GE4509 landing light..

[mitsos]

Hi Guys

For those of you that are AME's
here is a question...
The SE airplane i own has a generic GE4509 light bulb as a landing light...
I have found an LED replacement PAR36 light from a Company that makes them and according to their customer service and tech support they are a replacement for 4509 bulbs...
NOW.. this sealed LED light is much IDENTICAL to the 4509 beam, only brighter, draws less amps..about 1.4 to 1.5A as opposed to 4.5 to 6A for the 4509, runs almost cool to the touch,
lasts 40000 hrs , nevers gets dull,sealed beam with epoxy ,no probs for vibration,screw type leads as it is on the 4509, allows you to change lens if it cracks or stone chipped(but it is unlikely this is bulid So strong)
Anyway i can go on...
It is not the STC wheelen crap for 450 bucks..
This is only 125 plus hst...., makes perfect sense...

Here is the million $ question..
Can i change the bulb myself ??..( that i know ) YES
does it have to be an STC bulb or a 4509? LED stcd?..
Doe this have to be signed off by an AME?...

For legality where im i at?

Cheers and thank you!!!!

[CID]

This comes back to "airworthiness". When you do maintenance, the airplane must conform to the type design. If that bulb isn't listed in an maintenance document identified it as part of the approved configuration, you can't install it. An STC can validate that part and add it as part of the type design for use on your airplane.

Lots of mumbo-jumbo there but in short, yes you need an STC to legally install a replacement landing light on your airplane. As far as requiring an AME to install it, once you have an STC I think it actually qualifies as elementary maintenance.

[624]

This might help you decide. http://www.tc.gc.ca/eng/civilaviation/r ... a-1893.htm
I would also call your local tc m&m office for further clarification.

[culver10]

You as the aircraft owner are responsible for maintaining your aircraft in an airworthy manner. As the AME, we are responsible to do and sign for any work we perform “in accordance with the applicable standards of airworthiness”. The only time that I sign that an aircraft is “Airworthy” and in compliance with the Type Certificate is when I sign the application for a Certificate of Airworthiness during an import. So I cannot install and sign for that nifty LED light, but if it was on the plane during and annual inspection, it would not bother “me” since I had nothing to do with it.

[ruddersup?]

If it has FAA/PMA on it, then it's good to go on.

[mitsos]

Thanks Guys

I appreciate that...

[CID]

ruddersup?, the regulation dealing with the installation of PMA parts states:

(a) except in the case of aircraft that are operated pursuant to a special certificate of airworthiness in the owner-maintenance or amateur-built classification, only parts that are specified in the type design of an aeronautical product, or that are approved alternative parts, are eligible for installation in that product;

Information Note:

An approved alternative part may be a replacement part that has been given either Part Design Approval (TCCA PDA) by Transport Canada or a Parts Manufacturer Approval (FAA PMA) by the Federal Aviation Administration.
(amended 2007/12/30; no previous version)

So you are correct, but the PMA part must be specified by the manufacturer as a replacement part for the part you are replacing. There have been a few issues in the past of people who just go ahead and install a PMA part only to find out that it was designed to replace a slightly different part.

So yes, but a little due diligence is in order.

[azimuthaviation]

If an aircraft has a transistor listed as the manufacturers part number it can be replaced with a commercial part but can an cross reference transistor be replaced if it is an equivelent part number?

[CID]

When a transistor is declared a "cross reference" it is usually the transistor manufacturer that makes that claim not a aviation regulatory authority. One of the most common instances of this when it comes to semi-conductors is the NTE line. They often cross reference to several similar transistors, not necessarily identical. Furthermore when cross referencing a part, its not enough to examine the performance characteristics. You also need to consider the quality control system of the manufacturer.

When an OEM chooses a part, they must qualify them against their quality system and register them as such. So why would they allow you to select a transistor that is not on the OEM's QPL? So no, you can`t legally use cross referenced transistors in aeronautical products unless the OEM makes allowance for it or if the modification is approved.

In the case of the replacement light, if it's not the same light intensity (higher or lower) do we know if it's bright enough or possibly too bright causing excessive glare? Is is a focused beam lke the original light or a wide angle diffused light?

[azimuthaviation]

What if it was a cross reference component that had the same performance characteristics and was approved for aviation?

[CID]

What is your interpretation of "approved for aviation"?

As far as a component that has the same performance characteristics, we're still in the same boat. If it doesn't have the same part number it doesn't conform to the type design. If you want to install a substitute, you need to apply 571.06 and determine if it's a major or "other than major" modification and pursue approval as prescribed.

