The New Procedure For 337's -Field APP.
- Thread starter av8ron
- Start date
B
bearsnack
I heard the IAs are charging double now for 337 paperwork and approvals
Steve Pierce
BENEFACTOR
Graham, TX
From Aircraft Maintenance Technology Magezine
by Bill O'Brien who is the national resource specialist for the Federal Aviation Administration in Washington, D.C.
Long but worth the read.
Very interesting what the three things are that determine a major repair or alteration.
On May 21, 2003, seven months after the Federal Aviation Administration (FAA) made the first substantive revision to field approval policy in 20 years, the FAA issued a second revision. This latest revision is Change 16 to Volume 2, Chapter 1, of FAA Order 8300.10, Airworthiness Inspector's Handbook. You can get a copy of the Order and revisions by getting online and pulling up: http://www2.faa.gov/avr/afs/faa/8300/.
It would be an understatement to say that everyone, including the inspectors in FAA local Flight Standards District Offices (FSDO), was happy with the first revision. So, armed with an exemption from the Environmental Protection Agency (EPA), I will attempt to put oil on troubled waters with a two-part article on field approvals. Part 1 will provide a short history of field approvals; in Part 2, I will cover the latest policy that came out in late May of this year. However, before we get too far into the field approval process, I would like to go over a few important facts.
Facts
FAA FSDOs nationwide process approximately 23,000 field approvals a year.
Of those 23,000 field approvals, approximately 65 percent deal with avionics installations (major alterations).
FAA airworthiness and avionics inspectors must be trained and authorized by their individual region and office before they can perform field approvals.
However, once approved, the authority and responsibility to perform a field approval is the FSDO inspector's alone.
The FSDO inspector must have experience in the areas that the applicant wants to alter or repair before he or she can sign off block 3 of Form 337.
FAA field approvals are "policy driven," not "regulatory driven." In other words, field approvals are not specifically addressed in FARs.
Because there is no rule that speaks to field approvals, maintenance personnel do not have a regulatory right to get a field approval.
Field approvals are listed in the FSDO inspector's work program as Demand Work, not Required Work, so they do not get extra marks on the bark for each field approval they sign off.
Now, despite what you've been hearing over the mechanic's rumor mill, FSDOs are still in the field approval business. Quite frankly, if FSDOs no longer processed field approvals, in 18 months a major portion of general aviation (GA) as we know it would cease to be. Avionics shops, repair stations, and fixed-base operators (FBO) would die from lack of business because they would be out of the major repair and major alteration business.
The next candidates for the marble orchard would be the equipment suppliers and the vendors. Shortly after we bury the repair stations, suppliers, and FBOs in a mass grave, the next casualty would be the FSDO that caters almost exclusively to the GA world. The FAA would be forced to close some of the FSDOs down or dramatically reduce their inspector work force, which would be based on the logic: "If the town is empty, who needs the cops?" So, despite all of the pessimistic talk in hangar lunchrooms, I am here to tell you that the FAA needs the field approvals business, just as much as industry.
History
There is an old saying that I just made up: "If you don't know where you've been, how did you get here?" The same is true with field approvals. I have done a bit of research on this subject and I am disappointed to report that as of this date, my research into the actual beginnings of field approvals is less than what I hoped for. This discrepancy in my research is due in part that even 60 plus years ago, field approvals as we now know them, were an instrument of policy, not a rule. As we know, policy is not bound by the strict legal record-keeping requirements that are required by the rulemaking process. However, I will share with you bits and pieces of intel of what I have found so far.
The earliest reference I have found - referencing major repairs - is a directive dated Feb. 20, 1929, from Clarence M. Young, then director of aeronautics in the Commerce Department. The directive required a rebuilder, prior to making the repairs, to furnish the department duplicate drawings and stress analysis of the parts to be rebuilt or repaired if, in the opinion of the Inspector of the department, the aircraft was damaged in excess of 50 percent. The department then approved the repair data. In addition, as part of the final inspection, the repairer must make a statement to the department inspector making the final inspection, under oath, that the repairs were made in accordance with that "approved" data.
The next reference I found was Aeronautics Bulletin NO 7-H Air Commerce Regulations, Alteration and Repair of Aircraft. This bulletin provides the definition of major repair and identifies Form 466, which is used to record the major repairs and major alterations. The form then is sent to the Department of Commerce Inspector involved in the repair or alteration.
