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.”

Kory Thomas, customer service manager for Duncan Aviation’s Battle Creek facility, told AIN, “Krylon 1401 has been used on many sets of landing gear without issue. Duncan Aviation was in contact with the manufacturer prior to painting any landing gear with the product and fully met the parameters called out for landing gear repainting at the time. It was brought to our attention that a particular customer did not like the final finish of the product. We immediately offered to repaint the gear with a different lot of the same paint or with an alternate product; the customer refused that offer.” Thomas said that since the FAA’s inquiry into the composition of the paint, it became clear the information the company had received from the paint manufacturer was in error. “We have since stopped using that particular product and switched to a product that fully meets the current requirements. That change satisfied the FAA’s inquiry and closed the issue,” Thomas said. “We have spoken with other operators who had the initial paint on their gear and are not aware of any concerns with the finish or durability on those gear sets.”