Avionics News February 2021 - 17

FREQUENTLY ASKED
QUESTIONS
United States
Fabricating an instrument panel
The following information is from Federal Aviation
Administration regulations and advisory circulars.

Question: How does a repair station fabricate
a new instrument panel as part of an aircraft
alteration?
Answer: Quite often, an avionics upgrade
is accompanied by the need to make a new
instrument panel. Over the years, this had been
described in numerous ways. With certain
exceptions, the former rule prohibited the
production of such parts for sale for installation
on a type-certificated product, unless those parts
were produced pursuant to a parts manufacturer
approval. The production of a part as a function of
maintenance was an exemption to the regulation.
In 2009, the regulation (14 CFR 21.9) was revised
to better represent the market and now includes a
regulatory basis for parts fabricated as a function
of repair and alterations.
14 CFR 21.9 Replacement and modification
articles.
(a) If a person knows, or should
know, that a replacement or
modification article is reasonably
likely to be installed on a typecertificated product, the person may
not produce that article unless it is
-
(1) - (5) ....
(6) Fabricated by an
appropriately rated
certificate holder with
a quality system, and
consumed in the repair or
alteration of a product or
article in accordance with
Part 43 of this chapter; or
(7) ....
Fabrication is defined as " An act in which a
part/subpart is made (fabricated) and consumed

by the fabricator on the product, or part thereof,
in the course of performing maintenance or
alterations in accordance with approved or
acceptable data, depending on the category
classification of the part being fabricated and the
applicable regulations. " (FAA AC 43-18)
The acceptable method of compliance to 14
CFR 21.9(a)(6) is contained in FAA Advisory
Circular 43-18 (latest revision). As stated in the
AC, " This AC provides one means of complying
with the requirements of Title 14 of the Code of
Federal Regulations (14 CFR) Parts 21 and 43
for the design and fabrication of parts by persons
performing maintenance and alterations using
methods, techniques, and practices acceptable to
the administrator. "
The AC defines the criteria necessary for
an appropriately rated certificate holder that
fabricates a part in the course of performing
maintenance or alterations which includes:
(1) Approved design data or data
acceptable to the administrator that is
determined by the CAT classification for
the part being fabricated; and
(2) An FQCS to ensure each fabricated
part conforms to its design data and is in
a condition for safe operation.
The criteria of the fabrication quality control
system is thoroughly discussed in the AC, and
repair stations are encouraged to review and
follow the guidance.
Since many repair stations will outsource the
fabrication of instrument panels, the repair station
should review the AC regarding guidance for
subcontractors. Again, from AC 43-18:
*	 When a subcontractor is used in the
fabrication process, the certificate holder
under whose surveillance the fabrication
occurs must control the design,
manufacture, and quality of the part.
*	 The work performed by the
subcontractor must be documented to
support a determination of conformance
to the purchase order requirements and
substantiated by a maintenance record.
*	 The documentation must describe any
special processes.
Subcontractors must be subject to control and
audit by the certificate holder fabricating the part
for return to service. q
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Avionics News February 2021

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