AVIATION SAFETY NEWSLETTER
Thought for the month....
Problems occur when two people try to be clever at the same time.
"DATA PLATE WITH GOOD LOGS FOR SALE: (Send money order)"....I was recently "surfing the web" viewing various aviation sites, and saw the preceding advertisement. As you would expect from anybody in my business this really caught my eye. I thought to myself that this is certainly one way to keep our aging fleet in service. Taking off my FAA hat for a moment, I can see how this could be a good way to employ a little "yankee ingenuity" and keep those old birds operational. Especially for those airplanes that become estate sales, i.e., found in an old barn stored for the last 25 years or something similar to that.
We have all heard that if we can save the data plate and build an airplane around it, what we have effectively done is a "repair" to that airplane. Like the individual who placed the advertisement above, many people don't realize that there is any problem here. I'm sorry to say that this isn't the case. We need to have some of the original component to build upon in order to use the term "repair" concerning the work performed.
By attaching a purchased data plate to a product (airframe, engine, or propeller) what we have just done was to buy into a fraudulent act that was started by the person who removed and offered the plate for sale. Federal Aviation Regulation (FAR) 45.13(e) states: "No person may install an identification plate… on any aircraft, aircraft engine, propeller, propeller blade, or propeller hub other than the one from which it was removed". The rule does allow for removal when necessary for maintenance operations or under approval by the (FAA) Administrator, but to my knowledge the FAA has yet to approve the installation of a data plate on something other that what it was originally installed on.
It's quite possible we could find out that the airplane we have been flying for the last 20 years, all of a sudden doesn't have a data plate on the engine, propeller, or other product required by FAR 45.11. This revelation may have come about when our mechanic opened the airplane up for an annual inspection. Both of us knew that it was there last year or at least we both thoughts it was. Now our mechanic is reluctant to sign the annual off because he has just returned from a maintenance seminar where this issue was discussed -ad nauseum- and he is now a believer that if he signs-off the annual as airworthy, the FAA will find out and revoke his certificate. What are we going to do to resolve our problem? We have half our life's investment and ¾th's of our marriage invested in this aircraft, and we're not going to shell out $10,000 for another engine just to satisfy the feds. Fortunately, there is a cheaper way out of this dilemma.
We can obtain replacement data plates, but it will take a bit more than a request from our mechanic to the engine manufacturer to get one. If a replacement data plate is needed, begin with a telephone call to the local FAA Flight Standards District Office. Speak with an airworthiness inspector and find out what the person who is going to handle your situation will need.
What I have required in the past to assist the owner obtaining a replacement data plate, are documents to ascertain that the product being presented is in fact the "real McCoy". The first document I will need is a letter from the owner stating his or her need for the replacement data plate. If the product is an engine, there may be casting numbers in the case that will be helpful. With these numbers we can call the engine manufacturer, and request from the customer service department a search of their records to determine what engine those casting numbers were installed on. I would also have the owner produce the engine and airframe maintenance records. These documents can help determine how long the engine and airframe were a "paired" unit. Maybe your mechanic has been the only person working on your airplane since you owned it, or at least long enough to be confident to present you with a letter giving testimony that it is the one that your records show it to be. It should be remembered that any document that you present to substantiate your claim is considered as a legal document. Keep it truthful (enough said about that).
In the case of the engine data plate, the information that is going to be needed are the engine model and series number, and the engine serial number and the manufacturer of the engine. The inspector may also want you to show the total time on the engine, the Airworthiness Directive status, and any other information that you are required to have per the regulations (ref. FAR 91.417). Assuming that you have convinced the FAA that the engine is what you have been claiming all along, the Inspector will provide you with a letter attesting that he or she has determined that your claim is verified and that a replacement data plate should be issued to you. You can then write another letter to the manufacturer of the product and include the letter from the FAA Inspector, for your replacement data plate.
Buying a data plate and building an aircraft around it might seem like a good deal for both the seller and the buyer, but problems occur when two people try to be clever at the same time.
Highland Airport, Highland, Illinois
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Airworthiness Safety Program Manager
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