1 

### Edinger, Richard

From: jay.turnberg@faa.gov

Sent: Wednesday, August 07, 2013 4:19 PM

To: Christopher.J.Richards@faa.gov

Cc: Edinger, Richard

Subject: Re: Fw: 45.11 and 45.13 ?

Attachments: pic20055.jpg; pic20328.jpg

Dick and Chris,

The fireproof marking is not an issue. The markings are on thick aluminum which does not

burn and will stand up to heat for a period of time.

Jay Turnberg

Engine & Propeller Directorate Standards Staff, ANE

‐ 111 Federal Aviation Administration

781

‐ 238

‐ 7116

From: Christopher J Richards/AGL/FAA

ACE

‐ CHI

‐ ACO

‐ 118C, Chicago, IL

To: redinger@hartzellprop.com,

Cc: Jay Turnberg/ANE/FAA@FAA

Date: 08/07/2013 04:14 PM

Subject: Fw: 45.11 and 45.13 ?

Hi Dick,

I spoke with Jay today regarding the issue of TC number marking on propeller blades. After a

discussion with our legal group we determined that Hartzell is not in compliance with 45.11

and 45.13. Going forward, Jay and I agreed there are two logical courses that Hartzell could

choose to take.

1) Apply for an exemption to these regulations. Hartzell will need to provide a justifiable

reason why it is not feasible to comply with these regulations.

2) Begin marking all applicable TC numbers on propeller blades. Also, create a service

bulletin that will have TC numbers marked on the blades at next opportunity.

Of the two, I would imagine that applying for an exemption would be the easier route. When

you are back in the office, give me a call and we can discuss this in more detail.

Regards,

Chris

Christopher J Richards

Senior Aerospace Engineer

FAA Chicago Aircraft Certification Office

Tel: 847

‐ 294

‐ 7156

Email: christopher.j.richards@faa.gov

‐‐‐‐‐ Forwarded by Christopher J Richards/AGL/FAA on 08/07/2013 03:07 PM

‐‐‐‐‐

From: Jay Turnberg/ANE/FAA2 ANE

‐ 111, Rulemaking and Policy

To: Daniel Kerman/ANE/FAA@FAA,

Cc: Christopher J Richards/AGL/FAA@FAA

Date: 07/31/2013 03:34 PM

Subject: Re: Fw: 45.11 and 45.13 ?

Hi Dan,

I have been doing some digging and it turns out that Hartzell has never followed the part

marking requirement to include the TC number on the blades because some of their blades can

be installed on many propeller applications and they wanted to be consistent for all blades

produced.

This goes all the way back to CARs. Some of the history is that the rules

said you had to have different TCs for propellers with different numbers of blades.

Therefore, if Hartzell had identical blades that could be installed on 2, 3 or more blades

propellers they did not want to limit the installation for identical blades. The

practicality of this would be that if the blade was initially for a 2 bladed propeller and

was stamped with a TC number but then they introduced another propeller that used the

identical blade it would have the wrong TC number. There is no safety issue but there is a

non

‐ compliance issue. I need to coordinate more with the Chicago ACO to learn why this has

gone on forever. There may be some old documentation that lets them do this. Technically,

Hartzell should apply for an exemption to the requirement.

We had a part marking issue with Sensenich wood propeller company because they have always

burned the part marking into their wood propellers. The rule calls for part marking to be

fireproof, wood burns. Sensenich applied for and was granted an Exemption. This could be a

potential problem for aluminum blades and hubs because the fireproof definition says at least

as well as steel. The marking on aluminum hubs and blades are typically stamped. Is an

aluminum blade or hub fireproof?

It is unfortunate that part 45 wasn't modified for the fireproof and TC marking issues when

it was updated a couple of years ago.

Jay Turnberg

Engine & Propeller Directorate Standards Staff, ANE

‐ 111 Federal Aviation Administration

781

‐ 238

‐ 7116

From: Daniel Kerman/ANE/FAA

ANE

‐ 180, Boston Manufacturing Insp Office

To: Jay Turnberg/ANE/FAA@FAA,

Date: 07/31/2013 09:14 AM

Subject: Fw: 45.11 and 45.13 ?

Any news??

