New sumps

[flyboy122]

I will do the PMA thing with the FAA. it's just paper work.

TC,

Have you PMA'd something before? Recently?

DEM

[T. C. Downey]

Have you PMA'd something before? Recently?

DEM

Why? have the rules changed?

[GAHorn]

Will this be a 3-bolt? or 5-bolt sump (for accy-case fitment....folks will need to know what theirs is when they order...)

[T. C. Downey]

Will this be a 3-bolt? or 5-bolt sump (for accy-case fitment....folks will need to know what theirs is when they order...)

You'll find the three hollers don't have this problem. Anyway this is for a 5 holler

[edbooth]

Will this be a 3-bolt? or 5-bolt sump (for accy-case fitment....folks will need to know what theirs is when they order...)

You'll find the three hollers don't have this problem. Anyway this is for a 5 holler

Not true, I have a three holer in my pile of hangar stuff and it has the beginnings of the corrosion problem, but not bad yet. I think it came off a C-125.

[T. C. Downey]

Will this be a 3-bolt? or 5-bolt sump (for accy-case fitment....folks will need to know what theirs is when they order...)

You'll find the three hollers don't have this problem. Anyway this is for a 5 holler

Not true, I have a three holer in my pile of hangar stuff and it has the beginnings of the corrosion problem, but not bad yet. I think it came off a C-125.

There's no shortage of three bolt sumps I have 1 also. there simply isn't a problem getting one.

[Jason]

Ok. Can you put a 3 bolt sump and matching accessory case on an O-300A? Supposing its possible is there disadvantages to doing this?

[T. C. Downey]

Ok. Can you put a 3 bolt sump and matching accessory case on an O-300A? Supposing its possible is there disadvantages to doing this?

no...

[flyboy122]

Have you PMA'd something before? Recently?

DEM

Why? have the rules changed?

TC,

When it comes to getting things certified, the FAA has been adhering to Moore's Law. It seems like the amount of paperwork, signoffs, justifications, etc... doubles every 18 months. Notice there is no smiley face here. This is the unfortunate reality we are dealing with.

If you have experience with this type of thing, no problem. You know what you are in for. If not, I would highly recommend researching the PMA requirements first. I did a quick check on the FAA website and the AC for the parts approval was 60 some pages alone (you need manufacturing approval after that).

DEM

[T. C. Downey]

Have you PMA'd something before? Recently?

DEM

Why? have the rules changed?

TC,

When it comes to getting things certified, the FAA has been adhering to Moore's Law. It seems like the amount of paperwork, signoffs, justifications, etc... doubles every 18 months. Notice there is no smiley face here. This is the unfortunate reality we are dealing with.

If you have experience with this type of thing, no problem. You know what you are in for. If not, I would highly recommend researching the PMA requirements first. I did a quick check on the FAA website and the AC for the parts approval was 60 some pages alone (you need manufacturing approval after that).

DEM

For the sake of the argument, let's say the PMA can't be gotten.
Could you still use the part?

[GAHorn]

If the owner specified to TC Enterprises that the owner wished TCE to "reverse engineer" his unserviceable sump and build a new one...and then the owner participated in the final "quality control inspection" of that sump prior to his A&P installing it upon the owner's engine..... then it would be legal (as an "owner produced part".)
The problem would be that the "reverse engineered sump" would be made of exorbitantly-expensive magnesium....not aluminum as TCE proposed.
An STC would likely be required if the replacement was made of aluminum, and a PMA would be required if multiple sumps were made and offered for sale to the aviation public regardless of the material or process utilized.
It's not impossible. But it adds to the complexity of the process and therefore the cost.

[T. C. Downey]

The 0-300 sump is not a structural part, would the material change be a major modification or a minor?

Who declares airworthiness?

[flyboy122]

The 0-300 sump is not a structural part, would the material change be a major modification or a minor?

Who declares airworthiness?

TC,

There are major/minor determination criteria from the FAA somewhere, I just can't happen to find it right now. I'm betting a material change is major.

As to who declares airworthiness, well the final determination is always up to the person installing the part (a&p, repair station, or owner). What that person will need is an 8130 or a Certificate of Conformance. In order to put that on the part it will have to have been inspected by a DAR, or have gone though an approved quality system (this is part of the manufacturing side of the PMA). The inspectors will be looking to see that the part conforms to the FAA approved drawing. In order to get the drawing approved you will need to go through the part PMA process. If you are making any changes whatsoever (and perhaps even if you aren't) you will most likely need a DER to sign off on it. It seems like lately the FAA doesn't want to even look at something until a DER has given it the ok. Starting to get the picture?

My apologies if this sounds like I'm trying to rain on your parade. That is not the intent. I'm just trying to help you take the appropriate path to where you want to be. If you feel there is a real market out there for these sumps and the goal is to set up a business selling these things for the long term, then a PMA is appropriate. If you are just trying to solve a headache for yourself and a few buddies, then you may want to look into just getting a field approval. A third alternative is to find someone who is already PMA'ing engine parts or Cessna parts, take your 10-20 customers, and see if they would be interested. If they are already making parts, it will be a lot faster/easier to add another than to start from scratch. (A friend of mine up in Alaska has F. Atlee Dodge build helicopter baskets for him for this very reason. Dodge has all the approvals, my friend puts up the money and markets/sells them.)

Good luck, and don't give up! Despite the headaches, making and selling airplane parts is fun!

DEM

[T. C. Downey]

FAR 43.13 (b) Each person maintaining or altering, or performing preventive maintenance, shall do that work in such a manner and use materials of such a quality, that the condition of the aircraft, airframe, aircraft engine, propeller, or appliance worked on will be at least equal to its original or properly altered condition (with regard to aerodynamic function, structural strength, resistance to vibration and deterioration, and other qualities affecting airworthiness).

That's fit form and function.

here are the things that will be a major alteration. remember the sump is not a structural part.
FAR 43. Apendix A

(2) Powerplant major alterations. The following alterations of a powerplant when not listed in the engine specifications issued by the FAA, are powerplant major alterations.

(i) Conversion of an aircraft engine from one approved model to another, involving any changes in compression ratio, propeller reduction gear, impeller gear ratios or the substitution of major engine parts which requires extensive rework and testing of the engine.

(ii) Changes to the engine by replacing aircraft engine structural parts with parts not supplied by the original manufacturer or parts not specifically approved by the Administrator.

(iii) Installation of an accessory which is not approved for the engine.

(iv) Removal of accessories that are listed as required equipment on the aircraft or engine specification.

(v) Installation of structural parts other than the type of parts approved for the installation.

(vi) Conversions of any sort for the purpose of using fuel of a rating or grade other than that listed in the engine specifications.

see any thing there that requires anything but the installers approval?

[voorheesh]

To answer your question: Appendix A to Part 43 Major Alterations (v) installation of structural parts other than the type of parts approved for the installation. The sump of an 0-300 is a magnesium structure that collects the oil that lubricates the engine. To change it to aluminum is a major alteration that will require an engineering evaluation. This "opinion" is not based on some bureaucratic concern over the definition of the word "structure". It is based on the simple fact that you wouldn't want to modify something as important as a sump without making sure you are covering ALL THE BASES and producing a component that will be safe and reliable.