Epoxy glue approval

[Baldeagle]

From Addison Pemberton, let's all write-

To all
This is our opportunity to have 43.13-1B up dated which will allow a
change to the wording in chapter one (wood repair and construction) to
include new verbiage which could approve Epoxy adhesives like West Systems
for construction and repair. As we all know currently Epoxy is encouraged
in the current version of 43.13-1B but requires a Mil Spec for the material
to be used, No Epoxy products including West provide this current
requirement.

Please write to the FAA address below and encourage an up date to 43.13-1B,
this will give Mike Grimes (our antique ally and contributing author of
chapter one) the chance to fix the wording in chapter one to include Epoxy
adhesives for us.

U.S. Dept. of Transportation
Federal Aviation Administration
AFS-300
800 Independence Ave. SW
Washington, D.C. 20591

Attn: Charlie Fellows, if you wish


Back ground to date I now have 12ea copies of 337 field approvals for West
systems Epoxy adhesive for aircraft repair on Stearman's, Waco's,
Staggerwings, Howards , Boeing 40 and other old airplanes. West is a great
product with excelled strength and work ability. The only approved adhesive
currently in 43.13-1B is Resorcinol and in California it is illegal to buy
it now !!!! Charlie Fellows did point out an interesting fact. After the
last revision to AC43.13 no feedback was recieved from anyone in industry.
Hmmmm.......... AKA no feed back no change!!!!




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[JDK]

I understand that the West System is being used at the RAAF Museum for the static restoration of the Mosquito PR.XVI, and also on Project 2014 building a replica Bristol Military Biplane (or Boxkite) to fly.

www.boxkite2014.org

Dunno if this data adds any weight to US legislation process, Andrew. Your call?

[RandolphB]

Is there a time frame involved for this? Is there some sort of yearly review or update time for the publication...as mine, which I bought about a year ago for school, is dated as the last edition being "September 27, 2001".

Thanks!

[Wheels up]

Epoxy glue approval

From Addison Pemberton, let's all write-

To all
This is our opportunity to have 43.13-1B up dated which will allow a
change to the wording in chapter one (wood repair and construction) to
include new verbiage which could approve Epoxy adhesives like West Systems
for construction and repair. As we all know currently Epoxy is encouraged
in the current version of 43.13-1B but requires a Mil Spec for the material
to be used, No Epoxy products including West provide this current
requirement.

Please write to the FAA address below and encourage an up date to 43.13-1B,
this will give Mike Grimes (our antique ally and contributing author of
chapter one) the chance to fix the wording in chapter one to include Epoxy
adhesives for us.

U.S. Dept. of Transportation
Federal Aviation Administration
AFS-300
800 Independence Ave. SW
Washington, D.C. 20591

Attn: Charlie Fellows, if you wish


Back ground to date I now have 12ea copies of 337 field approvals for West
systems Epoxy adhesive for aircraft repair on Stearman's, Waco's,
Staggerwings, Howards , Boeing 40 and other old airplanes. West is a great
product with excelled strength and work ability. The only approved adhesive
currently in 43.13-1B is Resorcinol and in California it is illegal to buy
it now !!!! Charlie Fellows did point out an interesting fact. After the
last revision to AC43.13 no feedback was recieved from anyone in industry.
Hmmmm.......... AKA no feed back no change!!!!

Easy there fellows...easy. What big important word here is being misused and misapplied??
What is the title on that big book known as AC43.13?
If you want to have your Administrator actually listen to you, speak their language.

[JDK]

Easy there fellows...easy. What big important word here is being misused and misapplied??
What is the title on that big book known as AC43.13?
If you want to have your Administrator actually listen to you, speak their language.

For those of us not looped in, care to elaborate?

Some of us are interested while still unqualified, undocumented and offshore. amazing really.

[Baldeagle]

I understand that the West System is being used at the RAAF Museum for the static restoration of the Mosquito PR.XVI, and also on Project 2014 building a replica Bristol Military Biplane (or Boxkite) to fly.

www.boxkite2014.org

Dunno if this data adds any weight to US legislation process, Andrew. Your call?

Do you know of anybody to ask about Aussie CAA opinion of West System epoxy?




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[JDK]

The Boxkite project is under an exemption scheme, and I don't think the West System is acceptable for standard certification in Australia.

