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Old 5th Mar 2018, 01:17
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US STC

HI Everyone,
I've exhausted avenues to gaining an Australian STC for my camera pod.
Does anyone know of a US company that may suit. My searches only seem to find the bigger companies that modify jets and such.
Regards,
MC.
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Old 5th Mar 2018, 02:49
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Originally Posted by Murray Cod
HI Everyone,
I've exhausted avenues to gaining an Australian STC for my camera pod.
Does anyone know of a US company that may suit. My searches only seem to find the bigger companies that modify jets and such.
Regards,
MC.
Are you talking about a company who can do the relevant engineering drawings/tests or someone who can process the paperwork? Why have you ruled out the oz options?
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Old 5th Mar 2018, 07:25
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I've done all that, it's got an EO and the camera pods been in operation for over a year.
The 2 Aero Engineering firms I approached said that it's near impossible to gain an STC through CASA and it's easier and cheaper to obtain a US STC and get it rubber stamped in Aus.
I even organised the manufacturing through CASA production approved companies.
It was designed by a mechanical design engineer with paperwork.
I even have the CAM step program for the laser cutter.
But the CASA paperwork is the stopper. "A waste of Time"
If I ever get an STC'd pod, I'll be sure to have "made in the USA" boldly printed on the side of it.
I want to sell then over there anyway ,I tried to make them here but the "innovation nation" makes it impossible.
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Old 5th Mar 2018, 07:41
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My understanding is Gippsland Aero had this same issue with the cargo pod for the Airvan GA8's.

They got them STC'd in the USA I heard - if that's true try them.
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Old 5th Mar 2018, 07:59
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You can get a US or EASA STC in Australia, there are people in Nova Systems that can do that.
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Old 7th Mar 2018, 11:52
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Folks,
Sadly, Murray Cod's experience is SOP with CASA, as is the advice to get an FAA STC.

I could (but I won't) quote the experience of a number of small and innovative Australian companies that have gone down the FAA (not EASA) route, CASA being impossible, timescales quoted in years, not months, not to mention the scale of CASA charges sending you broke.

Another benefit of the FAA route, a commercial imperative, is that quite a few national authorities will not recognise a CASA STC, largely because these national authorities do not regard CASA as competent, probably quite a reasonable assessment.

Even with the US/AU bi-lateral airworthiness agreement, a CASA STC is not a given to be accepted in the US, and good old CASA will even put roadblocks in the way of that, even if you do get a CASA STC.

An FAA production certificate will also be easier to arrange/maintain.

