A Falcon operator filed a complaint with the FAA against Duncan Aviation Battle Creek citing the unauthorized use of Krylon 1401 paint on the airplane’s landing gear. The operator also forwarded a copy of the FAA’s response to AIN. In a letter responding to the complainant, Carol Johnson, acting program manager for the FAA’s aviation safety hotline, explained that the FAA’s Duncan Aviation Certificate Management Office (CMU) and the Lincoln Flight Standards District Office (FSDO) conducted an investigation into the complainant’s concern. She wrote, “A discussion and review of Krylon Product Group (KPG) Regulatory Information personnel regarding Krylon 1401 use determined the paint to be an alkalyd enamel-based product. It has a high metallic content for brightness but is easily smudged and rubbed off unless an additional clear coat product is applied.”
The agency further stated that Duncan had violated FAA regulations by using a paint product that was not approved by the component manufacturer or listed in the approved procedures. “The Krylon 1401 paint failed to provide a durable finish during normal aircraft operations. The product was applied to the landing gear as an appearance improvement but did not affect the airworthiness or safe operation of the aircraft. A Letter of Correction has been issued to Duncan Aviation requiring a review of the approved procedures for refinishing of landing gear system components to ensure approved materials are used. Upon satisfactory review and acceptance of corrections and inspection of the paint shop by the agency’s CMU, this issue will be completed.”
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