Expert Witness Blog
In Parts Produced by an Owner or Operator. Are They Legal? aircraft operations expert witness David A Botich writes on how owners may keep their aircraft airworthy if parts are unavailable or otherwise unobtainable:
As this has been a subject that many have asked “how do I do this?”, the Assistant Chief Counsel for Regulations, AGC-200 of the FAA has written a Memo addressing this issue. I will summarize the main points of concern here.
1. Only the owner/operator can produce the part for their aircraft. They cannot produce that part for sale or for another aircraft.
2. The owner/operator doesn’t need to actually produce the part but must be the “producer” by overseeing and directing the production process. This means that he may hire another person to make the part so long as he is directly responsible for the process by participating in the design, manufacturing and quality control.
3. The part must be produced using the same design data, material, process, etc. that was used to produce the original part. This can be done by using the original FAA approved design data or by reverse engineering the part.
4. The part is an FAA approved part as it meets the requirements of FAR 21.303
5. The producer must properly document the production process. All approved parts require this documentation process.6. The part can be manufactured by either a certificated or non-certificated entity
Once the part is produced it will require the installation by a certificated mechanic or facility.