They have most of it in stock and have had it there for 10 years. But the UK end of CAV has slipped (yet again) on a few bits like the pump and reservoir assembly.
Let’s say I get a part shipment. Would it be legal to install say the fluid refill point, which is a door like the oil dipstick door? There is a fair bit of labour involved in doing that and doing it neatly and making good the paint around it.
I have the Annual coming up, and fitting a new (exchange) engine, so will be grounded for 2-3 weeks.
Installing the fluid refill point will obviously have no impact on performance or w&b or anything, but you can’t just cut a hole in the side of a plane, can you, as a Minor Alteration IAW with the AC-something generic maintenance/repair manual?
I think the answer is NO for the STC route because an IA has to inspect the installation for STC compliance and sign the 337 and send that to Oklahoma. It is all or nothing… no way to be half pregnant.
But it may be possible to do some “trivial” work as a Minor alteration.
Just being cheeky – if the pump failed, you would still be able to fly with the pump inop, and defer the defect
Would you be allowed to fly with the inop pump removed for repairs? FAR 91.213 allows it to be … “(i) Removed from the aircraft, the cockpit control placarded, and the maintenance recorded in accordance with Sec. 43.9 of this chapter”
How does this change if the pump was never installed in the first place?
Peter wrote:
I think the answer is NO for the STC route because an IA has to inspect the installation for STC compliance and sign the 337 and send that to Oklahoma. It is all or nothing… no way to be half pregnant.
Your intuition is correct.
OK… that implies that any aircraft is grounded from the commencement of any STC-covered work until the IA signs off the 337 at the end.
There must be some practical way out of this, in the FAA system, short of a total restoration to the previous condition, if something has gone wrong with an installation. But if you drilled even a single hole, you have to make that good, which is not possible short of re-skinning that part of the aircraft. So at least one would have to make a patch for the hole, as a Minor alteration, no?
Peter wrote:
OK… that implies that any aircraft is grounded from the commencement of any STC-covered work until the IA signs off the 337 at the end.
100% correct.
As a matter of fact, I once had a client that was surprised that I made an "un-airworthy " statement in the log-book when they picked up the acft to bring it to another shop for some more work whilst the STC I was installing was not entirely complete.
No big deal, any A&P can sign off as airworthy once the STC is complete.
Peter wrote:
So at least one would have to make a patch for the hole, as a Minor alteration, no?
That sounds reasonable. This situation is no different than any OTHER maintenance or modification project inasmuch that " it ain’t over ’till the fat lady sings ! "
So, do you reckon the TKS refill door could be done as a Minor Alteration?
Peter wrote:
So, do you reckon the TKS refill door could be done as a Minor Alteration?
As usual, it wil depend on which A&P (you don’t NEED an IA for this) you ask to sign off the mod.
Where is that door located ?
OK, saw the pictures. That may not be considered a Minor … I would take it up with your A&P.
Which aspect of it could make it a Major? The structural aspect of the airframe skin? There is a doubler plate, in effect.