In 1938, the Civil Aeronautics Act created the Civil Aeronautics Agency, which was changed to Civil Aeronautics Administration (CAA) in 1941. By word of mouth only, I have found that "field approvals" were first performed by Civil Aeronautics Inspectors, starting back as early as 1939. This policy of "field approvals" was allowed because a sizable number of CAA inspectors were engineers and the field approvals even back then were not complex in nature. During the same period, CAA Form ACA-337, Major Repair and Alteration Form, replaced the now defunct Bureau of Aeronautics Form 466. The need for field approvals dropped to zero during the WWII years because all civilian flying was grounded with the exception of the Civil Air Patrol aircraft.
When the war ended, the CAA was downsized because of budget cuts. The cuts included the CAA's engineering personnel headquarters in Washington, so with the workload piling up, the once frowned-upon field approvals became part of CAA policy. In 1951, President Truman signed an amendment to the CAA Act, which allowed individual mechanics appointed by the CAA and called Designated Aviation Maintenance Inspectors (DAMI) to sign off field approvals. This privilege for DAMI lasted until October of 1956, when this privilege was canceled. I have not found out why, but I suspect it was canceled due to legal problems over the implementing of the policy.
On April 1, 1958, the Federal Aviation Act was signed by President Eisenhower and a massive re-codification of the Civil Aviation Regulations (CAR) into the Federal Aviation Regulations (FAR) began. At the same time, FAA policy was also re-codified along with the rules. One of the first FAA references to field approvals was FAA Order 8310.6, Airworthiness Compliance Check Sheet Handbook. This handbook was a compilation of check sheets that included regulations, structural requirements, hazards, and operating aspects to be considered before making a major alteration and whose beginnings are lost in the mists of time. In the middle '70s, the FAA published FAA Order 8600.1, Airworthiness Inspector's Handbook, which included the first real FAA policy on field approvals. This Order was later superceded by the current Order 8300.10. I had to smile to myself when I discovered that, while the amount of words describing field approval policy has increased tenfold over the past 60 years, the substance of the early policy has remained pretty much the same. In Part 2 of this article I will go over the field approval process under the new policy.
O'Brien's Laws for Field Approvals:
1. Don't cut metal, string wire, or drive a rivet without first having an FAA inspector sign block 3 of your Form 337.
2. Make sure that your major repair or alteration is not going to interfere with other systems or STCs installed on the aircraft.
3. Check all sources first - there might be an STC on the books for the major alteration or major repair you are planning.
4. Use the checklist for instructions for continued airworthiness when making a major alteration.
5. If you have determined that the repair or alteration is minor, state so in the logbook after you did the work and reference data that supports your decision.
6. If you have DER data, check and see if the data covers the installation of the product as well as any major repair or alteration. If the installation is not covered, then you need a field approval.
7. Check and see if the piece of equipment you install is going to stay where it's supposed to stay by figuring out the design loads in chapter 1 of AC 43.13.2A.
8. No matter what, make sure that the repair or alteration meets the type design standard or approved alteration the aircraft was built to.
9. Give the FAA inspector a reasonable amount of time to review Form 337 for a field approval.
--------------------------------------------------------------------------------
Bill O'Brien is the national resource specialist for the Federal Aviation Administration in Washington, D.C.
Field Approvals
Part 2: Still part of the process
By Bill O'Brien
In Part 2 of my tome on field approvals, we will cover current field approval policy found in Change 16 to FAA Order 8300.10. You can pull up Change 16 on our web site at: http://www2.faa.gov/avr/afs/faa/8300/.
In order for the rest of the article to make sense, we have to first agree that a repair is a procedure or a process whose intent is to restore the aircraft or one of its parts back to the original design or properly altered condition. An alteration is a change to the original design or properly altered condition.
Is or isn't?
Before running to the FSDO for a field approval, your first question should be whether the repair or alteration staring you in the face is either major or minor. Making this is or isn't determination is not as easy as it sounds. If we look in 14 CFR part 1, the definitions of major repair and major alterations are strikingly similar. If we consolidate and paraphrase the two 14 CFR definitions of a major repair and a major alteration into one, it would look like this:
1. If a repair or alteration is improperly done, it might affect weight and balance, structural strength, performance, powerplant operations, flight characteristics, or other qualities affecting airworthiness.
