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PVC Conduit in Certificated Aircraft

 
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jluckey(at)pacbell.net
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PostPosted: Sat Sep 30, 2023 8:58 am    Post subject: PVC Conduit in Certificated Aircraft Reply with quote

Does anyone know if PVC can be used for a wiring conduit in Certificated aircraft?
It is my understanding that the reason we use Tefzel wire in aircraft is to minimize the toxic gasses given-off from burning insulation. The more common (and cheaper) automotive-type wire is a no-no because its insulation is PVC-based and its fumes are very toxic.
So I was surprised to hear an A&P suggest a PVC conduit in a Certified airframe.

TIA


-Jeff


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PostPosted: Sat Sep 30, 2023 9:08 am    Post subject: PVC Conduit in Certificated Aircraft Reply with quote

I'd say the answer to your question depends on the IA who is going to be signing off the Annual, but may I propose that if you're going to shop in the plumbing department, I like Pex better than PVC.

On Sat, Sep 30, 2023 at 1:03 PM Jeff Luckey <jluckey(at)pacbell.net (jluckey(at)pacbell.net)> wrote:

Quote:
Does anyone know if PVC can be used for a wiring conduit in Certificated aircraft?
It is my understanding that the reason we use Tefzel wire in aircraft is to minimize the toxic gasses given-off from burning insulation.  The more common (and cheaper) automotive-type wire is a no-no because its insulation is PVC-based and its fumes are very toxic.
So I was surprised to hear an A&P suggest a PVC conduit in a Certified airframe. 

TIA


-Jeff



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PostPosted: Sat Sep 30, 2023 1:09 pm    Post subject: PVC Conduit in Certificated Aircraft Reply with quote

On 9/30/2023 11:57 AM, Jeff Luckey wrote:

Quote:
Does anyone know if PVC can be used for a wiring conduit in Certificated aircraft?


It is my understanding that the reason we use Tefzel wire in aircraft is to minimize the toxic gasses given-off from burning insulation.  The more common (and cheaper) automotive-type wire is a no-no because its insulation is PVC-based and its fumes are very toxic.


So I was surprised to hear an A&P suggest a PVC conduit in a Certified airframe. 





TIA




-Jeff




PVC has a much lower temperature rating than Tefzel. IIRC, it's also a bit more vulnerable to moisture migration through it to the copper. I believe that all the insulations, including Tefzel, emit nasty gases when they burn.
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PostPosted: Sat Sep 30, 2023 5:32 pm    Post subject: PVC Conduit in Certificated Aircraft Reply with quote

At 11:57 AM 9/30/2023, you wrote:
Quote:
Does anyone know if PVC can be used for a wiring conduit in Certificated aircraft?

A TC aircraft left the factory configured
per approved drawings. Substituting any
part not on that drawing requires an
approval via one-time field approval (Form 337)
or an STC.

I can't imagine any licensed technician
attempting to 'sell' such a deviation
to the local FSDO.

What kind of 'mod' are we talking about?
If the wires were not part of the original
TC then one is advised to rely on
legacy practices when submitting a Form 337.
To be sure, PVC plumbing would not fall in that category.




Bob . . .

////
(o o)
===========o00o=(_)=o00o=========
< Go ahead, make my day . . . >
< show me where I'm wrong. >
=================================

In the interest of creative evolution
of the-best-we-know-how-to-do based
on physics and good practice.


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jluckey(at)pacbell.net
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PostPosted: Sun Oct 01, 2023 8:37 am    Post subject: PVC Conduit in Certificated Aircraft Reply with quote

Bob and others,
I want to summarize ...
Bob - I understand, agree with, and appreciate your cogent and concise explanation of the rules. Right on the money, as usual.

However, as far as anyone who responded knows, there is no FAR or other regulation that would prohibit the use of a PVC conduit in a Certificated airframe.

If an A&P/IA completes a 337 and gets it approved by their local FSDO, a piece of PVC could be used in a Certificated airplane. It is really up to the FSDO and the relationship that A&P has with them. I understand that the approval process might be challenging, but there is no reg that prohibits the use of PVC as a conduit.
Over the past few years, I have come to discover that what is dis-allowed by one FSDO might be approved by another. I was surprised to find out just how capricious and inconsistent the application of the rules is from district to district across the country.


For the record, I am not considering using PVC for a conduit in a Certificated or Experimental aircraft. Based on my understanding of the toxic properties of PVC, I would not consider it. I had overheard a conversation with an IA who suggested using a piece of PVC in the tail of an Experimental and he went on to say that "he had done it in a Cessna". And I thought that was odd and I also thought: "I wouldn't let this guy work on MY airplane".

