Field Approvals, (Again)
- Thread starter T.J.
- Start date
Steve Pierce
BENEFACTOR
Graham, TX
I have heard the same thing but not seen it here yet. I think they have a lot of people retiring and they aren't hiring new people.
Alex Clark
Registered User
Life Long Alaskan
At one of the Medallion Foundation meetings they were talking about the FAA dropping the Wings Program and gutting the safety end of the outfit,, while trying to replace some of their outgoing folks with unpaid volunteers....
Steve Pierce
BENEFACTOR
Graham, TX
Yea, and they employ more lawyers than anything else. 
flat country pilot
FRIEND
North Dakota
Too bad we can't move some of the better FAA field guys up the totem pole to a position where they can fix rules and regulations. People who are actually pilots first and lawyers last. I guess they don't want to be stuck in an office full of bull pies.
Bill
Bill
mvivion
SPONSOR
Bozeman,MT
There's a long history to this field approval issue. It was never originally intended that FSDO's do "engineering-like" work or approvals. That's not an "Airworthiness Inspector's" job, actually, though they have the authority to sign field approvals in certain circumstances where engineering is obviously not required.
Evaluating and approving SIGNIFICANT alterations to an aircraft was supposedly the province of the Engineering Offices of FAA. Unfortunately, they hired mostly slide rule guys there, many of whom frankly couldn't get a job in industry, and most of these guys spent all their time testing designs to death. Literally. Test it long enough, and it goes away. Hence, in the mind of a government engineer, he's been successful. Doesn't have to sign a thing. Also, there has never been accountability of the Engineering and Certification Offices, so they could virtually jerk anyone around and get away with it.
At some point, FSDO Inspectors got fed up with it, and started field approving things that actually should have gone to engineering, but the FSDO guys knew that was the kiss of death, so they signed em off. In Alaska, there was actually a sort of quiet initiative to get as many airplanes legal as possible, recognizing that there were a lot of bootleg modifications out there with no paper on them. So, FSDO's got in the habit of signing off some pretty interesting stuff, and A & P mechanics got in the habit of submitting everything for a field approval, since then the FAA's signature is in the record, as opposed to the mechanic. This went to the extreme, and mechanics were trained by the FAA not to sign off anything as a minor with a logbook entry, but rather to submit a 337.
All of a sudden this change order comes down, and Inspectors are supposed to get concurrance of a PANEL prior to signing a 337 field approval. Part of the intent was that mechanics should assume the responsibility of signing things off as minors that really are minors, by definition.
Unfortunately, most Maintenance Inspectors will tell you anything but going to a different heat range on the spark plugs constitutes a major alteration.
So, now we are in a Catch 22: Mechanics should sign off a lot of stuff as minors, but they know if they do, it's likely that a Maintenance Inspector will see it, and take the mechanic to task for not field approving or STC'ing it. The FSDO guys may or may not sign off anything, cause they can always fall back on the guidance that mechanics should sign things off as minors, or if they aren't minors, they should be looked at by Engineering. Question is: Who are the lawyers going to come visit if anything goes south.
At least one FAA Engineer has been heard to say in a meeting fairly recently that the Engineering Office is understaffed, so they intend to simply hold everything till someone calls their Senator, at which time, Engineering will plead understaffed and get funded for more positions. Good grief.
But, everyone in the FAA can go home and pat themselves on the back, cause they've done their job: Pass the buck.
A good friend of mine who works for FSDO, and is a good guy told me some time ago that the FAA has a new, unofficial motto:
"We're not happy till you're not Happy".
As TJ noted, there are some really good, practical minded folks who work for the FAA, but leadership in that organization is terrible. I recently had conversations with a couple of "leaders" in FAA, and was appalled at the sophomoric attitude they had between three divisions of the FAA.
As to the Safety Program, it has completely changed. And, it has been a painfully slow process. Many if not most of the people who have been put in charge of the new program as Supervisors came from the 121 side. Hey, the airlines have a great safety record, right? So, all we have to do is get some of those folks over to the GA side, and we'll fix the safety record of GA right off.
I wish there were some good news, and I hope there is, but the FAA seems bent during the tenure of the last two Administrators, neither of whom were pilots, to politicize the FAA to the point where it is a do nothing, obstruct everything organization.
Light sport is the bright spot I can see, but that was purely politically driven. Good for the folks who were able to push it through, but....
Sorry for the rant.
MTV
Evaluating and approving SIGNIFICANT alterations to an aircraft was supposedly the province of the Engineering Offices of FAA. Unfortunately, they hired mostly slide rule guys there, many of whom frankly couldn't get a job in industry, and most of these guys spent all their time testing designs to death. Literally. Test it long enough, and it goes away. Hence, in the mind of a government engineer, he's been successful. Doesn't have to sign a thing. Also, there has never been accountability of the Engineering and Certification Offices, so they could virtually jerk anyone around and get away with it.
At some point, FSDO Inspectors got fed up with it, and started field approving things that actually should have gone to engineering, but the FSDO guys knew that was the kiss of death, so they signed em off. In Alaska, there was actually a sort of quiet initiative to get as many airplanes legal as possible, recognizing that there were a lot of bootleg modifications out there with no paper on them. So, FSDO's got in the habit of signing off some pretty interesting stuff, and A & P mechanics got in the habit of submitting everything for a field approval, since then the FAA's signature is in the record, as opposed to the mechanic. This went to the extreme, and mechanics were trained by the FAA not to sign off anything as a minor with a logbook entry, but rather to submit a 337.