2. That is not done according to accepted practices or cannot be done by elementary operations.
If you take that definition at face value, any repair or alteration that you do on an aircraft would be major because everything you touch on an aircraft affects something else. Even as a mechanic working at North Philadelphia airport 25 pounds ago, I always believed that the lawyers who wrote the part 1 definitions for major repairs and alterations should have worked a little harder to narrow the definitions down to a level of understanding we did not need a second legal opinion for.
So where do you go next to figure out major or minor? Try Part 43, appendix A. It lists major repairs and major alterations by powerplant, airframe, and appliances. But you may have a problem with the appendix A list. The problem is the lists in the appendix are not all that inclusive, so your repair or alteration may not be identified as major on the list. So if you roll craps, then try the manufacturer and see if it can tell you if what you want to do is major or minor. But it has been my experience that most manufacturers are less than helpful in the major repair or major alteration department because lawyers have made cowards of us all. In an act of final desperation, you can call your FAA inspector and ask your major or minor question.
Let's say you tried all of the above and still no luck. As a last gap measure I have a possible solution for you. Ask yourself three questions. If the answers to any of those questions are no, then the repair or alteration you want to perform is major. While not perfect, the three-part question enables you to focus on the decision in front of you. The question begins with: If the repair or alteration you performed totally fails, can the aircraft:
1. Continue to fly?
2. Land?
3. Keep passengers, crew, and people on the ground unharmed?
If the answer to all three questions is yes, then you have a minor; if the answer to any one of the three questions is a no, then you have a major repair or a major alteration.
Let's say you now have determined that you have a major alteration. The next thing you need is data to do the work and all major repairs and major alterations must use data approved by the FAA.
Data
There are two kinds of data: acceptable and approved. Acceptable data can be manufacturer's manuals, bulletins, Advisory Circulars 43.13-1B, Acceptable Techniques and Practices, Aircraft Inspection and Repair, and AC 43.13-2A, Aircraft Alterations. Acceptable data is used for regular old inspections, maintenance, and minor repairs and alterations. Ninety-eight percent of maintenance performed on aircraft is done using acceptable data.
However, to perform a major repair or a major alteration, parts 43, 65, 121, and 145 say you must use FAA-"approved data." This data must be approved because you are either changing the type design of the aircraft with a major alteration or returning the aircraft back to its original or properly altered condition with a major repair. Some examples of FAA approved data are Type Certificate drawings, Airworthiness Directives, approved portions of the manufacturer's manual (like structural repair chapter), CAA Forms 337 dated before 10/1/55, and DAS data. For even more examples of approved data, please see Change 16 revision to the field approval chapter in FAA Order 8300.10.
I wish I could tell you that in every case, the word acceptable means acceptable, and the word approved means approved. But when you read the Order you will find out that there are exceptions. For example, you can use an appliance manufacturer's manual to make FAA-approved major repairs to their product even though the manual does not say FAA-approved. Or you can use AC 43.13-1B for major repairs on nonpressurized areas of aircraft only when the mechanic determines that the major repair is:
1. Appropriate to the product being repaired;
2. Directly applicable to the repair being made; and
3. Not contrary to the manufacturer's data.
If you forget where the three limitations are for using the AC, they are easy to find: they are on the first page, in the first paragraph of the signature page of the AC. For other examples of approved data, see FAA Order 8300.10 Change 16, Vol. 2, Chapter 1. If you do not have an STC in your pocket, then you are in the market for a field approval.
Definition of a field approval
A field approval is an approval by the Administrator, through an authorized FAA inspector, of technical data and/or installation used to accomplish major repairs and major alterations. Such data or installation becomes technical data approved by the Administrator and it is used for a one-time installation.
So, there are two kinds of field approvals: one for data which is the most common. The data is usually generated by the mechanic doing the repair or alteration. The mechanic must make sure that the data that is supplied to the inspector meets or exceeds the CAR or FAR standard the aircraft was built to, or your application will be rejected.
The second kind of field approval is for installations and repairs that were previously done by parties unknown. This second one comes in pretty handy when, during an annual inspection, you find an installation that obviously has been on the aircraft forever. For example, let's say bigger battery/battery box installation than what the type certification (TC) called for, and you have zero paperwork. To fix the paperwork/approval problem, you fill out Form 337 just as if you were doing the installation and get your local FAA inspector to approve the installation, based on his inspection, and by signing off Block 3 of Form 337. Then, you approve the installation by signing your name and certificate number in Block 7 of the form. You must also create the Instructions for Continued Airworthiness (ICA) for this installation and attach the ICA to the form.
