Someone was going to open this can or worms, and I just knew it would be you, Don!
This is an interesting subject that gets brought up as a reminder from time to time, and I always do an eye-roll and bite my tongue...... Actually, this forum is full of dozens (hundreds?) of "non-conformities" that all constitute deviations from Van's design drawings. I may be wrong, but my impression is that builders "solve" their problems themselves or by hashing the problem over with other builders (like on this Forum), or with someone at Van's Builder-Assist line, and arrive at a common-sense solution. I think (tell me if I'm wrong), that actually getting something in writing from Van's - allowing a deviation - is exceedingly rare. Based upon the very few revised drawing pages, problems in the plans that are reported by builders rarely result in released drawing updates. It may be, of course, that Van's keeps records of the corrections in some Master copy that may be released someday. But, current builders are left mostly in a no-man's land between the drawing and the hardware at-hand, and (mostly) make good sense decisions. Maybe, Van's knows all this stuff, and prudently let's sleeping dogs lie.
If a DAR wanted to, he could easily flunk a builder for non-conformity - I sure could! In my case, it would be easy - he would only have to look at my plans where I have pencil notations indicating "problems" along with my "solutions."
At the risk of boring the whole board (yawn), waaaay back in 'the last century' (or was it the century before last - I can't remember), in 1966 I was a young pup (really!) Liaison Engineer working on building the first 737. I worked from 4 PM - 2 AM, and had a steel desk right under the airplane's right wing in the new factory. I did that seven days a week. A Liaison Engineer at Boeing fixes all the errors in the drawings and all the screw-ups in the factory, by means of Pickups and Rejection Tags.
Everything required a Disposition. If there was an error in the drawing, for example (as above- a countersunk fastener called out for installation in a non-countersunk hole,) then I would write a Disposition (say calling for counter-sinking the hole, or changing the fastener) that would allow the shop to proceed with the airplane's assembly. This then required the Discrepancy to migrate back up the Drawing system to the "Project" engineer responsible for that drawing. He (sometimes I would) would generate an ADCN - Advance Drawing Change Notice. This would document the correction to the drawing, and as a released piece of paper, get stapled to the drawing. All drawings had them - when there was a moderately thick bunch stapled to a drawing, the engineer would DCN the drawing - Drawing Change Notice - and the drawing would be re-released with all the ADCN's incorporated on the face of the drawing, which now had a Revision Letter - i.e. Rev "A".
The Shop, QC, and Drawing Release (where the shop would get their drawings) all had to review the build against the drawing INCLUDING all attached ADCN's - if any. All drawings used on the shop floor had a date sticker afixed to document the drawing's currency.
The OTHER thing I did was Disposition the Shop screw-ups that resulted in a non-conformity with the drawing requirements. These ranged from the common (over-sized or mis-located holes, wire bundles severed by accidental drill-throughs) to the major (airplane fell off jacks and punched a hole in the fuselage or wing) to the gargantuan (biggest I was ever involved in - remove both wings off a 747 - took two weeks.) An R/T (Rejection Tag) was created, and engineering (usually me) would disposition it with a repair or MRB (Materials Review Board.) It would authorize the shop to oversize the hole, drill a new hole, substitute a different fastener, manufacture a repair splice or doubler, or some such. (Struc & Func in Boeing jargon was the easiest - the as-built is Structurally and Functionally satisfactory.)
Everything had to be documented. Everything had a pedigree. That is the nature of operating under a Production Certificate. Every airplane has a pedigree involving three FAA Certificates - under Title 14. A TYPE Certificate, that says the airplane has been demonstrated to comply with the applicable Airworthiness requirements (in Boeing's case - FAR 25 - Transport Category airplanes). A Production Certificate, that says Boeing has demonstrated to the FAA's satisfaction that it has the tools, organization, and systems to produce the airplane. And an Airworthiness Certificate, that says that that individual airplane has been manufactured in conformity with the Type design using the approved Production system.
In the case of an E-LSA, in a sense, WE are the holders of the Production Certificate. But - unlike an E-AB airplane - we are NOT the "manufacturer." That's why Van's gets their name on the Data Plate - and not us.
Van's has certified (actually self-certified, with some FAA oversight) that the design meets the design requirements (in this case the ASTM LSA Committee F-37 requirements.) When we present to the FAA (or their designee - a DAR) an application for an Airworthiness Certificate, we are legally declaring that we have constructed the airplane in conformity with the plans. 100% conformity.
But, of course, we don't. Don't conform 100%, that is. I can guarantee it. Since Van's obviously does not run a Production set-up like the Boeing system I described above (or these would be $10M LSA's!), then WE are left to bridge the gaps between the drawings, with their inevitable discrepancies, and the deviations from the drawings (mis-drilled and butchered holes, etc.) I'd say we do the producing and gap-bridging in a pretty intelligent and safe way. An RV-12, like a 737, has a lot of foregiveness built into it, to accommodate deviations.
How's that for a long-winded reply, Don? And I was just getting started! If DARs wanted to be hard-nosed on this subject, there wouldn't be a single E-LSA out there flying.
Bob Bogash
N737G
