–01 which you can read here.

[GAHorn]

Here are the pertinent sentences of the FAA letter:
"Installation of shoulder harnesses may be accomplished without FAA approval if the installation is a minor change to the
airplane design"

"For aircraft type certificated before the effective date of Amendment 23–20, the shoulder harnesses need not meet the
requirements of 14 CFR 23.561, and its predecessor regulations, if the installation of the harness is not essential to the operation of the airplane. A shoulder harness installed as a minor change does not have to provide the level of safety required in 14 CFR 23.561. The head impact injury criteria and strength requirements of the harnesses, including fitting factors, do not have to be met for minor change installations."

"However, the FAA should not forbid the approval of a retrofit shoulder harness installation as a minor change in:· The front seats of those small airplanes manufactured before July 19, 1978, and · In other seats of those small airplanes manufactured before December 13, 1986. A retrofit shoulder harness installation may receive approval as a minor change in these small airplanes if:
· The installation requires no change
of the structure (such as welding or
drilling holes).
· The certification basis of the
airplane is 14 CFR part 23 before
Amendment 23–20, part 3 of the Civil
Air Regulations, or a predecessor
regulation."

Bottom line is as I previously stated... Since our Cessna 170's were certified prior to the requirement for shoulder harnesses, any harness installed may be done by minor alteration, and does not need to meet the same requirements of the BAS harnesses. (In fact, you can install automotive harnesses if you like. Therefore BAS harnesses installed under minor mods do not have to meet BAS recertification requirements since they are not installed under that mfr's installation instructions. This may be a moot point however if the installation is made per major alteration methods.)

[GAHorn]

... 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. ....

I don't wish to appear disagreeable or critical...I only hope to provide some useful information....

I don't believe this opinion is valid, Minton. I believe the correct procedure is for the inspector to complete the inspection and for those items he does not consider "airworthy" ...he must make a separate list of them and provide that list to the owner/operator. The inspector signs off the inspection as having been "completed and a list of discrepancies provided the owner/operator."
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