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What is considered fabrication, and what is assembly?

G

gotyoke

Well Known Member
From old threads it appears the official definitions of fabrication and assembly are not cut in stone. Building a 14, Van's has done a lot of work that older kit builders needed to handle, but still it's a lot. It feels like deburring alone is 30 to 40% of the build, and that riveting, where I've drawn the line between fabrication and assembly, only begins after you've done 80-90% of the work. I suspect the definitions of these things aren't as critical to the FAA as showing the work (51%+) that you did, but I'm curious: Where do you draw the line?

Cutting parts with a band saw and trimming them - Fabrication
Edge deburring - Fabrication
Temporary assembly and match/final-drilling - Fabrication
Disassembly and hole deburring - Fabrication
Dimpling and countersinking - Fabrication
Scuffing, cleaning, and priming - Fabrication
Final assembly and riveting - Assembly
Bending leading edges - Assembly
 
gotyoke said:
From old threads it appears the official definitions of fabrication and assembly are not cut in stone. Building a 14, Van's has done a lot of work that older kit builders needed to handle, but still it's a lot. It feels like deburring alone is 30 to 40% of the build, and that riveting, where I've drawn the line between fabrication and assembly, only begins after you've done 80-90% of the work. I suspect the definitions of these things aren't as critical to the FAA as showing the work (51%+) that you did, but I'm curious: Where do you draw the line?

Cutting parts with a band saw and trimming them - Fabrication
Edge deburring - Fabrication
Temporary assembly and match/final-drilling - Fabrication
Disassembly and hole deburring - Fabrication
Dimpling and countersinking - Fabrication
Scuffing, cleaning, and priming - Fabrication
Final assembly and riveting - Assembly
Bending leading edges - Assembly
Click to expand...

Your inspector will have a matrix from FAA Order 8130.2J that will guide him/her to ask those questions.
 
This is a good topic! As a DAR, I am required to determine "major portion" for fabrication and assembly, usually per photos, build logs, and the "51%" checklist.
In most cases, rebuilding Type Certified parts do not count toward the "51%" rule. With the many build schools now functioning, it adds another layer to the determination. Order 8130.2j is still current, and educational assistance does not count against the major portion amateur built. Sooo, I show you how to set 1000 rivets, now you try one.... see the potential conflict? Two weeks to taxi, really? A kit manufacture I deal with has a client show up for about 10 days, go through several "build table positions" fabricating the basic parts for the project, and the kit manufacture "assembles" the aircraft, the client returns to help install the control surfaces, and receives the certificate of airworthiness, as this process HAS been evaluated by a local FSDO and MIDO, but it is not on the "NKET" evaluated kit list. In this case, the builder receives a lot of credits for fabrication, but few for assembly. At the end of the day, it is up to the FAA ASI or the DAR to make the determination. But to be the devils advocate, an aircraft constructed under the supervision of a build school is often more standardized, inspected, and perhaps safer than many of the projects I have inspected. So, please don't castigate me on this... as this is just a thought to ponder.....Perhaps the devil is in the certification standards and requirements? I can see how a T/C manufacture may be resistant to different rules for EAB aircraft using a "manufacture" for the end product, but does this really take business away from that manufacture? We have aircraft that are commercially built to Part 23 airworthiness standards, aircraft such as SLSA and ELSA built to ASTM standards, and aircraft by amateur (EAB) builders to a less definable "condition for safe operation" standard all sharing the same sky. This has been and will continue to be areas of discussion in ongoing EAA meetings, and during EAA / FAA interchanges. If you have any ideas or suggestions, perhaps have a dialogue with the EAA and FAA. I would also welcome your comments.

DAR Gary
 
OBVIOUSLY YOU HAVE NEVER EXPERIENCED THE PERSONAL INSULT OF PINCHING A FINGER BETWEEN TWO PIECES OF METAL OR SLIPPED WITH A SCREWDRIVER DURING ASSEMBLY! (I KEEP A DECNT QUANTITY OF VARIOUS BAND AIDS IN THE SHOP......)
DAR Gary
 
The following is found in FAA Order 8130.2J, which is the guidance used in certificating amateur-built aircraft. (REF: Page 15-4)

Fabrication is defined as layout, bending, countersinking, straightening, cutting, sewing, gluing/bonding, forming, shaping, trimming, drilling, deburring, machining, applying protective coatings, surface preparation and priming, riveting, welding, and heat treating or otherwise transforming an article toward or into its finished state/

That pretty well outlines it.
 
jnorris said:
The following is found in FAA Order 8130.2J, which is the guidance used in certificating amateur-built aircraft. (REF: Page 15-4)

Fabrication is defined as layout, bending, countersinking, straightening, cutting, sewing, gluing/bonding, forming, shaping, trimming, drilling, deburring, machining, applying protective coatings, surface preparation and priming, riveting, welding, and heat treating or otherwise transforming an article toward or into its finished state/

That pretty well outlines it.
Click to expand...

Well, THAT narrows it down. LOL! Is there anything that *isn't* considered "fabrication"?
 
Sounds like that's a definition of fabricating an airplane. This thread is about fabricating parts. Former being a legal term, and latter being a fun discussion.
 
RV7A Flyer said:
Well, THAT narrows it down. LOL! Is there anything that *isn't* considered "fabrication"?
Click to expand...

The definition of fabrication found in the FAA Order was developed through a partnership between FAA and industry stakeholders (primarily EAA) so as to make sure everyone was basing their "major portion" decisions off the same information. It is as broad as we could make it so as to help kit manufacturers as well as individual builders meet the major portion requirement.

What isn't fabrication? When you take a completely finished part and attach it to other completely finished parts. that's "assembly", which also counts toward the major portion requirement. The rule requires that the amateur builder does some fabrication, not just assembly. Using this definition, it's hard to avoid it! :)
 
David Z said:
Sounds like that's a definition of fabricating an airplane. This thread is about fabricating parts. Former being a legal term, and latter being a fun discussion.
Click to expand...

You don't "fabricate" an airplane. You assemble the airplane using the parts that you fabricated!
 
i think a lot of people get to wrapped around the axle about this topic. all of vans kits are on the FAA 51% list. so unless you use hired help for your build simple documentation that the kit was built by persons for educational or recreational purposes will be all you need to satisfy the requirements. since the rules and checklist are based on tasks performed, unless you hire out parts of the airframe build and assembly, it really is hard to exceed the amount allowed. most people really only hire out stuff like paint, interior, and panel wiring, those account for very few "tasks" per the list.

bob burns
RV-4 N82RB
 
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