Argus & Relative Workshop

[JerryBaumchen 1,372]

Hi Mark,

As I prefer to say: I do not speak for the FAA & can only offer my thoughts.

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They are using the same TSO, but with the name change, so did ownership of the TSO.

I happened to talk to Bill Booth about this at PIA/Reno in '09 and I 'understood' that it was only a name change. If it is a new ownership that does change things.

I have an excerpt from an FAA document ( that was provided by the Seattle ACO ) with a section titled:

NAME, ADDRESS, OR OWNERSHIP CHANGES. It says, in part: 'However, the sale of a company, or the sale of TSO design rights is considered a transfer and continued production under the original TSO authorization would require the new owners to submit an application for an exemption per the procedures specified in 14 CFR Part 11. In either case, the intent is to permit continued production, in most cases of older TSO articles usen on existing type certificated aircraft.'

If you would like a copy, let me know & I'll send one to you.

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The TSO can only be owned by one responsible entity that reports to MIDO (FAA).

We might splitting hairs on this one; IMO a TSO holder can license an unlimited number of entities to use the TSO. The licensed entities need to have their own QA program approved & go through all of the hoops ( except the design testing & the submission of design test reports ) as a new applicant. Licensing is done quite often in aviation.

After all of the cows have come home, IMO it is the FAA who will make any final decisions. Although it does make for interesting internet discussions.

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Case and point,.. Sky Supplies, Inc, that built the original Mirage, later sold to National,

The TSO was held by an entity called Southeast Sewing. National did not buy it, they licensed it. I have a letter from National detailing the arrangement, less the financial considerations. Many, many years ago I discussed this with Larry Krueger on the details of how it was done. I do not say that I am an authority on these matters but I have discussed this with the Seattle ACO. The ACO in your area may say something different; IMO lack of consistency is a major problem within the FAA.

As to any previous liability, I would say that is to be determined. Every attorney I've ever talked to about it feels that they cannot dump the liability if the new product(s) are being built from the existing TSO. IMO the FAA would merely be an 'expert witness' should the matter end up in a courtroom.

I do accept that we each have our opinions and we can disagree. No harm, no foul.

Take care,

JerryBaumchen

[mjosparky 4]

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I was going to say, I'm pretty sure the 81 'hog I have sitting in my other room has the same TSO as my 2010 V3-M.

One of the main reasons behind a TSO is tractability of materials. That and a comprehensive QA system are in place to insure that each production unit is built to the same specifications as the one submitted for approval and testing. When one company takes over an issued TSO from another company they must also take over the historic records for materials tractability and develop a QA system that the FED’s will buy off on. The only way around this is to surrender the TSO and all related records.

Sparky

My idea of a fair fight is clubbing baby seals

[mjosparky 4]

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Getting to the field approval issue.....
It may come to this on all rigs as it stands now.

Can you say a little more about this? It seems like if all rigs will need some sort of approval, the simplest place to do that is with the rig manufacturers -- but then we wouldn't need field approvals, would we?

Or, since this is an Argus thread, are you suggesting that field approvals would be a way to get around the manufacturers' disapprovals?

Mark

Field approval would only be needed if an AAD install was to be done by other than the manufacture. That is the way it was handled when the newer AAD’s come along. The manufactures submitted a minor change and presto.

Sparky

My idea of a fair fight is clubbing baby seals