Daniel Kerman

Safety Management Integration

Manufacturing Process Specialist

Manufacturing Inspection Office, ANE

‐ 180

Tel: (781) 238

‐ 7195

Fax: (781) 238

‐ 78983 Email: daniel.kerman@faa.gov

‐‐‐‐‐ Forwarded by Daniel Kerman/ANE/FAA on 07/31/2013 09:13 AM

‐‐‐‐‐

From: Michael Alberts/ACE/FAA

ACE

‐ 180, Manufacturing Inspection Office

To: Daniel Kerman/ANE/FAA@FAA,

Date: 07/25/2013 01:59 PM

Subject: Fw: 45.11 and 45.13 ?

Dan,

by chance, do you have any input regarding the propeller/part marking question below? or

should I contact Jay?

Michael M. Alberts(Embedded image moved to file: p ic20055.jpg) Technical & Program Management

Specialist Manufacturing Inspection Office

816

‐ 329

‐ 4189

‐‐‐‐‐ Forwarded by Michael Alberts/ACE/FAA on 07/25/2013 12:57 PM

‐‐‐‐‐

From: Daniel Kerman/ANE/FAA

ACE

‐ 180, Manufacturing Inspection Office

To: Michael Alberts/ACE/FAA@FAA,

Cc: Carlos Pestana/ANE/FAA@FAA

Date: 06/18/2013 03:27 PM

Subject: Re: Fw: 45.11 and 45.13 ?

Mike: Let me get with Jay Turnberg who is our Part 35 expert!! I think I know the answer,

buy cahnce but want to check with him first!! Talk to you tomorrow.

Best Regards

P.S. Any Pilot Program activity on your end??

Daniel Kerman

Safety Management Integration

Manufacturing Process Specialist

Manufacturing Inspection Office, ANE

‐ 180

Tel: (781) 238

‐ 7195

Fax: (781) 238

‐ 7898

Email: daniel.kerman@faa.gov

‐‐‐‐‐ Michael Alberts/ACE/FAA wrote:

‐‐‐‐‐

To: Daniel Kerman/ANE/FAA@FAA

From: Michael Alberts/ACE/FAA

Date: 06/18/2013 03:50PM

Subject: Fw: 45.11 and 45.13 ?

Hey Dan,4 I received this question (see below) from one of our MIDOs. I've read the regulations and

definitions and am in the process of conducting my research and thought maybe you might have

particle experience on this matter of part marking propeller and propeller components. If you

get a chance, could you share your thoughts on this. I'd appreciate any information or

opinion you may have. Thanks very much.

Michael M. Alberts(Embedded image moved to file: pic20328.jpg) Technical & Program Management

Specialist Manufacturing Inspection Office

816

‐ 329

‐ 4189

‐‐‐‐‐ Forwarded by Michael Alberts/ACE/FAA on 06/18/2013 02:44 PM

‐‐‐‐‐

From: Kim Edwards/AGL/FAA

ACE

‐ VAN

‐ MIDO, Vandalia, OH

To: Michael Alberts/ACE/FAA@FAA,

Cc: Diane Millam/ACE/FAA@FAA, Jane Dorsey/AGL/FAA@FAA

Date: 06/18/2013 02:03 PM

Subject: 45.11 and 45.13 ?

Michael

‐

in your spare time, could you please inquire with someone in AIR

‐ 200 (a part 21/45 guru)

about the intent/interpretation of 14 CFR 45.11(c) and

45.13 (a)(1

‐ 5, specifically 4 and 5).

We have a propeller manufacture, who holds a TC and PC.

They sell complete propeller assy and spare propeller blades and propeller hubs (sold

separately

‐ as requested).

My question is: When these blades and hubs are sold as spares, must they contain all the

part marking included in 45.13?

There is no question when this PAH sells a complete propeller (hub, blade, spinner assembly),

they are in full compliance with the rule (45.11 and 45.13). The identification question has

come up several times in the past with regards to spare blades and hubs, but the ACO, thus

far, has not been able to pin down a definitive reply for the PAH or me.

Thanks in advance for your assistance.

Kim Edwards

FAA Vandalia, MIDO

Senior Aviation Safety Inspector

937

‐ 898

‐ 3991