-Jeff


On Saturday, September 30, 2023 at 06:37:37 PM PDT, Robert L. Nuckolls, III <nuckolls.bob(at)aeroelectric.com> wrote:




At 11:57 AM 9/30/2023, you wrote:
Quote:
Does anyone know if PVC can be used for a wiring conduit in Certificated aircraft?

A TC aircraft left the factory configured
per approved drawings. Substituting any
part not on that drawing requires an
approval via one-time field approval (Form 337)
or an STC.

I can't imagine any licensed technician
attempting to 'sell' such a deviation
to the local FSDO.

What kind of 'mod' are we talking about?
If the wires were not part of the original
TC then one is advised to rely on
legacy practices when submitting a Form 337.
To be sure, PVC plumbing would not fall in that category.




Bob . . .

////
(o o)
===========o00o=(_)=o00o=========
< Go ahead, make my day . . . >
< show me where I'm wrong. >
=================================

In the interest of creative evolution
of the-best-we-know-how-to-do based
on physics and good practice.


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alec(at)alecmyers.com
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PostPosted: Mon Oct 02, 2023 6:26 pm    Post subject: PVC Conduit in Certificated Aircraft Reply with quote

I have a small certified aircraft with PVC tubes. I just read the 3000 hour inspection checklist that requires them to be inspected. There’s a cable conduit under the cabin floor that I’m pretty sure is PVC, although I’m not sure if that’s one that needs inspecting. Some of the control surfaces have PVC tubes in.

Searching through the maintenance manual, I see that the entire structure of the aircraft is described variously as "GRP skins [AND] a rigid PVC foam core”, and there’s a lot of rigid PVC foam too.
On Oct 1, 2023, at 12:37, Jeff Luckey <jluckey(at)pacbell.net> wrote:

Bob and others,

I want to summarize ...

Bob - I understand, agree with, and appreciate your cogent and concise explanation of the rules. Right on the money, as usual.

However, as far as anyone who responded knows, there is no FAR or other regulation that would prohibit the use of a PVC conduit in a Certificated airframe.

If an A&P/IA completes a 337 and gets it approved by their local FSDO, a piece of PVC could be used in a Certificated airplane. It is really up to the FSDO and the relationship that A&P has with them. I understand that the approval process might be challenging, but there is no reg that prohibits the use of PVC as a conduit.

Over the past few years, I have come to discover that what is dis-allowed by one FSDO might be approved by another. I was surprised to find out just how capricious and inconsistent the application of the rules is from district to district across the country.
For the record, I am not considering using PVC for a conduit in a Certificated or Experimental aircraft. Based on my understanding of the toxic properties of PVC, I would not consider it. I had overheard a conversation with an IA who suggested using a piece of PVC in the tail of an Experimental and he went on to say that "he had done it in a Cessna". And I thought that was odd and I also thought: "I wouldn't let this guy work on MY airplane".

-Jeff

On Saturday, September 30, 2023 at 06:37:37 PM PDT, Robert L. Nuckolls, III <nuckolls.bob(at)aeroelectric.com> wrote:
At 11:57 AM 9/30/2023, you wrote:
Quote:
Does anyone know if PVC can be used for a wiring conduit in Certificated aircraft?

A TC aircraft left the factory configured
per approved drawings. Substituting any
part not on that drawing requires an
approval via one-time field approval (Form 337)
or an STC.

I can't imagine any licensed technician
attempting to 'sell' such a deviation
to the local FSDO.

What kind of 'mod' are we talking about?
If the wires were not part of the original
TC then one is advised to rely on
legacy practices when submitting a Form 337.
To be sure, PVC plumbing would not fall in that category.

Bob . . .

////
(o o)
===========o00o=(_)=o00o=========
< Go ahead, make my day . . . >
< show me where I'm wrong. >
=================================

In the interest of creative evolution
of the-best-we-know-how-to-do based
on physics and good practice.


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alec(at)alecmyers.com
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PostPosted: Mon Oct 02, 2023 6:28 pm    Post subject: PVC Conduit in Certificated Aircraft Reply with quote

Sorry - that should say “a lot of rigid PVC honeycomb too”.
On Oct 2, 2023, at 22:25, Alec Myers <alec(at)alecmyers.com> wrote:



I have a small certified aircraft with PVC tubes. I just read the 3000 hour inspection checklist that requires them to be inspected. There’s a cable conduit under the cabin floor that I’m pretty sure is PVC, although I’m not sure if that’s one that needs inspecting. Some of the control surfaces have PVC tubes in.

