I don’t think carpets and other non-structural cosmetic interior trim are any different in the eyes of FAA.
These cosmetic items would be installed on a logbook entry (minor mod) and who produced them is irrelevant. The Owner Produced route is different and applicable to non-cosmetic parts (any) manufactured by either the aircraft owner or at his direction, supervised by him. Those have to be manufactured to design data, which is why e.g. the availability of original drawings is useful.
tmo wrote:
Well, no, I would say that CS-STAN-103a allows you to make your own,
Which part of the text you quote in your view requires that you produce the part by yourself?
Carpets must be relatively easy otherwise re-upholstery of cockpits would be impossible. Nobody is going to buy whole new seats etc from the aircraft manufacturer. And the flammability due diligence is discharged by obtaining a specific certificate for the material. The actual work can be junk.
This thing is different.
tmo wrote:
Well, no, I would say that CS-STAN-103a allows you to make your own, they even reference FAA Advisory Circular AC 23-2A Change 1 as a source for approved data and go on to say:
My club replaced part of the interior on a PA28. The new interior was made by a local car interior company. Our CAMO had no objections whatsoever.
Well, no, I would say that CS-STAN-103a allows you to make your own, they even reference FAA Advisory Circular AC 23-2A Change 1 as a source for approved data and go on to say:
Interior material (e.g. carpets) can be replaced by new materials (e.g. carpets) under the following conditions:
- the shape is taken from the original OEM material installed in the aircraft;
- the same attachment method is used as for the OEM installation;
- impact on weight and balance needs to be considered; and
- ‘flame resistant’ capability of the material installed on aircraft other than gliders, motor-powered gliders, LSA, and balloons must be demonstrated. ‘Flame resistant’ capability can be demonstrated by:
— compliance with ‘flame resistance’ requirements proven by means of FAA AC 23-2A Change 1 §8 b, or equivalent, and documented by appropriate test reports released by the material suppliers, or
— compliance with any other more stringent flammability tests (e.g. vertical tests of FAR/CS-25 Appendix F), or
— successful execution of the following ‘Flame Resistant’ tests referenced or recorded in EASA Form 123:
IF you can buy them. Mostly you can’t – too specialised, unless it is a type with a fleet size approaching 10k. Socata are under 2k.
EASA has a much better thing: As long as we are talking about cosmetic interior trims, the owner does not even have to manufacture the parts himself, but can actually legally buy them and install under CS-TAN103a.
Right.
FWIW, I don’t think EASA has an actual OPP concession, no matter how one reads the regs – unless you can demonstrate that you obtained the original design data, which will never happen in any real scenario (and which is why OPP is no use even on an N-reg for things like the landing gear; well not without expert input).
Right; in that case, sure – OPP for N-reg, and for those on EASA regs, there is this whole thread and this summary post
I started the discussion for education purposes. If I didn’t want that, I would just do it quietly and not tell anybody – knowing it would be legal under OPP (owner produced parts). Search here for “owner-produced”.
But once one goes public with something, one needs to be more careful because there are usually people out there who are out to cause hassle. I’ve had legal threats within an hour of something being posted here, so plenty of people have that as their #1 motive 
The Minor mod area can be a grey area, if somebody wants to give you hassle – because you don’t have gold plated paperwork from an agency.
