Airworthiness Notices - B037, Edition 1 - 4 April 1997
Installation of Automotive Heaters in Aircraft Engine Compartments
Purpose
The purpose of this notice is to inform the aviation public of the requirements associated with the installations of automotive heaters in aircraft engine compartments.
Background
The installation of automotive type heaters in aircraft engine compartments for the purpose of engine pre-heating has been found useful by many operators in dealing with aircraft exposed to extreme cold weather conditions.
Automotive heaters are not controlled aeronautical products, therefore, it is not the intention of Transport Canada to evaluate and approve such installations as they would normally be regarded as minor modifications. Notwithstanding, the installation of heaters requires certification by an Aircraft Maintenance Engineer (AME) to ensure that such an installation will not adversely effect the airworthiness of the aircraft.
Requirements
Prior to making the required certification, the AME must ensure that:
•The device is installed in such a way that it will not interfere with any control or the powerplant cooling airflow.
•The device is installed in such a way that no deterioration of plastic or rubber hoses, cable insulation etc., will occur as a result of the hot air efflux.
•Provisions are made so that, in the event the heater or any of its parts should become detached, no interference with controls or cooling airflow will result during aircraft operation.
•The method of attachment conforms to standard aeronautical practices as outlined in manufacturers' manuals or FAA A.C. 43-13-1A, etc.
•Provisions are made in the aircraft maintenance program to visually inspect, prior to the first flight of each day when the heater has been in use, items located in close proximity to the heater and that could have been affected by prolonged exposure to hot air efflux.
Should it become evident that, through cursory inspections or other means of verification, the installation fails to meet any of the criteria mentioned above, actions must be taken to rectify the deficiency prior to returning the affected aircraft to service.
Liquid Charlie wrote:
Burn one down and see if they are still your friend - search a little closer -- there is likely a clause about "being legal"
I suspect Lloyds and their underwriters will not pay out if your system is not approved -- the best way to clarify is to ask and see what their reaction to a non STC'd engine heating systems -- the insurance companies have no clue about heating or keeping an engine warm so it can be started -- all the care about is if you are adhearing to the rules and that there is no negligence -- unapproved equipment is negligent in their eyes no matter how practical it is -- it's similar to no one burning Arctic Diesel anymore - did it for years but not anymore --
'
It was when I was at First Air that we received the order to stop using "car warmers" because of the insurance company pulling the plug-so to speak -- the reality is that insurance companies will look for any abnormality so as not to pay out -- especially if you are a "little guy" who they don't want to insure in the first place.
Being STCd is only an issue if it's a permanent modification to the airframe. Usually the insurance policy will say they won't pay out if the plane is unairworthy or loaded beyond gross weight/CG limits. I'm pretty sure putting a space heater under the cowl or in the cockpit isn't going to render the aircraft unairworthy.
It sounds like maybe First Air just had twitchy lawyers or insurance. Having said that, if I had a multi-million dollar piece of equipment I probably wouldn't preheat it with a car warmer either.
CapnCrunch wrote:Being STCd is only an issue if it's a permanent modification to the airframe.
This Airworthiness Notice in question, AN B037, is with regard to a permanent installation.
azimuthaviation wrote:
So an aircraft is no longer in conformance with its type design if you add new equipment?
Everything done to an aircraft is allegedly done to:
Approved; Specified; or Acceptable Data.
From CAR 571.06:
“acceptable data” - includes:
(a) drawings and methods recommended by the manufacturer of the aircraft, component, or appliance;
(b) Transport Canada advisory documents; and,
(c) advisory documents issued by foreign airworthiness authorities with whom Canada has entered into airworthiness agreements or memoranda of understanding such as current issues of Advisory Circular 43.13-1 and -2 issued by the FAA, Civil Aviation Information Publications (CAIPs) issued by the Civil Aviation Authority (CAA) of the United Kingdom, or Advisory Circular, Joint (ACJs) issued by the Joint Aviation Authority (JAA) or Acceptable Means of Compliance (AMC) issued by the European Aviation Safety Agency (EASA); and,
(amended 2009/12/01; previous version)
(d) drawings and methods found appropriate by a delegate in conformity with paragraph 4.2(o) and subsection 4.3(1) of the Aeronautics Act. (données acceptables)
(amended 2009/12/01; previous version)
This is a common discussion about a topic that is easily explained but seldom understood for some reason. TCCA defines "airworthy" as "in a fit and safe state for flight AND in conformity with its type design".
