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Hey Dick: The way the shoulder harness regulation was explained to me
by
the FSDO was a bit different. You are correct if no structural change is
required, i.e., wrap the harness around an existing structural member.
However, when you remove rivets, modify the original structure with an
addition to the structure to carry the load of the shoulder harness, and
then
install new rivets, you have just changed the original structure.
Whether you have weakened or strengthened the structure is a moot
point, but you certainly have changed the structure, which does require
FSDO
approval.
The problem really isn't the FAA, it is the litigation that occurs
after a mishap and persons not involved in the mishap try to squeeze
remuneration out of insurance companies or other non related parties. If
no
mishap occurs with the modified aircraft, then there is never a problem.
However, now that someone has been passing the word that FAA inspectors
can
become personally liable for approvals they have made, some of the
inspectors
have become very reluctant to approve alterations.
Lynn Nelsen
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