I'll find out what the full story / correct details is /are when I see the guys next - as you may gather I handle PR and the website for the Boxkite project, but wisely I'm not allowed near anything technical!

The Australian civil aviation body is CASA. http://www.casa.gov.au/ You could contact them direct.

Two other thoughts. A contact of mine in a small population Northern country is restoring a British wooden aircraft, and he was exploring the glue options. I'll point him at this thread. Another is to talk to Ryan in NZ - dragonflydh90 here, IIRC, and he deals with a lot of wooden aircraft there, he may have some useful insights.

[bdk]

From Addison Pemberton, let's all write-

As we all know currently Epoxy is encouraged in the current version of 43.13-1B but requires a Mil Spec for the material to be used, No Epoxy products including West provide this current requirement.

Whatchu talkin about Willis?

Here are just some Hysol paste adhesive products- aerospace OEM quality that have MIL-SPEC numbers and are currently used by F-18, C-17, etc. There are other manufacturers as well, Hysol just off the top of my head from home.

http://www.henkelna.com/cps/rde/xchg/henkel_us/hs.xsl/product-search-1554.htm?iname=Hysol%C2%AE+EA+934NA&countryCode=us&BU=industrial&parentredDotUID=productfinder&redDotUID=0000000IS8

http://www.henkelna.com/cps/rde/xchg/henkel_us/hs.xsl/product-search-1554.htm?iname=Hysol%C2%AE+EA+9394&countryCode=us&BU=industrial&parentredDotUID=productfinder&redDotUID=0000000ISD

National Stock Number
8040-00-016-8662,,"HYSOL EA 934NA, QUART KIT"
8040-00-152-0017,,"HYSOL EA 934NA, 2.5OZ SEMKIT"
8040-00-152-0023,,"HYSOL EA 934NA, 6 OZ SEMKIT"
8040-00-995-7017,,"HYSOL EA 934NA, GALLON KIT"
8040-01-102-2098,,"HYSOL EA934NA, QUART KIT"
8040-01-169-5304,,"HYSOL EA 9394, 50 GRAM KIT"
8040-01-288-5856,,"HYSOL EA 9394, QUART KIT"
8040-01-297-2378,,"HYSOL EA 9394,QT KIT,MMM-A-132A,T1,C3,FP"
8040-01-347-7599,,"HYSOL EA 934NA, 25 GRAM KIT"
8040-01-347-7600,,"HYSOL EA 934NA, 50 GRAM KIT"
8040-01-450-6910,,"HYSOL EA 934NA, PINT KIT"
8040-01-490-2329,,EA9394-50 ML REPAIR KIT
8040-01-490-5417,,EA9394-50ML REPLACEMENT KIT

I can guarantee you that WIXer "Brad" can walk into any USAF airbase backshop and find these products on the shelf. Look online and you can get pricing from a number of suppliers.

[Baldeagle]

From Addison Pemberton, let's all write-

As we all know currently Epoxy is encouraged in the current version of 43.13-1B but requires a Mil Spec for the material to be used, No Epoxy products including West provide this current requirement.

Whatchu talkin about Willis?

.

I think those mil specs are all for bonding metal or composite, not for wood. I believe West System meets a mil spec for bonding metal, but the FAA says that won't fly for wood.




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[bdk]

The reason all test coupons in these specs are aluminum is because the purpose is to test the adhesive, not the substrate (wood in this case). If the wood fails first, you have no idea how strong the adhesive is. This is standard throughout the industry for determining adhesive strength and for determining the quality from batch to batch.

Metals themselves have very well defined and generally accepted properties (MIL-HDBK-5, although even that is obsolete now). For composites (which is as close to wood as we're likely to get), each OEM (Northrop, Boeing, AIRBUS, etc.) does their own testing and develops their own proprietary material allowables. This is because any bonding or laminating operation is very sensitive to the exact process used (environmental conditions, bonding pressures, combinations of materials used, etc.).

My guess that the reason the FAA is going the field approval route is that the restorer using epoxy is acting as the pseudo-OEM. I'm (still) guessing that part of the field approval process was a data submission of test results showing that the replacement adhesive materials and processes used are at least as strong as the OEM materials and processes.

