I understand that rules and regs are there for a reason Peter but in the case of the light cover in your original post, if you can make a replacement from better materials that is in better condition to the one you have then why not do it…??
The questions you must ask youself are…
1. Is my replacement part similar or better quality than the original?
2. If it failed, what would be the consequence?
You’ve already covered point 1 in your first post by saying you’d be using a better material. Point 2, IMHO, is that the cover would crack and potentially leave the aircraft. This could result in a slight reduction in aerodynamics at the light housing area. Would this be catastrophic?? Highley unlikely….Could the current cover, or indeed a ‘factory’ made replacement part do the same in its current condition?? Yes, probably.
On the basis of these arguments and the fact that it would be nigh-on impossible for anyone to actually tell the difference, I’d definitely consider replacing it myself.
Those are my sentiments too, obviously 
I was asking about legality. Someone who runs a forum will have a bunch of people ready to report them 
The component can’t come out because there is a curved piece of plexiglass in front of it. So the worst on point 2 is that it might obstruct the light(s).
The factory original is junk. It is cracked at all three mounting points, on almost every TB specimen you look at, but people don’t fix them. In fact I tried to buy one a few years ago but wasn’t able to unambiguously establish the P/N from the IPC, and neither Socata nor their disti in France was able to help.
Peter, with all due respect, are you yanking our chain? I mean, you know all you need to do is sign it off as an owner produced part; you also know that if you have any doubt, just need to ask your IA, and since you have a very sensible and reasonable guy, there is no way he’ll say “no”.
So what is the question, again? Selling them?
You’ve seen what Guy Gibney, from the Beech (now TBM) crowd, produces, right? You do know how stuff from McMaster-Carr works. Same with Plane Plastics. Or all the exhausts rebuilt in inconel from a rusted piece of a muffler. Or battery boxes eaten away by spilled acid from a battery that got boiled by a broken 1940’s voltage regulator. Heck, probably Saywell effectively end up working the same way when one orders a teflon hose from them to replace what is left of a 40 year old original one. All the SCAT tubing being replaced with SCEET. The list is close to endless.
As Adam pointed out, nowhere do the regs say that the owner has to actually produce the OPP from raw materials, so yes, you can send Guy, or Igor from Kharkov, a request to make you one.
Isn’t this one of the reasons you’re N-reg? :)
ps. yes, the part not being available does matter, as it is another reason to allow an OPP to be installed, a very solid one
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.
Right; in that case, sure – OPP for N-reg, and for those on EASA regs, there is this whole thread and this summary post
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).
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.
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.
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:
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.
