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At 05:16 PM 10/31/2005, Ed Burkhead wrote:
In the second example, the auto fuel pump utilized by Continental is clearly
a "standard part" deemed suitable by Continental and ERCO for the intended
purpose as selected from the (then existing) auto industry.
What can I say. I deal with the FAA on these issues on a daily
basis. They do not agree with your interpretation. I have checked,
specifically on fuel pump parts.
An AN10 bolt is produced to a published specification by a number of
manufacturers. Any of those bolts are suitable for use in an
Ercoupe. When I buy them, I get a document certifying that the
product meets the spec, and listing traceability information so that
if a bolt from this manufacturing lot is found to be sub-standard,
all it's sibling bolts can be located and removed from service. These
are affectionately known as "certs". The Chin Wah Auto Parts company
does not produce fuel pump diaphragms to any published and accepted
specification nor do they provide any traceability information. Try
and get a production drawing and materials list form them! Try even
to get a production date or lot number. These parts are not
acceptable for use in an Ercoupe because they do not meet the
requirements you have mentioned.
They also do not meet the requirements for owner produced parts as
the owner has not participated in the design, manufacture or quality
assurance for the part. You cannot even tell me what material the
diaphragm is made from.
I know this will not convince you, so I suggest you bring this up
with your FSDO and ask them for a ruling.
If you put a fuel pump diaphragm in from the Chin Wah Auto Parts
Company, and do not tell the inspector doing your annual, you are
putting his certificate in jeopardy. When he signs that aircraft
off, he is saying that he has verified that it meets the
airworthiness requirements. If that part is acceptable, he won't
mind signing off on it. If, on the other hand, the crankcase fills
up with gas because the material was not compatible with avgas, and
there is an incident or accident, who's neck do you think will be the
first one in the noose?
That's my story and I'm sticking to it.
John Cooper
Skyport Services
PO Box 249
4996 Delaware Tnpk
Rensselaerville, NY 12147
518 797-3064
Fax 518 797-3865
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