How To: Owner Produced Parts

[Kristin Winter]

Many of you know that “owner-produced” parts are becoming a more common way of obtaining replacement Comanche parts. Webco, Comanche Gear, McFarlane, and others have experience duplicating original Piper parts. When the market is big enough, sometimes the producer will get a PMA (FAA Parts Manufacturing Authority). For the parts with little turnover, often custom fabrication is the only way to go.

FAR Part 21.9(a) If a person knows, or should know, that a replacement or modification article is reasonably likely to be installed on a type-certificated product, the person may not produce that article unless it is — (here is our exception) (5) Produced by an owner or operator for maintaining or altering that owner or operator's product.

Note that this regulation is directed at the person/entity making the part. To make it legal for them, you need to provide them with certain things to prove that the part was being produced for an owner, at the owner’s behest. Attached is a form that you can consider using when ordering a part to be made.

To make it legal for both, the owner/operator needs to have some involvement in the production process. The FAA has given several examples of what would count as owner involvement:

1. The owner provided the manufacturer with the design or performance data from which to manufacture the part. (This may occur, for instance, where a person provided a part to the manufacturer and asked that the part be duplicated.)
2. The owner provided the manufacturer with materials from which to manufacture the part.
3. The owner provided the manufacturer with fabrication processes or assembly methods to be used in the manufacture of the part.
4. The owner provided the manufacturer with quality control procedures to be used in the manufacture of the part.
5. The owner supervised the manufacturer of the part.

There may be others that would qualify. The easiest might be to send them the old part. If you use the attached form, or something similar, there will be a paper trail to cover everyone.

If anyone has any questions or specific examples, feel free to post here. If you need a formal legal opinion for CYA purposes, you can email me at kristin at aviatrixlawyer dot com.

Keep ‘em flying!

[N3322G]

Thank you Kristin!

[Ed Asmus]

I also thank you!

Ed Asmus