Instructions for continued airworthiness
This policy sets forth a requirement for field approvals for major alterations; the mechanic or repair station doing the work must create instructions on how to maintain the continued airworthiness of that alteration for the mechanics that follows. The policy came out in 1999 and I am the one responsible for it. If you want to find out more about the background and the reason why the policy came to be, you can read my articles titled: "Red Tape" and "Dead Cat's Replacement". The articles can be found on the AMT website.
The requirement to develop Instructions for Continued Airworthiness (ICA) is simple to comply with. You can use the checklist found in Change 16 to the FAA Airworthiness Inspector's Handbook, Vol. 2, Chapter 1. The Handbook can be found on the FAA website: http://www2.faa.gov/avr/afs/faa/8300/. The checklist contains 16 blocks you must check off. Field trials of the form indicate that only five to eight blocks are usually filled out with information, the rest of the blocks can be filled in with N/A. There are a couple of pluses to using the ICA checklist. First, the form is standardized, and it is national policy so it meets 14 CFR. Next, the ICA checklist allows you to identify replacement parts for your alteration, so you won't need another field approval to replace a part, and it allows you to revise the checklist when a need arises.
What are the changes to field approval policy?
For the most part, field approval policy has remained 90 percent the way it was. The three biggest changes to field approvals were: first, the deletion of the third kind of field approval, the multiple field approval that was performed by the original modifier. Second, the addition of a decision flow chart (appendix 1-2) for the field approval process that is applicable both to industry and FAA inspectors to improve standardization. Third, was the incorporation of a 12-page job aid for major alterations. This job aid is what all the fuss was about.
The opening paragraph for the job aid for major alterations contains a statement that says: The following lists indicate which method(s) may be used for approving major alterations to TC'd and STC'd products. These lists are not all-inclusive and each alteration should be evaluated on a case-by-case basis. So, in reality, this job list is not so much different from earlier field approval policy, but it does provide a structure for decision-making.
For example, the job aid contains a list of major alterations broken down into four broad categories such as general aviation aircraft; transport aircraft; rotor craft; and engines, propellers, and APU. Each category is further broken down into areas such as: weight and balance, structural strength, operational characteristics, airworthiness, and crashworthiness.
Within each area there is a list of applicable alterations. At the right-hand side of each individual alteration is a block that is marked with the letters STC, EVL, or ENG. The letters STC stands for Supplemental Type Certificate. This means an STC must be approved for that particular alteration. The letters EVL mean that particular alteration may be eligible for an approval other than an STC, like a field approval. The letters ENG means that the local FAA Airworthiness Inspector needs input of some kind from FAA Engineering.
In summary, the old saw says change can be good, it can be bad, or it can keep the status quo. But it is only our reaction to change that matters. I want you to examine the new policy on field approvals, and discuss it among your peers. Only by educating yourself can you make the decision whether or not the new policy is good, bad, or if it just keeps the status quo. You can start your education on field approvals by pulling up our web site: http://www2.faa.gov/avr/afs/faa/8300/. The latest Change 16 revision to our FAA Order 8300.10 is listed there. If you have any comments, good or bad, get back to me at william.o'brien@faa.gov.
--------------------------------------------------------------------------------
Bill O'Brien is the national resource specialist for the Federal Aviation Administration in Washington, D.C.
by Bill O'Brien who is the national resource specialist for the Federal Aviation Administration in Washington, D.C.
Long but worth the read.
Very interesting what the three things are that determine a major repair or alteration.
On May 21, 2003, seven months after the Federal Aviation Administration (FAA) made the first substantive revision to field approval policy in 20 years, the FAA issued a second revision. This latest revision is Change 16 to Volume 2, Chapter 1, of FAA Order 8300.10, Airworthiness Inspector's Handbook. You can get a copy of the Order and revisions by getting online and pulling up: http://www2.faa.gov/avr/afs/faa/8300/.
It would be an understatement to say that everyone, including the inspectors in FAA local Flight Standards District Offices (FSDO), was happy with the first revision. So, armed with an exemption from the Environmental Protection Agency (EPA), I will attempt to put oil on troubled waters with a two-part article on field approvals. Part 1 will provide a short history of field approvals; in Part 2, I will cover the latest policy that came out in late May of this year. However, before we get too far into the field approval process, I would like to go over a few important facts.