Searching through the maintenance manual, I see that the entire structure of the aircraft is described variously as "GRP skins [AND] a rigid PVC foam core”, and there’s a lot of rigid PVC foam too.
On Oct 1, 2023, at 12:37, Jeff Luckey <jluckey(at)pacbell.net> wrote:

Bob and others,

I want to summarize ...

Bob - I understand, agree with, and appreciate your cogent and concise explanation of the rules. Right on the money, as usual.

However, as far as anyone who responded knows, there is no FAR or other regulation that would prohibit the use of a PVC conduit in a Certificated airframe.

If an A&P/IA completes a 337 and gets it approved by their local FSDO, a piece of PVC could be used in a Certificated airplane. It is really up to the FSDO and the relationship that A&P has with them. I understand that the approval process might be challenging, but there is no reg that prohibits the use of PVC as a conduit.

Over the past few years, I have come to discover that what is dis-allowed by one FSDO might be approved by another. I was surprised to find out just how capricious and inconsistent the application of the rules is from district to district across the country.
For the record, I am not considering using PVC for a conduit in a Certificated or Experimental aircraft. Based on my understanding of the toxic properties of PVC, I would not consider it. I had overheard a conversation with an IA who suggested using a piece of PVC in the tail of an Experimental and he went on to say that "he had done it in a Cessna". And I thought that was odd and I also thought: "I wouldn't let this guy work on MY airplane".

-Jeff

On Saturday, September 30, 2023 at 06:37:37 PM PDT, Robert L. Nuckolls, III <nuckolls.bob(at)aeroelectric.com> wrote:
At 11:57 AM 9/30/2023, you wrote:
Quote:
Does anyone know if PVC can be used for a wiring conduit in Certificated aircraft?

A TC aircraft left the factory configured
per approved drawings. Substituting any
part not on that drawing requires an
approval via one-time field approval (Form 337)
or an STC.

I can't imagine any licensed technician
attempting to 'sell' such a deviation
to the local FSDO.

What kind of 'mod' are we talking about?
If the wires were not part of the original
TC then one is advised to rely on
legacy practices when submitting a Form 337.
To be sure, PVC plumbing would not fall in that category.

Bob . . .

////
(o o)
===========o00o=(_)=o00o=========
< Go ahead, make my day . . . >
< show me where I'm wrong. >
=================================

In the interest of creative evolution
of the-best-we-know-how-to-do based
on physics and good practice.


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nuckolls.bob(at)aeroelect
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PostPosted: Mon Oct 02, 2023 9:34 pm    Post subject: PVC Conduit in Certificated Aircraft Reply with quote

Quote:
Bob and others,

I want to summarize ...

Bob - I understand, agree with, and appreciate your cogent and concise explanation of the rules. Right on the money, as usual.

However, as far as anyone who responded knows, there is no FAR or other regulation that would prohibit the use of a PVC conduit in a Certificated airframe.

Didn't say there was . . . only that deviations
from the airplane's type certification is
to be discouraged without overriding approval
lest lightning from on high come down and smite thee.

Now, if some manufacture has achieved certification
with ANY particular material, then that TC
becomes "approved data" but only for that particular
application. PVC approved in one place doesn't say
okay to use anywhere.

Quote:
If an A&P/IA completes a 337 and gets it approved by their
local FSDO, a piece of PVC could be used in a Certificated
airplane. It is really up to the FSDO and the relationship
that A&P has with them. I understand that the approval
process might be challenging, but there is no reg that
prohibits the use of PVC as a conduit.

I recall rules that speak to flammability of any
material used on the airframe. The topic got really
hot after Swissair 111 suffered some soft fault ignition
of insulation in the overhead. Something about
flaming drips, self extinguishing times, fumes, proximity
to critical systems, etc.

Yup, here 'tis:

https://www.faa.gov/documentlibrary/media/advisory_circular/ac%2023-2a.pdf



Quote:
Over the past few years, I have come to discover that what is
dis-allowed by one FSDO might be approved by another. I
was surprised to find out just how capricious and inconsistent
the application of the rules is from district to district across the country.

You got that right! In years past seekers of royal
permission would FSDO Shop . . . Back then Ft. Worth
and Seattle were popular shops. Last I heard,
the practice was halted with a directive, "Tho
shalt seek blessings only from thy local FSDO."

I think the Teterboro office got miffed 'cause
nobody ever asked them for permission/guidance . . .
wonder why.

