Can an Air Carrier Remove an Article from a Flight Simulator and Install it on an Aircraft?

I received many interesting questions during the ASA/AFRA Conference last week.  Today I wanted to address the question: “Can an air carrier remove a part from a flight simulator and install it an aircraft?”

Simulators are approved under 14 C.F.R. Part 60.  This sort of approval is a device approval for simulator use.  It is NOT the same as a Part 21 approval (which is the approval process for products and articles)   Thus, simulator parts are not inherently “approved parts” for purposes of installation in aircraft, because they are not naturally subject to the design and production approvals associated with “approved parts.”

We have to recognize that flight simulators can be purpose-built (so they are not subject to the Part 21 rules at all), but sometimes flight simulators are built from existing fuselages.  When the parts are purpose-built for the simulator, then there is typically no need to build them according to type design nor is there a need to produce them under a production approval; consequently, there is no evidence that they meet type design (and thus no evidence of airworthiness). When a simulator is built from an existing fuselage, though, then articles taken from the existing fuselage may, in fact, be approved parts.

Knowing that an article meets approved design parameters before installing it on a type certificated aircraft is a legal requirement under the installation rules of Part 43.

Approval sets the baseline for airworthiness, because an approved part is presumed to be airworthy at the time of release from the quality assurance system (and remains airworthy, subject to damage or degradation).  If you think you might want to take an approved part off of a simulator for use on a type certificated aircraft, then it is also important to ensure that any such parts that might be removed from a simulator remain airworthy.  Such parts may have been subject to damage or degradation that does not matter when used in a simulator, but would create unwanted risk in an aircraft.  If the parts are subject to normal maintenance cycles, then they may not have receive such normal maintenance when used within a simulator.

In summary, it may be possible to remove a part from a simulator for use in an airworthy aircraft, if:

1. The installer confirms that the original part was produced under a production approval, or is otherwise known to meet the applicable airworthiness standards (this is different from being approved for use on a simulator);
2. The installer confirms that the part has been subject to appropriate maintenance when maintenance is normal for such parts;
3. The installer confirms that the part has not been subject to damage or degradation while installed on the simulator (as well as before such installation).

While there is a theoretical path for possible use of some simulator parts on type certificated aircraft, we generally do not recommended such use, except where non-simulator parts are otherwise unavailable, because of the amount of analysis that would be necessary to confirm airworthiness.