For example, if you want to install a COM transceiver in a small aircraft, you can do so and use AC 43.13 as "specified data" as defined in 571.06. But....if the COM is not TSO'd you're out of luck. That's one definition of "approved for aviation" in the context that the TSO approves the COM and provides qualification to a standard.

If the COM isn't TSO'd you pretty much need an STC.

So if you have a transistor that happens to have a TSO, you're in luck...or are you? AC 43.13 doesn't ahve a section that installs transistors. So again...you pretty much need an STC. OEM service bulletins are OK too.

[azimuthaviation]

Are you familiar with this AD and corresponding SB? http://wwwapps3.tc.gc.ca/Saf-Sec-Sur/2/ ... -08-16.pdf

And since this AD is for the compliance to Narco SB AT150 No. 6, and Narco isnt answering their phone, what does someone do if such a transponder in that serial # range land on his bench? Can someone legally return it to serviceif the AD is outstanding? If someone has a copy of the SB in question how can one ascertain that it is the correct one and also that it has not ben superceded by a revision?

Also the transistor the SD calls for is not available anywhere on planet earth (the transistor part number required is a commercial part number and the resistor called for is only for a half Watt 1k Ohm (iirc) resistor).

EDIT: to clarify by return to service with AD outstanding I meant is it possible to return it to service it arrives with the AD outstanding. And when I say the correct one as far as a copy of the SB is concerned I mean how can someone verify the authenticity of the document, as well as provide a source for it.

[CID]

If you have an AT-150 and can't comply with the AD for whatever reason, the unit is not airworthy. That's a fact of life for aeronautical products that are no longer supported.

There are other options but likely not very cost effective. You can have DAR or DAO develop an "Alternate Means of Compliance" (AMOC) for that AD that introduces another suitable transistor and resistor. It would cost more than the transponder would cost to replace.

When there's a mandatory action like an AD or an inspection and you're in a position where the OEM no longer supports the equipment and parts are not longer available, you can't (legally) just throw up your hands and invent solutions and apply them under your AMO's authority. There are plenty of airplanes that have been taken out of service under similar circumstances.

I'm fully aware that this sort of thing happens in the field occasionally and the risk of it causing a serious problem especially in a Transponder is low but the risk of you being charged under the Aeronautics Act if you're caught.

I happen to know someone who got caught once. During an audit, the inspector noticed that a commercial part was used to repair a radio. The avionics tech fully admitted to it thinking it was OK. His AMO SCA suspension was 3 months.

[azimuthaviation]

So assuming the parts were available and a copy of the SB was available could someone still complete the AD/SB? My vote would be no because the source of the SB can not be traced back to any body that can issue it. My company's QA procedure states all manuals and information is considered uncontrolled documetation until it is verified as being current and correct. This is now impossible to do. In fact all Narco documentation is in the same category, so how can one return to airworthy condition a Narco ELT IAW CARs 571 Appendix G when it states certain parameters of the ELT "shall meet the specifications of the ELT manufacturer"?

[CID]

The answer is "due diligence". If you practice due diligence and determine that "to the best of your ability" the service bulletin is genuine and your manual was current on the date the OEM company was dissolved, I don't think TC would take issue with you. If your QA system verified that a manual was "current and correct", having the issuing company go out of business doesn't suddenly make it "non-current and incorrect".

I assume you don't verify the validity of your library on a daily basis or call the OEM before you use a manual to repair a component. So why wouldn't your last copy of the manuals and the service bulletins be "current and correct"?

And here's the obvious question. If you're concerned about these issues, why not ask your PMI?

[The Old Fogducker]

CID .... My "sixth sense" driven by inputs from my third eye tells me some "Inspector Shopping" is going on.

OFD

[SeptRepair]

Excellent discussion so far. Should make this recurrent training. Hopefully the aircraft owners out there are reading this and are getting an insight to the type of problems we AME's encounter on a daily basis with aging aircraft and components, and even why we cringe when they bring us the part to install.

[azimuthaviation]

I assume you don't verify the validity of your library on a daily basis or call the OEM before you use a manual to repair a component. So why wouldn't your last copy of the manuals and the service bulletins be "current and correct"?

Actually we do, on an as-required basis. Contacting the manufacturer is just a matter of checking their website. Until the manual on hand matches the listed document number, revision number and revision date it is deemed to be unapproved data, for reference only.

Im not terribly concerned, just curious as to what someone more stringent in his interpretations of these matters thinks/would do.