The problem is that unless the adhesive manufacturer themselves get their product certified to meet the old (casein/resorcinol) wood bonding MIL-SPEC, which is not likely due to liability concerns, there is no control over the strength of the adhesive. These companies change formulations occasionally (for product cost and environmental control reasons) which does affect the adhesive properties. What affect these chemistry changes might have has to be tested and documented by the manufacturer. For the number of Boeing 40s, Wacos, staggerwings (or whatever) being restored, the return on investment for the adhesive manufacturer doesn't exist. Especially if they sell the product anyhow when people get field approvals! No real liability gets assigned to them...

Perhaps Mr. Pemberton can get an STC for a West Systems product for use in bonding wood? That might solve the problem. I suggest he buy a LOT of liability insurance though.

This is a tough problem and I hope someone can come up with an easier answer!

[Wheels up]

For those of us not looped in, care to elaborate?

Some of us are interested while still unqualified, undocumented and offshore. amazing really.

Hello James,
Amazing indeed that you might find interest in U.S. Government CFR FAA dribble!

The FAA (Administrator) approves certain data. Documents that are approved include type certificates, manufacturer's manuals of sorts, supplemental type certs, airworthiness directives, etc.
Advisory Circulars are NOT approved data....they are, just what they say: Advisory.
The subject document of this topic is AC43.13-1B. See the AC prefix? That means Advisory Circulars. What is the title of this document?

Acceptable Methods, Techniques, and Practices - Aircraft Inspection and Repair (emphasis mine)
This means all data contained therein is not necessarily approved....merely acceptable or of advisory nature. A further look at the signature page reveals the purpose of this document:

1. PURPOSE. This advisory circular (AC) contains methods, techniques, and practices acceptable to the
Administrator for the inspection and repair of nonpressurized areas of civil aircraft, only when there are no
manufacturer repair or maintenance instructions. This data generally pertains to minor repairs. The repairs
identified in this AC may only be used as a basis for FAA approval for major repairs. The repair data may
also be used as approved data, and the AC chapter, page, and paragraph listed in block 8 of FAA form 337
when:
a. the user has determined that it is appropriate to the product being repaired;
b. it is directly applicable to the repair being made; and
c. it is not contrary to manufacturer’s data.

Let's read that again..... data may also be used as approved data
I read that as meaning it may be used as a substitute for, in its stead, in lieu of, approved data for the 337 form if the user deems it appropriate. It means the Administrator will accept data referenced in AC43.13-1B instead of approved data for block 8. I am not a legal minded person and of no authority, but that seems clear to me. The data conatined in AC43.13-1B is only acceptable. The data never does become "approved" unless a block 3 signoff by the Administrator or representative thereof has been accomplished, the dreaded "field approval". With a field approval, the data has now become approved but is restricted to the specific aircraft airframe for which the 337 has been filed...one aircraft only.
What does that matter? I don't know....let a wing fall off and kill 3 people and I suppose the ensuing litigation will cypher it. I would suspect the Administrator is not going to lose. Who's left? How about the Mechanic and I/A? Uh oh.

Folks don't get me wrong. I am not here to admonish anyone, rather let's be lucid and accurate.
Having epoxy adhesive for wood structure widely accepted in AC43.13-1B is about as close as we are going to get to having a modern alternative to resorcinol or whatever glue the manufacturer originally used. I would love to see it included in that document and I can hardly imagine anyone being opposed.
But as I mentioned earlier, I feel the Administrator would be more receptive to input if we displayed an understanding of the regulations and actually know how to apply them safely. I suppose it is the "thought that counts" in this endeavor...."write them and screw the accuracy. They'll get the message." That is perhaps true.
But how much more effective would these pleas be if they displayed a sound understanding of 14CFR?

[airnutz]

I understand that the West System is being used at the RAAF Museum for the static restoration of the Mosquito PR.XVI, and also on Project 2014 building a replica Bristol Military Biplane (or Boxkite) to fly.

www.boxkite2014.org

Dunno if this data adds any weight to US legislation process, Andrew. Your call?

If I remember(alarm bells )...correctly, Glyn Powell chose the West System epoxy for his Mosquito
replications.