Facts
FAA FSDOs nationwide process approximately 23,000 field approvals a year.
Of those 23,000 field approvals, approximately 65 percent deal with avionics installations (major alterations).
FAA airworthiness and avionics inspectors must be trained and authorized by their individual region and office before they can perform field approvals.
However, once approved, the authority and responsibility to perform a field approval is the FSDO inspector's alone.
The FSDO inspector must have experience in the areas that the applicant wants to alter or repair before he or she can sign off block 3 of Form 337.
FAA field approvals are "policy driven," not "regulatory driven." In other words, field approvals are not specifically addressed in FARs.
Because there is no rule that speaks to field approvals, maintenance personnel do not have a regulatory right to get a field approval.
Field approvals are listed in the FSDO inspector's work program as Demand Work, not Required Work, so they do not get extra marks on the bark for each field approval they sign off.
Now, despite what you've been hearing over the mechanic's rumor mill, FSDOs are still in the field approval business. Quite frankly, if FSDOs no longer processed field approvals, in 18 months a major portion of general aviation (GA) as we know it would cease to be. Avionics shops, repair stations, and fixed-base operators (FBO) would die from lack of business because they would be out of the major repair and major alteration business.
The next candidates for the marble orchard would be the equipment suppliers and the vendors. Shortly after we bury the repair stations, suppliers, and FBOs in a mass grave, the next casualty would be the FSDO that caters almost exclusively to the GA world. The FAA would be forced to close some of the FSDOs down or dramatically reduce their inspector work force, which would be based on the logic: "If the town is empty, who needs the cops?" So, despite all of the pessimistic talk in hangar lunchrooms, I am here to tell you that the FAA needs the field approvals business, just as much as industry.
History
There is an old saying that I just made up: "If you don't know where you've been, how did you get here?" The same is true with field approvals. I have done a bit of research on this subject and I am disappointed to report that as of this date, my research into the actual beginnings of field approvals is less than what I hoped for. This discrepancy in my research is due in part that even 60 plus years ago, field approvals as we now know them, were an instrument of policy, not a rule. As we know, policy is not bound by the strict legal record-keeping requirements that are required by the rulemaking process. However, I will share with you bits and pieces of intel of what I have found so far.
The earliest reference I have found - referencing major repairs - is a directive dated Feb. 20, 1929, from Clarence M. Young, then director of aeronautics in the Commerce Department. The directive required a rebuilder, prior to making the repairs, to furnish the department duplicate drawings and stress analysis of the parts to be rebuilt or repaired if, in the opinion of the Inspector of the department, the aircraft was damaged in excess of 50 percent. The department then approved the repair data. In addition, as part of the final inspection, the repairer must make a statement to the department inspector making the final inspection, under oath, that the repairs were made in accordance with that "approved" data.
The next reference I found was Aeronautics Bulletin NO 7-H Air Commerce Regulations, Alteration and Repair of Aircraft. This bulletin provides the definition of major repair and identifies Form 466, which is used to record the major repairs and major alterations. The form then is sent to the Department of Commerce Inspector involved in the repair or alteration.
In 1938, the Civil Aeronautics Act created the Civil Aeronautics Agency, which was changed to Civil Aeronautics Administration (CAA) in 1941. By word of mouth only, I have found that "field approvals" were first performed by Civil Aeronautics Inspectors, starting back as early as 1939. This policy of "field approvals" was allowed because a sizable number of CAA inspectors were engineers and the field approvals even back then were not complex in nature. During the same period, CAA Form ACA-337, Major Repair and Alteration Form, replaced the now defunct Bureau of Aeronautics Form 466. The need for field approvals dropped to zero during the WWII years because all civilian flying was grounded with the exception of the Civil Air Patrol aircraft.
When the war ended, the CAA was downsized because of budget cuts. The cuts included the CAA's engineering personnel headquarters in Washington, so with the workload piling up, the once frowned-upon field approvals became part of CAA policy. In 1951, President Truman signed an amendment to the CAA Act, which allowed individual mechanics appointed by the CAA and called Designated Aviation Maintenance Inspectors (DAMI) to sign off field approvals. This privilege for DAMI lasted until October of 1956, when this privilege was canceled. I have not found out why, but I suspect it was canceled due to legal problems over the implementing of the policy.
