Xfer of Field approval.

Just looked at 8300-16. this is still in there. So technically they don't issue "multiple field approvals" but .....

Note:
[FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman]An ASI (or an appropriately rated DAR) approves data on FAA Form 337 for a major repair or alteration to a specific aircraft, powerplant, propeller, or appliance. Prior to September 2002, the FAA permitted approval of data on a single FAA Form 337 for use on multiple aircraft. This practice is no longer permitted. However, multiple approvals can still be used on identical aircraft by the original modifier. [/FONT][/FONT]
[FONT=Times New Roman,Times New Roman][FONT=Times New Roman,Times New Roman][/FONT][/FONT]

S2D said:

Just looked at 8300-16. this is still in there. So technically they don't issue "multiple field approvals" but .....

Note:
An ASI (or an appropriately rated DAR) approves data on FAA Form 337 for a major repair or alteration to a specific aircraft, powerplant, propeller, or appliance. Prior to September 2002, the FAA permitted approval of data on a single FAA Form 337 for use on multiple aircraft. This practice is no longer permitted. However, multiple approvals can still be used on identical aircraft by the original modifier.

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and I'm always curious what that means.... how do you write that up in logs/337's???

In the olden days, in a separate paragraph, they stated that a field approval was Approved Data for the original installer. There were no caveats or qualifiers, and it was a separate numbered paragraph without reference to the "multiple field approval" paragraph.

I simply put on the back of the 337 "Approved Data per 8900.1 Chapt. 9 Sect. 4e - see Field approval for Piper N- . . . Ser . . . Dated . . ."

There are lots of IAs that disagree with me, and that's fine. There is law on my side - it is called the "Doctrine of Independent Legal Significance". I study this stuff.

Unfortunately, I failed to keep a copy of that old Order. I bet nobody cares enough to challenge my installations. They have been functioning safely for over a decade.

I also note that if an approval was obtained when that paragraph was still in effect, the data is still approved. I think it takes an AD or a notice in the Federal Register to change the status of approved data.

All opinion.

bob turner said:

Unfortunately, I failed to keep a copy of that old Order.

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this has change history, maybe you can find it, and provide a link here

http://fsims.faa.gov/PICResults.aspx?mode=EBookContents&restricttocategory=all~menu

You know what? I have excerpts saved in a computer file. It was still good as of 2011 - it was 8900.1 Chg 159 Vol 4.1178 B2 (k). I just found it as I was looking for my new Stroker 337.

I am still thinking about the red excerpt above, but I bet, in conjunction with these paragraphs, a case can still be made for "original installer" approved data. Not sure - sometimes changing a rule means it was intended to delete the previous understanding. We are, of course, dealing with guidelines, not rules, but they are binding on the FAA inspectors.

I have a couple field-approved 337's in my airplane's files that used a previously-field approved 337 as documentation,
I guess you'd consider those as "accepted data",
but they both have their own FAA sign-off in block 3 (??).

This the one you are looking for??

http://fsims.faa.gov/wdocs/8900.1/v04 ac equip & auth/chapter 09/04_009_001_chg_159a.htm

Yes, but I had found an excerpt I stored in my computer.

The difference between a field approval for multiple aircraft and the idea that a 337 is approved data for the original installer is that the multiple field approval could be done by anyone - in effect, a poor man's STC. The fact that they stopped doing those and still retained the paragraph about 337s being approved data for the original installer is significant.

The FAA is clear - a previous field approval is acceptable data. The inspector is under no obligation to approve a mod based on acceptable data, as far as I can tell. My FSDO sure never paid much attention to that.

bob turner said:

The difference between a field approval for multiple aircraft and the idea that a 337 is approved data for the original installer is that the multiple field approval could be done by anyone - in effect, a poor man's STC. ..

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no, only the original entity that received it can do it.... and still can...( I have to have them come look at, and approve what was done and then they approve it under that)

but no new approvals of that type, can be given since 2002 change....

That is my point. You have two distinctly different paragraphs, and only one speaks to the original installer. But when an FAA official document calls something "approved data" it is difficult to believe that we would wish it were otherwise. Approved data needs no further approval; it can be cited and used with an IA signature.

opinion

Multiple-use field approvals....never heard of them before this discussion.
I do remember reading an article where the writer mentioned a "one time STC"--
never heard of that one either, other than that article.
That sounds more like a field approval than an STC to me though.

hotrod180 said:

Multiple-use field approvals....never heard of them before this discussion.
I do remember reading an article where the writer mentioned a "one time STC"--
never heard of that one either, other than that article.
That sounds more like a field approval than an STC to me though.

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One-time STCs have been around for a long time. You can read all about them in FAA Advisory Circular AC 21-40A. Multiple-use field approvals were pretty common some time ago, but my guess is that they don't much get issued anymore. My bet is that, if you're looking for a field approval to be applied to more than one airplane, the FAA will tell you to get an STC instead.

I hold field approvals for Grove Brakes for two Aeronca Champs. Others hold similar approvals. So far, the FSDO seems motivated by comments like "this conversion has made my aircraft dramatically safer." Never mind that the entire parts list is less expensive than one used Aeronca wheel.

Sure, an STC would be better, but the market is just not big enough to cover the cost of development.

bob turner said:

I hold field approvals for Grove Brakes for two Aeronca Champs. Others hold similar approvals. So far, the FSDO seems motivated by comments like "this conversion has made my aircraft dramatically safer." Never mind that the entire parts list is less expensive than one used Aeronca wheel.

Sure, an STC would be better, but the market is just not big enough to cover the cost of development.

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have you ever touched base with Burl. He is the Aeronca sedan manufacturer locally and I think he has STC for grove stuff. http://www.burlac.com/

Did not know that. Met him at CC a few years ago - really nice guy. We discussed Helios. He probably kept me out of trouble with his hints.