[AvroAvian]

Here's CASA's (Civil Aviation Safety Authority) view on wood glue:

7. ADHESIVES
In line with other materials and processes, adhesives for timber and plywood are not
approved by CASA. The onus is on the end user i.e. the manufacturer or repairer of the
aircraft or product to be satisfied that the adhesive is suitable in the particular application.
a) Be satisfied that the adhesive is suitable for the application, i.e. waterproof,
non-elastic, not corrosive to the wood fibres, not subject to fungal attack etc;
b) Is recommended by the adhesive manufacturer as suitable for wood gluing,
and preferably (but not usually available) as recommended by the adhesive
manufacturer as suitable for aircraft wood gluing;
c) Is manufactured in accordance with a suitable recognised standard;
d) Is used in accordance with the adhesive manufacturer’s instructions as to
shelf life, mixing instructions, spreading requirements, pot life, clamping
requirements, temperature and humidity limitations, gap filling properties etc;
e) Be satisfied with the documentation received with the adhesive;
f) Do whatever goods inwards inspection and testing the user needs to be
satisfied.
The following adhesives are commonly used for aircraft wood gluing:
a) Resorcinol Formaldehyde Synthetic Resin Glue
b) Urea Formaldehyde Synthetic Resin Glue, and
c) Epoxy resin Araldite AW 134 and Hardener HY 994.
Any worthwhile adhesive could be used, especially if supported by history of aeronautical
use. New adhesives are still being developed.
The use of a different adhesive to that specified in the approved design data of a
certificated aircraft requires modification approval.

Found here:
www.casa.gov.au/airworth/AWB/02/011.pdf

Therefore, if the user can prove that the glue selected is suitable, it can be used. Note, though, the certificated aircraft requirements. Could be a trap for unwary players.

[Baldeagle]

Below from Mike Grimes, update on what to write to the FAA


Many of us have collaborated on the rewrite of
AC43.13-1B about 15 years ago. When the work was edited in
Washington, D.C. by the head FAA maintenance guy a lot of the good
information got tossed out and some bad info inserted.

I am well aware of the West System/epoxy/ adhesive issue. I am also
well aware that this is just a SMALL part of the problems in the current AC.

I have been trying to stress to Addison and everybody else that what
we REALLY NEED to do is draw awareness to the FAA folks in
Washington, D.C. that AC43.13-1B needs to be overhauled. If we are
successful in this THEN they will allocate funds for the
revision. If nobody complains about the need to revise AC43.13-1B
then it probably won't get revised. Simple.

Once we get the door opened then DIck and I can work with the FAA and
correct the AC, including the adhesives issue.

Again, we need letters to the FAA (AFS-300) indicating that we
vintage aircraft owner/maintainers need AC43.13-1B updated as we
depend upon it for ACCURATE data in order that we can maintain our
vintage aircraft in an airworthy condition.

DON'T MENTION THE EPOXY ISSUE, IT'S NOT WHAT WE WANT TO ACCOMPLISH AT
THIS MOMENT. I'll take care of that at the proper time. Trust me.


For right now what needs to be done is for the aviation community to let the
FAA know that AC43.13-1B is critical as a data source for the Maintenance
and repair of vintage and amateur built aircraft. This is what Charlie
Fellows is fighting for right now, but he's bucking a large bureaucracy
that's attempting to allocate funds to varied other projects. As Charlie
told me, he had to fight uphill to update AC43.13-1B recently and when it
was done there was NO feedback from the aviation community for which it was
updated. Result: Lack of interest by the FAA chiefs in updating AC43.13-1B.
If they decide not to update it there is no way that I, or anybody else, can
help in getting it fixed.

Solution: Flood the FAA with letters from the aviation community Indicating
our need for AC43.13-1B to be updated so that we can have Up to date data
for the maintenance and repair of vintage and amateur Built aircraft. This
is a safety of flight issue!


U.S. Dept. of Transportation
Federal Aviation Administration
AFS-300
800 Independence Ave. SW
Washington, D.C. 20591

Attn: Charlie Fellows, if you wish.

The plan to fix the adhesives mess is already in place, but I need a Format
to put it on. An revised AC43.13-1B is the place to start.




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[JDK]

Hi Andrew,
Looks like that makes it a US-based poster question, really.

Is there anything overseas members can do (or ~um~ journalists for instance)?

Cheers
James