On April 1, 1958, the Federal Aviation Act was signed by President Eisenhower and a massive re-codification of the Civil Aviation Regulations (CAR) into the Federal Aviation Regulations (FAR) began. At the same time, FAA policy was also re-codified along with the rules. One of the first FAA references to field approvals was FAA Order 8310.6, Airworthiness Compliance Check Sheet Handbook. This handbook was a compilation of check sheets that included regulations, structural requirements, hazards, and operating aspects to be considered before making a major alteration and whose beginnings are lost in the mists of time. In the middle '70s, the FAA published FAA Order 8600.1, Airworthiness Inspector's Handbook, which included the first real FAA policy on field approvals. This Order was later superceded by the current Order 8300.10. I had to smile to myself when I discovered that, while the amount of words describing field approval policy has increased tenfold over the past 60 years, the substance of the early policy has remained pretty much the same. In Part 2 of this article I will go over the field approval process under the new policy.
O'Brien's Laws for Field Approvals:
1. Don't cut metal, string wire, or drive a rivet without first having an FAA inspector sign block 3 of your Form 337.
2. Make sure that your major repair or alteration is not going to interfere with other systems or STCs installed on the aircraft.
3. Check all sources first - there might be an STC on the books for the major alteration or major repair you are planning.
4. Use the checklist for instructions for continued airworthiness when making a major alteration.
5. If you have determined that the repair or alteration is minor, state so in the logbook after you did the work and reference data that supports your decision.
6. If you have DER data, check and see if the data covers the installation of the product as well as any major repair or alteration. If the installation is not covered, then you need a field approval.
7. Check and see if the piece of equipment you install is going to stay where it's supposed to stay by figuring out the design loads in chapter 1 of AC 43.13.2A.
8. No matter what, make sure that the repair or alteration meets the type design standard or approved alteration the aircraft was built to.
9. Give the FAA inspector a reasonable amount of time to review Form 337 for a field approval.
--------------------------------------------------------------------------------
Bill O'Brien is the national resource specialist for the Federal Aviation Administration in Washington, D.C.
Field Approvals
Part 2: Still part of the process
By Bill O'Brien
In Part 2 of my tome on field approvals, we will cover current field approval policy found in Change 16 to FAA Order 8300.10. You can pull up Change 16 on our web site at: http://www2.faa.gov/avr/afs/faa/8300/.
In order for the rest of the article to make sense, we have to first agree that a repair is a procedure or a process whose intent is to restore the aircraft or one of its parts back to the original design or properly altered condition. An alteration is a change to the original design or properly altered condition.
Is or isn't?
Before running to the FSDO for a field approval, your first question should be whether the repair or alteration staring you in the face is either major or minor. Making this is or isn't determination is not as easy as it sounds. If we look in 14 CFR part 1, the definitions of major repair and major alterations are strikingly similar. If we consolidate and paraphrase the two 14 CFR definitions of a major repair and a major alteration into one, it would look like this:
1. If a repair or alteration is improperly done, it might affect weight and balance, structural strength, performance, powerplant operations, flight characteristics, or other qualities affecting airworthiness.
2. That is not done according to accepted practices or cannot be done by elementary operations.
If you take that definition at face value, any repair or alteration that you do on an aircraft would be major because everything you touch on an aircraft affects something else. Even as a mechanic working at North Philadelphia airport 25 pounds ago, I always believed that the lawyers who wrote the part 1 definitions for major repairs and alterations should have worked a little harder to narrow the definitions down to a level of understanding we did not need a second legal opinion for.
So where do you go next to figure out major or minor? Try Part 43, appendix A. It lists major repairs and major alterations by powerplant, airframe, and appliances. But you may have a problem with the appendix A list. The problem is the lists in the appendix are not all that inclusive, so your repair or alteration may not be identified as major on the list. So if you roll craps, then try the manufacturer and see if it can tell you if what you want to do is major or minor. But it has been my experience that most manufacturers are less than helpful in the major repair or major alteration department because lawyers have made cowards of us all. In an act of final desperation, you can call your FAA inspector and ask your major or minor question.