Quote:
I had overheard a conversation with an IA who suggested using a
piece of PVC in the tail of an Experimental and he went on to
say that "he had done it in a Cessna". And I thought
that was odd and I also thought: "I wouldn't let this guy work on MY airplane".

I wonder if he jumped the hoops for paperwork.
There's nothing inherently hazardous for incorporation
of PVC . . . depends on application and exacerbation
of risk. But the absolutely minimal risk solutions
call for consideration of better materials
first. I suspect PVC conduit in the tailcone is not
a significant elevation of risk.


Bob . . .

////
(o o)
===========o00o=(_)=o00o=========
< Go ahead, make my day . . . >
< show me where I'm wrong. >
=================================

In the interest of creative evolution
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on physics and good practice.


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Joined: 16 Apr 2008
Posts: 57
Location: Winston-Salem, NC

PostPosted: Tue Oct 03, 2023 12:42 am    Post subject: PVC Conduit in Certificated Aircraft Reply with quote

What is the aircraft?

Thanks,
Bill

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PostPosted: Tue Oct 03, 2023 2:35 am    Post subject: PVC Conduit in Certificated Aircraft Reply with quote

Bob,

That link is to a document describing flammability tests. It doesn’t have any advice as to where flammable (or other) materials can be used.
There is in it a list of regulatory references (on page 7) that apply to individual parts of the aircraft, but they are very very specific. It may have been extended since 2007 when that AC was issued.

Looking through the FAR sections listed there that appear to apply to cables and accessories, the only relevant stipulation is this one:

23.1365(b) Any equipment that is associated with any electrical cable installation and that would overheat in the event of circuit overload or fault must be flame resistant. That equipment and the electrical cables must not emit dangerous quantities of toxic fumes.
If a circuit is protected, does it still count as something that would overheat in the event of overload or fault?




On Oct 3, 2023, at 01:34, Robert L. Nuckolls, III <nuckolls.bob(at)aeroelectric.com> wrote:

Quote:
Bob and others,

I want to summarize ...

Bob - I understand, agree with, and appreciate your cogent and concise explanation of the rules. Right on the money, as usual.

However, as far as anyone who responded knows, there is no FAR or other regulation that would prohibit the use of a PVC conduit in a Certificated airframe.

Didn't say there was . . . only that deviations
from the airplane's type certification is
to be discouraged without overriding approval
lest lightning from on high come down and smite thee.

Now, if some manufacture has achieved certification
with ANY particular material, then that TC
becomes "approved data" but only for that particular
application. PVC approved in one place doesn't say
okay to use anywhere.

Quote:
If an A&P/IA completes a 337 and gets it approved by their
local FSDO, a piece of PVC could be used in a Certificated
airplane. It is really up to the FSDO and the relationship
that A&P has with them. I understand that the approval
process might be challenging, but there is no reg that
prohibits the use of PVC as a conduit.

I recall rules that speak to flammability of any
material used on the airframe. The topic got really
hot after Swissair 111 suffered some soft fault ignition
of insulation in the overhead. Something about
flaming drips, self extinguishing times, fumes, proximity
to critical systems, etc.

Yup, here 'tis:

https://www.faa.gov/documentlibrary/media/advisory_circular/ac%2023-2a.pdf


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alec(at)alecmyers.com
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PostPosted: Tue Oct 03, 2023 2:39 am    Post subject: PVC Conduit in Certificated Aircraft Reply with quote

It’s a Grob G115

On Oct 3, 2023, at 04:41, Bill Settle <billsettle(at)bellsouth.net> wrote:



What is the aircraft?

Thanks,
Bill

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PostPosted: Tue Oct 03, 2023 6:04 pm    Post subject: PVC Conduit in Certificated Aircraft Reply with quote

Quote:

Looking through the FAR sections listed there that appear to apply to cables and accessories, the only relevant stipulation is this one:

23.1365(b) Any equipment that is associated with any electrical cable installation and that would overheat in the event of circuit overload or fault must be flame resistant. That equipment and the electrical cables must not emit dangerous quantities of toxic fumes.


If a circuit is protected, does it still count as something that would overheat in the event of overload or fault?

One would think. I've heard opinions from more than
one 'knowing' source. One agreed with that assertion.
The other did not . . . everything on the
ship's TC was originally assessed for fire risks.
Anything new is subject to the same assessment.


Bob . . .

////
(o o)
===========o00o=(_)=o00o=========
< Go ahead, make my day . . . >
< show me where I'm wrong. >
=================================

In the interest of creative evolution
of the-best-we-know-how-to-do based
on physics and good practice.


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