Truth or Consequences about 337's

[On Patrol]

Hi Folks, Miss Daisy is now back on wheels for the first time in 10 plus years. In followup to a previous question the IA I used in Maine was dissatisfied with the 337's filed back in 1993 when she was totally restored. References were made to STC's that were never purchased and the letter of the STC was never followed. Changes to my panel were made and the 337 reads that it was done in accordance with practices per reg 4313. I am extremely satisfied with the workmanship and want this guy to perform more work but he his spooked by the paper. He has been an IA only a short time. I have a different shop in Mass. take care of my Comanche and I discussed the issues with the paper. I was also able to get the 337's filed with OK city. All the changes and work performed in 1993 is on file and previously accepted by the FSDO. My Comanche IA has told me that it was common practice before 8-10 years back to perform changes and file 337's referring to STC's and 4313 and as long as the FSDO did not kick them back once they are filed with OK city it is game over and the work is forever accepted and not held to changes in standards. Unless of course the dreaded AD is imposed. If this is true my Maine IA will be satisfied. Anyone know of official rulings. John

 

[T.J.]

delete

 

[Steve Pierce]

I ditto what TJ said to the letter.

 

[On Patrol]

The Paperwork is not stamped with a field approval but has been filed and is on record as 337's with the FAA OK City. The paperwork in my logs matches. The second IA still maintains that this was common practice previous to 10 years ago. He says that the same practices would not fly today and going back retroactively is unheard of. I shudder to think that I should call the FSDO inspector for a determination and potentially end up grounded. The paperwork is only date stamped by OK city and the field approval block on the face is blank. What should I do Thanks John

 

[cubunltd]

Are the 337's signed on the bottom by an IA? If so and the paperwork is filed with OK city, then it's legal.

 

[On Patrol]

Bright and bold the 337's have the double signature of the AP AI. I have the originals and OK city has the copies that I now have on microfiche/CD Thanks John

 

[On Patrol]

Without naming names or N numbers my Maine AI just got a determination from his FSDO safety inspector. Since the 337's are on file and previously accepted by OK city we are golden. The inspector advised that he retain dated copies of the filed 337's from OK city to prove that he was diligent in ensuring that the erroneous paperwork was in actuality on file and not just in the logs. Obviously any mods not listed on an accepted 337 must be now documented properly. Thanks for all your help John

 

[S2D]

Without naming names or N numbers my Maine AI just got a determination from his FSDO safety inspector. Since the 337's are on file and previously accepted by OK city we are golden. The inspector advised that he retain dated copies of the filed 337's from OK city to prove that he was diligent in ensuring that the erroneous paperwork was in actuality on file and not just in the logs. Obviously any mods not listed on an accepted 337 must be now documented properly. Thanks for all your help John

Might want to get that opinion in writing so the next guy down the road has documentation

 

[Wingie]

Yeah but...You may very well be "golden" with FAA in regards to having the 337s filed that use STCs (purchased or not) as Approved Data, but you say that the "letter of the STCs" weren't followed when the mods were done. Perhaps the "most important thing" that the IA signs for (and the reason he has to make that cumbersome statement) is that he has inspected the aircraft and found it to conform to it's Type Certificate OR ALTERED CONDITION, with Approved Data on file as the basis for the alterations (which even a Field Approval provides). The airplane still has to pass the inspection that confirms that. If there are "unrecorded" shortcuts or omissions to the way the work was required to be done, if some of the work wasn't done at all or done in a manner NOT in accordance with methods and procedures spelled out in the STCs, then there had better be a "deviation" listed on those 337s. If the airplane doesn't "match" the STCs requirements, it is STILL NOT in an airworthy condition! WHY it is or isn't that way isn't the question. Which means the IA still has to be "warm and fuzzy" enough to sign off on it. So before you celebrate too much, there is still the issue as to whether the airplane conforms to the paperwork on file. Right? Or has that been taken care of?