Let's say you tried all of the above and still no luck. As a last gap measure I have a possible solution for you. Ask yourself three questions. If the answers to any of those questions are no, then the repair or alteration you want to perform is major. While not perfect, the three-part question enables you to focus on the decision in front of you. The question begins with: If the repair or alteration you performed totally fails, can the aircraft:
1. Continue to fly?
2. Land?
3. Keep passengers, crew, and people on the ground unharmed?
If the answer to all three questions is yes, then you have a minor; if the answer to any one of the three questions is a no, then you have a major repair or a major alteration.
Let's say you now have determined that you have a major alteration. The next thing you need is data to do the work and all major repairs and major alterations must use data approved by the FAA.
Data
There are two kinds of data: acceptable and approved. Acceptable data can be manufacturer's manuals, bulletins, Advisory Circulars 43.13-1B, Acceptable Techniques and Practices, Aircraft Inspection and Repair, and AC 43.13-2A, Aircraft Alterations. Acceptable data is used for regular old inspections, maintenance, and minor repairs and alterations. Ninety-eight percent of maintenance performed on aircraft is done using acceptable data.
However, to perform a major repair or a major alteration, parts 43, 65, 121, and 145 say you must use FAA-"approved data." This data must be approved because you are either changing the type design of the aircraft with a major alteration or returning the aircraft back to its original or properly altered condition with a major repair. Some examples of FAA approved data are Type Certificate drawings, Airworthiness Directives, approved portions of the manufacturer's manual (like structural repair chapter), CAA Forms 337 dated before 10/1/55, and DAS data. For even more examples of approved data, please see Change 16 revision to the field approval chapter in FAA Order 8300.10.
I wish I could tell you that in every case, the word acceptable means acceptable, and the word approved means approved. But when you read the Order you will find out that there are exceptions. For example, you can use an appliance manufacturer's manual to make FAA-approved major repairs to their product even though the manual does not say FAA-approved. Or you can use AC 43.13-1B for major repairs on nonpressurized areas of aircraft only when the mechanic determines that the major repair is:
1. Appropriate to the product being repaired;
2. Directly applicable to the repair being made; and
3. Not contrary to the manufacturer's data.
If you forget where the three limitations are for using the AC, they are easy to find: they are on the first page, in the first paragraph of the signature page of the AC. For other examples of approved data, see FAA Order 8300.10 Change 16, Vol. 2, Chapter 1. If you do not have an STC in your pocket, then you are in the market for a field approval.
Definition of a field approval
A field approval is an approval by the Administrator, through an authorized FAA inspector, of technical data and/or installation used to accomplish major repairs and major alterations. Such data or installation becomes technical data approved by the Administrator and it is used for a one-time installation.
So, there are two kinds of field approvals: one for data which is the most common. The data is usually generated by the mechanic doing the repair or alteration. The mechanic must make sure that the data that is supplied to the inspector meets or exceeds the CAR or FAR standard the aircraft was built to, or your application will be rejected.
The second kind of field approval is for installations and repairs that were previously done by parties unknown. This second one comes in pretty handy when, during an annual inspection, you find an installation that obviously has been on the aircraft forever. For example, let's say bigger battery/battery box installation than what the type certification (TC) called for, and you have zero paperwork. To fix the paperwork/approval problem, you fill out Form 337 just as if you were doing the installation and get your local FAA inspector to approve the installation, based on his inspection, and by signing off Block 3 of Form 337. Then, you approve the installation by signing your name and certificate number in Block 7 of the form. You must also create the Instructions for Continued Airworthiness (ICA) for this installation and attach the ICA to the form.
Instructions for continued airworthiness
This policy sets forth a requirement for field approvals for major alterations; the mechanic or repair station doing the work must create instructions on how to maintain the continued airworthiness of that alteration for the mechanics that follows. The policy came out in 1999 and I am the one responsible for it. If you want to find out more about the background and the reason why the policy came to be, you can read my articles titled: "Red Tape" and "Dead Cat's Replacement". The articles can be found on the AMT website.
The requirement to develop Instructions for Continued Airworthiness (ICA) is simple to comply with. You can use the checklist found in Change 16 to the FAA Airworthiness Inspector's Handbook, Vol. 2, Chapter 1. The Handbook can be found on the FAA website: http://www2.faa.gov/avr/afs/faa/8300/. The checklist contains 16 blocks you must check off. Field trials of the form indicate that only five to eight blocks are usually filled out with information, the rest of the blocks can be filled in with N/A. There are a couple of pluses to using the ICA checklist. First, the form is standardized, and it is national policy so it meets 14 CFR. Next, the ICA checklist allows you to identify replacement parts for your alteration, so you won't need another field approval to replace a part, and it allows you to revise the checklist when a need arises.
