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FAA Owner Manufactured Parts = ability to repair equipment?

I have heard of an interesting and potentially extremely useful interpretation of the owner mfg parts concession

Under CFR Article 21, Subpart A, paragraph 21.9 (5) articles may be
produced by an owner or operator for maintaining or altering his own
product. All articles which are NOT produced by the Production Certificate
or Type Certificate holder, or under FAA-PMA approval, or under TSO, a
commercial part (21.1) or are Standard part (AN, MS, NAS, etc.) must
qualify as “owner or operator produced” to be legally installed on a
type-certificated aircraft.
In order to qualify as an “owner or operator produced” article, the owner
or operator of the aircraft much have participated in controlling the
design, manufacture, or quality of the article.
That article must meet at least one of the following criteria:
1. The aircraft owner or operator provided the manufacturer of the article
with design or performance data from which to manufacture the article.
(This may occur, for instance, when a person provides an article to the
manufacturer and asks that article be duplicated.)
2. The aircraft owner or operator provided the manufacturer of the article
with materials from which to manufacturer the article.
3. The aircraft owner or operator provided the manufacturer of the article
with fabrication processes or assembly methods to be used in the
manufacture of the article.
4. The aircraft owner or operator provided the manufacturer of the article
with quality control procedures to be used in the manufacture of the
article.
5. The aircraft owner or operator supervised or participated in the
manufacture of the article. You are not considered a producer of the
article by merely ordering the article. You would not be participating in
control of the design, manufacture, or quality of the article, and
therefore the article would not be legal for installation.

It seems obvious that the aircraft owner can repair e.g. an avionics item provided that the end result is exactly the same as it was previously.

It seems obvious that replacing CMOS memory batteries doesn’t need an avionics shop, for example.

A more practical than legal issue is that you may need MMs (maintenance manuals) and/or test equipment may be needed. And MMs are very hard to find. Garmin MMs are especially hard to find and some are useless; e.g. the GNS430 one is almost totally useless. I have a huge collection of manuals which I have been collecting since I got my plane in 2002, when Air Touring failed to give me the ones I asked for (and they agreed to give me) so I realised that having them is very valuable.

Administrator
Shoreham EGKA, United Kingdom

Peter,
there is a EAA webinar by Mike Bush on this topic that may explain a lot . But I do not remember he dealt with avionics repairs. You would have to draw your own conclusions.

Vic

EAA webinar

vic
EDME

This is how most rare types or warbirds are maintained.

Here is another great article on this and related stuff.

Administrator
Shoreham EGKA, United Kingdom

The downside of this route is that liability remains with you for the life of the part. So if you sell your aircraft and 20 years later it crashes due to failure of the part you will be taken to the cleaners.

Does that apply to cars and houses too?

I think not, and it is highly dependent on where and the context.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:


produced by an owner or operator for maintaining or altering his own
product. All articles which are NOT produced by the Production Certificate
or Type Certificate holder, or under FAA-PMA approval, or under TSO, a
commercial part (21.1) or are Standard part (AN, MS, NAS, etc.) must
qualify as “owner or operator produced” to be legally installed on a
type-certificated aircraft.

In order to qualify as an “owner or operator produced” article, the owner
or operator of the aircraft much have participated in controlling the
design, manufacture, or quality of the article.

That article must meet at least one of the following criteria:

Hi Peter, can you please advise the source for the extract that you posted? Thanks

YPJT, United Arab Emirates

Most likely it came from US AOPA – magazine or website.

I did the usual thing just now when locating sources (a google on a selected sequence of words, between quotes) but it finds only EuroGA

I also have some articles on owner-produced stuff on my website.

Administrator
Shoreham EGKA, United Kingdom

Ok…it’s just that the list of methods available to qualify owner produced parts is a lot more extensive than I had thought…so if the list represents some sort of FAA recognized acceptable means of compliance it would be nice to be able to quote the original source….(in the airplane logs)

Last Edited by AnthonyQ at 26 Jun 08:34
YPJT, United Arab Emirates

AnthonyQ wrote:

…so if the list represents some sort of FAA recognized acceptable means of compliance it would be nice to be able to quote the original source…

Alas, the FARs are chock-a-block full of grey areas …

FAA A&P/IA
LFPN
23 Posts
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