Tootle pip!!
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Old 7th Mar 2018, 22:46
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Originally Posted by Murray Cod
HI Everyone,
I've exhausted avenues to gaining an Australian STC for my camera pod.
Does anyone know of a US company that may suit. My searches only seem to find the bigger companies that modify jets and such.
Regards,
MC.
You need an EO, Engineering Order, from a Part 21M organisation not an STC.
I cannot see any reason why you are having an issue with this.
What am I missing here?
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Old 7th Mar 2018, 23:45
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Originally Posted by Eddie Dean
You need an EO, Engineering Order, from a Part 21M organisation not an STC.
I cannot see any reason why you are having an issue with this.
What am I missing here?
Then every aircraft would need its own EO to install the pod. An STC doesn’t require every single aircraft to have its’ own individual EO tied to the specific airframe.
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Old 8th Mar 2018, 04:25
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Havick,
Eddie, I think, doesn't like people criticising CASA. CASA would never obfuscate the issue, now, would they??
I am certain Eddie well knows that the STC is the way, if you want to produce and sell in numbers, particularly to the biggest market, USA/Canada.
Tootle pip!!
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Old 8th Mar 2018, 09:43
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just take your product to the U.S. , there is no point trying to do anything from here.
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Old 8th Mar 2018, 11:02
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Got a good example of an EO for you.
If you wanted a set of brakes/tailwheel for your Tiger moth, you simply bought the kit from local supplier, got a separate EO for each aircraft (about $600 each I think), and had a LAME fit the kit. Cost of getting an STC was prohibitive so I'm told. But never mind, $600 for a piece of paper with your own personal VH on it wasn't too onerous, and you could always frame it.
Because the kit included commercial parts (non PMA parts), and due to our recently embracing all things European (EASA), as from a year or so ago no more commercial parts on aircraft, so no more EO. Extremely expensive exercise now, almost impossible I'm told.
So, about 200 Tigers modified in this fashion over many years, contributing greatly to their safety, and with no adverse events I've heard of.
Now no more brakes/tailwheel for Tigers, unless you can find an original set (impossible).
Thanks to CASA all the other Tigers and those currently being restored will have to stick with the skids and no brakes, or pay an absolute bomb for an EO (if you can find someone prepared to do it). Well done CASA. But then I suppose they don't make the rules...........do they?
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Old 8th Mar 2018, 23:01
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Originally Posted by CHAIRMAN
Got a good example of an EO for you.
If you wanted a set of brakes/tailwheel for your Tiger moth, you simply bought the kit from local supplier, got a separate EO for each aircraft (about $600 each I think), and had a LAME fit the kit. Cost of getting an STC was prohibitive so I'm told. But never mind, $600 for a piece of paper with your own personal VH on it wasn't too onerous, and you could always frame it.
Because the kit included commercial parts (non PMA parts), and due to our recently embracing all things European (EASA), as from a year or so ago no more commercial parts on aircraft, so no more EO. Extremely expensive exercise now, almost impossible I'm told.
So, about 200 Tigers modified in this fashion over many years, contributing greatly to their safety, and with no adverse events I've heard of.
Now no more brakes/tailwheel for Tigers, unless you can find an original set (impossible).
Thanks to CASA all the other Tigers and those currently being restored will have to stick with the skids and no brakes, or pay an absolute bomb for an EO (if you can find someone prepared to do it). Well done CASA. But then I suppose they don't make the rules...........do they?
Mmmm Not wanting to gainsay your thoughts, but I am still using EO for commercial timkon bearings as well as a couple of other EOs for commercial products.
Do you have a reference?
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Old 9th Mar 2018, 11:01
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No problem EDDIE. There is no retrospectivity, so any EO already issued is still OK, but don't try to get another one - so I'm told.
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Old 9th Mar 2018, 13:38
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Originally Posted by CHAIRMAN
No problem EDDIE. There is no retrospectivity, so any EO already issued is still OK, but don't try to get another one - so I'm told.
Time to find a new engineer chairman: AC21-08 provides very specific advice on how to incorporate commercial off the shelf components into modifications and repairs.
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Old 10th Mar 2018, 14:40
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Originally Posted by Murray Cod
HI Everyone,
Does anyone know of a US company that may suit. .
There are several paths to follow to an STC, but since you're based outside the US a few more steps may be needed. I've seen a couple ways used but don't know if they would be advantageous to your product.

First path, contact a Management Designated Engineering Representative (DER) and inquire on the process. A Manage DER is "authorized" to assemble the STC application package (not solely approve data) and work it through the process. Plus they work directly with/for you.

Second path, contact an FAA Aircraft Certification Office (ACO) for info. ACOs are the ones who approve all STCs regardless origin.

A list of DERs can be found here:
http://www.faa.gov/other_visit/aviat...rdirectory.pdf

ACOs:
https://www.faa.gov/aircraft/air_cer...te_office/aco/
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Old 11th Mar 2018, 06:07
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and due to our recently embracing all things European (EASA)
Chairman,
What you meant to say was:"due to our recently embracing a CASA bastardized and unrecognisable interpretation of all things EASA, starting with completely losing the outcome based principles of EASA regulation, in favour of CASA preferred rigidly prescriptive criminal law ----".
Tootle pip!!
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Old 11th Mar 2018, 13:45
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Time to find a new engineer chairman: AC21-08 provides very specific advice on how to incorporate commercial off the shelf components into modifications and repairs.
Dunno Progressive.
AC21-08 was only issued Feb 2015, and does indeed provide specific advice as you say. My reading of it seems to concur with my Aeronautical Engineer EO guy - that the cost to incorporate COTS parts in any new EO is extremely/prohibitively expensive. Better to completely rejig any design to use PMA parts.
Any EO guys here?
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Old 14th Mar 2018, 14:02
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Chairman et al,
Some thorough scrutiny of the FAA "rules" when you are the STC holder or the PMA holder may well prove worthwhile.
I refer, of course, to the FAA process for both of the above finding compliance for materials used in manufacture.
For example, there is no PMA (or otherwise approved) manufacturer of the large diameter aluminium irrigation pipe that forms a substantial part of the fuselage of several LSA, but the same general principle applies to any Part 23 aircraft. It is, in this case and similar, the STC/PMA holder that finds compliance as per their specifications that form a major part of the STC/PMA documentation.
Tootle pip!!

