Transcript Document
Replacement Precision Instrument Bearings Agenda No. 15 • Issue: Replacement Precision Instrument Bearings • Avionics repair and overhaul shops are claiming to be at a competitive disadvantage with respect to US repair shops. The FAA allows replacement instrument bearings that are purchased directly from the bearing manufacturer rather than from the OEM (Instrument manufacturer). • RECOMMENDATION: Request that TCCA prepare formal guidance material on this issue. AEA Canada and other interested sources may have valuable input 1 Replacement Precision Instrument Bearings • TCCA concurs that guidance material on this subject would greatly assist the instrument repair shops • Documentation that will harmonize the process internationally and domestically is in the works 2 Replacement Precision Instrument Bearings • Documentation should be ready for distribution early in the new year 3 Replacement Precision Instrument Bearings • TCCA Position: To ensure harmony between the TCCA and the FAA position, TCCA reviewed the following FAA documents: FAA Notice N8110.73 (cancelled) - IMPLEMENTATION OF TECHNICAL Flight Standards Handbook Bulletin for Airworthiness (HBAW) HBAW 9819A (AMENDED) - Implementation of Technical Standard Orders for Parts: STANDARD ORDERS (TSO) FOR PARTS TSO-C148, Aircraft Mechanical Fasteners; TSO-C149, Aircraft Bearings; and TSO-C150, Aircraft Seals FAA Notice N8110.73 regarding part substitution 4 Replacement Precision Instrument Bearings • • 1. The replacement bearing must have FAA TSO c149 approval. 2. The bearing manufacturer must provide a letter that clearly establishes that the bearings being provided to the overhaul facility are the same as the bearings that they ship to the instrument manufacturer as listed in the original instrument manufacturer’s documentation. 3. The installer must prove that the instrument manufacturer does not have a screening or modification program that would result in the bearings being altered by the instrument manufacturer or meeting tighter tolerances, etc. This combination of a TSO and letter of confirmation from the bearing manufacturer would be considered “specified data” under the requirements of CAR/STD 571.06. In the absence of the above information and where it cannot be established that the proposed replacement bearing is the same as the one used by the original instrument manufacturer, additional information and substantiating data would be required leading to the issuance of an RDC or a PDA. 5 Replacement Precision Instrument Bearings • TCCA Position In the absence of meeting the criteria set out and where it cannot be established that the proposed replacement bearing is the same as the instrument manufacturers, a separate approval would be required: • Supplemental Type Certificate • Part Design Approval 6