What are the changes to field approval policy?
For the most part, field approval policy has remained 90 percent the way it was. The three biggest changes to field approvals were: first, the deletion of the third kind of field approval, the multiple field approval that was performed by the original modifier. Second, the addition of a decision flow chart (appendix 1-2) for the field approval process that is applicable both to industry and FAA inspectors to improve standardization. Third, was the incorporation of a 12-page job aid for major alterations. This job aid is what all the fuss was about.
The opening paragraph for the job aid for major alterations contains a statement that says: The following lists indicate which method(s) may be used for approving major alterations to TC'd and STC'd products. These lists are not all-inclusive and each alteration should be evaluated on a case-by-case basis. So, in reality, this job list is not so much different from earlier field approval policy, but it does provide a structure for decision-making.
For example, the job aid contains a list of major alterations broken down into four broad categories such as general aviation aircraft; transport aircraft; rotor craft; and engines, propellers, and APU. Each category is further broken down into areas such as: weight and balance, structural strength, operational characteristics, airworthiness, and crashworthiness.
Within each area there is a list of applicable alterations. At the right-hand side of each individual alteration is a block that is marked with the letters STC, EVL, or ENG. The letters STC stands for Supplemental Type Certificate. This means an STC must be approved for that particular alteration. The letters EVL mean that particular alteration may be eligible for an approval other than an STC, like a field approval. The letters ENG means that the local FAA Airworthiness Inspector needs input of some kind from FAA Engineering.
In summary, the old saw says change can be good, it can be bad, or it can keep the status quo. But it is only our reaction to change that matters. I want you to examine the new policy on field approvals, and discuss it among your peers. Only by educating yourself can you make the decision whether or not the new policy is good, bad, or if it just keeps the status quo. You can start your education on field approvals by pulling up our web site: http://www2.faa.gov/avr/afs/faa/8300/. The latest Change 16 revision to our FAA Order 8300.10 is listed there. If you have any comments, good or bad, get back to me at william.o'brien@faa.gov.
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Bill O'Brien is the national resource specialist for the Federal Aviation Administration in Washington, D.C.
Steve;
Thanks for this lengthy explanation. I did read it. As usual, it seem to be left up to interpretation. The rumor mill in AK is that unless there is an STC for the modification you have to go to engineering before you can get an approval. For instance, I am trying to get my battery moved up under my seat and replaced with the small gel cell in my PA-12. There is no STC so I am being told that I need to preform testing and provide engineering to get this alteration approved.
Thanks For the input!
Ron
Thanks for this lengthy explanation. I did read it. As usual, it seem to be left up to interpretation. The rumor mill in AK is that unless there is an STC for the modification you have to go to engineering before you can get an approval. For instance, I am trying to get my battery moved up under my seat and replaced with the small gel cell in my PA-12. There is no STC so I am being told that I need to preform testing and provide engineering to get this alteration approved.
Thanks For the input!
Ron
Steve Pierce
BENEFACTOR
Graham, TX
That sucks. My airworthiness inspector would take the paperwork from the PA18 and use that data to approve. I have done mods on Clippers using Pacer and Tri-Pacer STC data. I am putting "X" bracing in three Clippers right now using the PA18 STC from Atlee and the Clipper and Super Cub fuselage drawings. They need some people with some common sense. Good luck.
Steve Pierce
BENEFACTOR
Graham, TX
Yes I read it. My ASI is the head Airworthiness Inspector at the Ft. Worth FSDO. He retires in two years unfortunately. He had a shop and worked in the real world.
Steve, just a side note: I connected with Bill O'brien through email this morning and he highlighted the fact that if you can find any CAA 337 form prior to 10/1955 they are considered to be approved data and no STC or field approval is required for the same alteration. This is a good option. There needs to be a forum to share these old 337. I'm sure there are not a lot of them but some could be very useful.
You are fortunate to be working with someone so flexible. O'brien also agreed that we Alaskans were the contributing factor to Change 16.
Ron
You are fortunate to be working with someone so flexible. O'brien also agreed that we Alaskans were the contributing factor to Change 16.
Ron
