Originally Posted by
nulrich
Hi Ron:
I've heard of some bizarre interpretations of the GCR being circulated via private messages and emails, thanks for posting this particular private communication so I can defend our design! (And I don't think this particular interpretation is "bizarre," just incorrect).
If the language in the GCR said "non-ferrous metal" or, better yet, "nonferrous metal alloy" then I would agree it would exclude composite materials. It doesn't, it says "non-ferrous" with a hyphen. The most direct and logical interpretation of that is "not ferrous" and therefore anything that doesn't contain at least 50% iron. The simple explanation is that brackets don't have to be steel, which is an interpretation that has been used to construct very complex assemblies of aluminum panels that are "brackets" for the transmission (otherwise known as bell housings). That is how constructors have avoided the prohibition against stressed-skin construction in section B.1 (and elsewhere) in the GCR to allow monocoque assembled bell housings.
I agree those brackets are much more than a single part used for attachment (the conventional idea of a bracket) but that's how the GCR has been interpreted, so that same interpretation applies to our cockpit protection panels, which are much simpler than a multi-part bolted-together bell housing like used in the latest Citation. I suspect that's why the proposed new rules remove the prohibition against stressed-skin construction (they scratched out the six inch rule and the rule prohibiting monocoque structures).
If you search on the web, you can find many definitions of "nonferrous" (without a hyphen). I've been designing and machining mechanical parts for 25 years, and I have never heard anyone limit "nonferrous" to metal alloys. In fact, many cutting guidelines for end mills and drills include plastics in their definition of "nonferrous."
If they meant to only allow aluminum or magnesium they could have used the term "light alloy." Of course that would exclude people from making brackets out of plastic, which I've seen on many cars.
And, even with all this, our panels don't even need to meet the definition of bracket to be legal. They are also clearly legal as cockpit interior panels--they are inside the cockpit, not licked by the airstream, form the interior surfaces of the cockpit and are the closest part to the driver over the vast majority of the cockpit:
I apologize for the long reply, hope it's helpful.
Nathan