PS: There is one helicopter manufacturer uses off spec (out of tolerance) new production bearing in a rotor head, the normal industrial spec. is "too tight", so they use bearing that have failed QC because the races have "excess" clearance. OK in you rotor head but already worn out, if it is the front wheel bearings of your auto. The bearing OEM is more than happy to sell a few sets, rather than having to bin them.
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Old 15th Mar 2018, 12:50
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Some thorough scrutiny of the FAA "rules" when you are the STC holder or the PMA holder may well prove worthwhile.
Ah Leadie, therein lies the rub.
The outfit making the brake kits for Tigers the past 20 years doesn't have PMA or STC (wildly expensive to get, so went the individual EO way), and I'm sure that the manufacturer of the motorcycle brake parts used doesn't have PMA or STC either.
So it seems to be go the expensive E(C)ASA compliant way or go home.
Not saying the non E(C)ASA compliant way to go is, but when a simple system has been working trouble free for 20 years, saving untold damage and injury, these new rules appear to have the effect of chucking the baby out with the bathwater.
Cheers
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Old 17th Mar 2018, 07:45
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and I'm sure that the manufacturer of the motorcycle brake parts used doesn't have PMA or STC either.
Chairman (and others)
Re. the above motorcycle parts mentioned, whether it is part of an STC'd kit/incorporated in a kit made made under a PMA or, for that matter, an OEM, the motorcycle brake manufacturer doesn't have to do anything, aviation wise.
It is the STC/PMA organisation who find the appropriate bits to "conform" to the approved design. They do have to be careful that the motorcycle brake manufacturer does not have conditions of sale barring the aviation use --- I have seen that bear trap happen.

Likewise with standard parts, it is the STC/PMA/OEM that finds compliance with the approved design.

I can't see how that has changed with the "new" rules, it hasn't re. FAA, and FAA and EASA have a high level of harmonisation here, so it sound more like CASA nonsense to me. I have had a quick look through the current CASR 21 etc., and related ACs, maybe a few in CASA can't read.

When it comes to COTS, there is a lot of absolute rubbish talked/written about "aeronautical standards".

Many years ago, there was a big blue here, about the cost of wheel bearings from a (then CAA) "approved supplier", a local CAR 30 shop/LAME was accused of using auto bearings in Cessna wheels that "didn't conform to aeronautical standards".

To the embarrassment of (by the time it came to court) of CASA and the "approved supplier" it was established in evidence that the method of elevation of parts to aeronautical standards, "aeronautical approval" consisted of the approved supplier taking delivery of said bearing from a local commercial bearing specialist, and raising an invoice with company's CASA APPROVAL number, and the bearing number on said invoice.

Of course, the big difference was price, the "bit of paper" that turned the ordinary or common garden variety bearing set into "aviation standard" was a price escalation of about 8+ times.

It was also established that the reason why these bearing were only available in the afternoon was that none were kept in stock, and the bearing company delivered on this aerodrome at around 11.00 am every day.

The same CASA Approved supplier had a slightly more complex method of supplying "aviation standard alternators". The standard Delco auto units would arrive in bulk, about 20 a time. A workman had a set of metal stamps, and a part number and serial number would miraculously appear on the frame of the alternator, the same number on the accompanying crisp, crease free release note. And a tenfold increase in price, compared to Repco retail.

Just today, in a current aviation publication, I have been reading a complete nonsense advertisement about "aviation grade" wheel bearings. Think about how much hard work a set of bearing does in the front wheel hub of your (2000kg RWD) car --- maybe 100,000 km, then think how much work the same bearing does in a Cessna 152 wheel.

Tootle pip!!

PS: Back to the thread. If you want to sell significant numbers, the FAA STC is the way to go, forget CASA

Last edited by LeadSled; 17th Mar 2018 at 13:55. Reason: PS added.
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