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-----Original Message----- From: William R. Bayne [mailto:[EMAIL PROTECTED] Sent: Tuesday, November 01, 2005 3:57 PM To: Ed Burkhead Subject: Re: WRB Re: [COUPERS-TECH] Verify inlet/outlet on Fuel Pump RLYTECH Hi John, On Nov 1, 2005, at 10:03 AM, John Cooper wrote: > > At 05:16 PM 10/31/2005, WRB via Ed Burkhead's computer 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. > With Skyport, and as a mechanic you HAVE to "get along" with your FAA Regional Office. You HAVE to "toe the line". At the same time this very fact brings with it a certain bias to your necessary perspective. What's the name of that syndrome where those kidnapped become sympathetic to their kidnappers and their agenda? A city in Sweden, I think. > 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". OK, you're taking FAA/CAA "aircraft" terms and attempting to infer that somehow in the mid-sixties these became applicable in hindsight to aircraft certified with certain automotive parts under earlier, much more liberal regulations. That argument has yet to be impartially validated on a logical basis. That said, I know the difference; and WANT an AN bolt holding my wing on! > 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. I disagree. AC auto fuel pumps met the design criteria they originated. Parts were not manufactured to be traceable because this was neither common nor necessary practice for automobiles in the late thirties and early forties. I highly doubt you could get a production drawing and materials list from AC or its successors while in production. Proprietary secret, old man. Accordingly, acceptability of such pumps and such parts remains unchanged today because it is "grandfathered" and no specific FAA regulation was ever announced or adopted with the acknowledged purpose of changing that fact. > > 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. > The owner produced them, as in "here's some auto pump parts for the auto pump. ERCO didn't know or care what the AC pump diaphragm was made of. It worked, and that's what mattered back then. For Ercoupe installation, I supply the pump and the mechanic puts it on and signs off on the installation ONLY. > I know this will not convince you, so I suggest you bring this up with > your FSDO and ask them for a ruling. > As a purportedly free American, to purchase less expensive identical drugs from Canada I don't have to write a letter requesting permission to an FDA I already know will turn me down. I just do it. Similarly, when the IRS would deny a legitimate medical deduction for these drugs because they are deemed "illegal", such is not meekly accepted. Why? because we don't recognize the abuse of regulatory authority WE grant these government representatives WE pay to perform services that purportedly benefit WE, the people. We have the right to make reasonable interpretations of our own which may differ. We understand that Uncle Sam is our uncle, not our dad. Remember there was once a copperhead snake on our flag and the slogan "Don't tread on me!" > 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. So give me one example of a mechanic who lost his certificate from auto parts failure in AC auto fuel pumps over the years. Many of these pumps/parts soldier on even today, ignorant of FAA hopes and dreams of empire? > When he signs that aircraft off, he is saying that he has verified > that it meets the airworthiness requirements. While this is how the FAA accepts the signoff, there are more than a few legal cases that limit a mechanic's liability to only those things added, removed, disassembled, or otherwise specifically necessary to check and verify as operationally functional within acceptable variation. Checking engine connecting rods or fuel pump parts for PMA traceability isn't on any "annual" list. > If that part is acceptable, he won't mind signing off on it. That's acceptable to HIM and to HIS satisfaction, not necessarily the FAA's. He's paid to work-they're paid to...well, you know. A successful mechanic needs satisfied customers. Not many work for the FAA, so that's NOT where their bread is buttered. > 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? These days, there's an equal chance the aviation part may not be compatible with mogas. In either case, the owner/pilot, without doubt, will be first held responsible. It's the easiest violation...all planes that fall from the sky were unairworthy at takeoff. Gotcha! It's been fun, WRB > > That's my story and I'm sticking to it. > > John Cooper > Skyport Services ============================================================================== To leave this forum go to: http://ercoupers.com/lists.htm Search the archives on http://escribe.com/aviation/coupers-tech/