If you add equipment to your aircraft it is not airworthy until the installation is certified using the appropriate data. (See 571.06)
Not "type certificate", "type DESIGN". You can look in the 100 series of the CARS for the definition. The type certifcate is just part of the type design.
TCCA is suggesting the installation of a car warmer is likely "minor" (or more correctly...not major) therefore "accepable" data would be appropriate.
If you spent $150,000 on a hangar, would you put a $10 lock on the front door? Seems trying to find the cheapest way to preheat your engine is skimping out on a critical part of aircraft maintenance?
photofly wrote:
If I can have an AME install a Canadian Tire buddy heater, can I have him or her install a car battery from Canadian Tire too?
How about some curtains and an ornamental fountain?
See my post above, with the CAR reference, allowing the install of the ceramic heater. The Airworthiness Notice is not extended to curtains or ornamental fountains or batteries from Canadian Tire.
photofly wrote:
If I can have an AME install a Canadian Tire buddy heater, can I have him or her install a car battery from Canadian Tire too?
How about some curtains and an ornamental fountain?
See my post above, with the CAR reference, allowing the install of the ceramic heater. The Airworthiness Notice is not extended to curtains or ornamental fountains or batteries from Canadian Tire.
I'm missing something. The AN says:
"Automotive heaters are not controlled aeronautical products, therefore, it is not the intention of Transport Canada to evaluate and approve such installations as they would normally be regarded as minor modifications."
Neither a battery nor an ornamental fountain from Canadian Tire are controlled aeronautical products either. How would I know whether I can have an AME install one in an aircraft?
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DId you hear the one about the jurisprudence fetishist? He got off on a technicality.
Before electricity people would paint their nacelles black and use coals and a tent to preheat. Then came herman nelson blowing hot air but was bulky. Then came tanis pads and ceramic heaters which make life a bit easier. The one thing that all these systems share is the need for insulation. Add covers or tents or blankets and you're all set.
Perhaps you'd care to qualify that statement? Why wouldn't you let it anywhere near an airplane?
For starters, you are using a heater that is not rated for outdoor use and you would have had to bypass the "tip-over" safety switch to make it work. In any serious cold the fan will seize up and the heater coils will overheat a few times before the overheat switch fails. They aren't made to cycle for very long.
It would be a no-brainer for ANY lawyer to convince a judge that the insurance company is off the hook for damages.
Furthermore, as someone else stated, the thing wouldn't work for any significant cold weather. Most of the heat would be lost en-route to the engine compartment. Air is not the greatest medium to transfer heat. Especially when there is nothing used to isolate the compartment.
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Last edited by CID on Sat Feb 08, 2014 2:47 pm, edited 1 time in total.
I figured it would be helpful to discuss a few of the STC points brought up.
When you modify an airplane, an AME must determine if the mod is "major" or not. Major mods need to be done IAW "approved" or "specified" data. That's an STC (approved) or an SB or other authoritative data (specified) and for small aircraft an AME can even use AC.43.13 as specified data.
Also, if an airplane is not in conformity with its type design and/or not "safe for flight" it's not "airworthy" and the C of A is not in force.
So that means that airplanes that are in the middle of a wheel change or airplanes that are sitting in a parking lot with a little buddy in the cowling and plugged in is not airworthy. Unplug it and as long as the dead heater is mounted in accordance with AC 43.13 standards and properly signed off, it's airworthy and the C of A is back in force. Of course as long as everything else is up to snuff.
The fact that the thing is from Canadian tire doesn't hinder you if you're just installing a non-functioning gizmo. Just be careful of the flammability potential.
And yes, theoretically you can install all sorts of things from Canadian Tire on an airplane as long as the proper data is used. A battery could be installed but it would be a major mod and the battery would need to be properly qualified.
A car stereo can likely be installed in a small airplane IAW AV 43.13 since it doesn't perform any critical function. And again, as long as it's documented properly. Yes, its a major mod but 571 lets an AME use AC 43.13 as "specified" data for small airplanes.
-- the reality is that insurance companies will look for any abnormality so as not to pay out -- especially if you are a "little guy" who they don't want to insure in the first place.