All of a sudden this change order comes down, and Inspectors are supposed to get concurrance of a PANEL prior to signing a 337 field approval. Part of the intent was that mechanics should assume the responsibility of signing things off as minors that really are minors, by definition.
Unfortunately, most Maintenance Inspectors will tell you anything but going to a different heat range on the spark plugs constitutes a major alteration.
So, now we are in a Catch 22: Mechanics should sign off a lot of stuff as minors, but they know if they do, it's likely that a Maintenance Inspector will see it, and take the mechanic to task for not field approving or STC'ing it. The FSDO guys may or may not sign off anything, cause they can always fall back on the guidance that mechanics should sign things off as minors, or if they aren't minors, they should be looked at by Engineering. Question is: Who are the lawyers going to come visit if anything goes south.
At least one FAA Engineer has been heard to say in a meeting fairly recently that the Engineering Office is understaffed, so they intend to simply hold everything till someone calls their Senator, at which time, Engineering will plead understaffed and get funded for more positions. Good grief.
But, everyone in the FAA can go home and pat themselves on the back, cause they've done their job: Pass the buck.
A good friend of mine who works for FSDO, and is a good guy told me some time ago that the FAA has a new, unofficial motto:
"We're not happy till you're not Happy".
As TJ noted, there are some really good, practical minded folks who work for the FAA, but leadership in that organization is terrible. I recently had conversations with a couple of "leaders" in FAA, and was appalled at the sophomoric attitude they had between three divisions of the FAA.
As to the Safety Program, it has completely changed. And, it has been a painfully slow process. Many if not most of the people who have been put in charge of the new program as Supervisors came from the 121 side. Hey, the airlines have a great safety record, right? So, all we have to do is get some of those folks over to the GA side, and we'll fix the safety record of GA right off.
I wish there were some good news, and I hope there is, but the FAA seems bent during the tenure of the last two Administrators, neither of whom were pilots, to politicize the FAA to the point where it is a do nothing, obstruct everything organization.
Light sport is the bright spot I can see, but that was purely politically driven. Good for the folks who were able to push it through, but....
Sorry for the rant.
MTV
Steve Pierce
BENEFACTOR
Graham, TX
Mike, The problem that I see is the FSDO doesn't want to accept their own regs. FSDOs won't accept data that is acceptable per their own handbook. They are not approving the engineering only accepting the data. I get a lot of Field Approvals all within the guidelines of the airworthiness inspectors handbook and the FARs. I get calls almost weekly from other mechanics in other FSDOs that can't get those approvals. What I see is a lot of military people with no GA experience getting hired in and don't know and won't do. Kinda like the inspector who wouldn't approve the shoulder harness installation and then was embarrassed when presented with the policy statement on shoulder harness approval. At least he was open minded though. If you point out the regs and guidelines to some inspectors that is your death sentence.
Dave Calkins
Registered User
Anchorage, Alaska
TJ, in what region is your IA friend with the Fed PMI problem? That PMI is NOT doing his job, and probably is does NOT know the rules. His supervisor needs a call ASAP.
I'm still getting approvals. The difference is that I do ALL the footwork instead of my PMI. Instead of just listing what the alteration encompasses on the back of the 337 and submitting it.........the "field approval checklist" and "compliance checklist" that accompany my Form 337 submission spell it all out again, including a list of the exact paragraphs from the 43. (which are already listed in my 337 block 8) and also including a list of the exact regulation the a/c was certificated under and paragraph the mod may affect (CAR3.279, or FAR 23. 155, etc, etc.).
Unless something changed last night approvals should still be coming my way, your way, and also to TJ's friend. Sounds to me like his friend has a PMI who does not know how to do his job.
I sure hope nothing changed last night!
I'm still getting approvals. The difference is that I do ALL the footwork instead of my PMI. Instead of just listing what the alteration encompasses on the back of the 337 and submitting it.........the "field approval checklist" and "compliance checklist" that accompany my Form 337 submission spell it all out again, including a list of the exact paragraphs from the 43. (which are already listed in my 337 block 8) and also including a list of the exact regulation the a/c was certificated under and paragraph the mod may affect (CAR3.279, or FAR 23. 155, etc, etc.).
Unless something changed last night
approvals should still be coming my way, your way, and also to TJ's friend. Sounds to me like his friend has a PMI who does not know how to do his job.I sure hope nothing changed last night!
Crash
GONE WEST
Nikiski Alaska
Fortunately for us, the PA-18 has most of the best mods, the ones you would want to do, already STC'd.
The only one I might want to do again is the extended leading edges on the wings, but I don't consider it mandatory for the plane to perform well. Other then that, everything I would want to do to a PA-18 is approved by an STC. Crash
The only one I might want to do again is the extended leading edges on the wings, but I don't consider it mandatory for the plane to perform well. Other then that, everything I would want to do to a PA-18 is approved by an STC. Crash
mvivion
SPONSOR
Bozeman,MT
Steve,
I know what it is that FSDO inspectors are supposed to do. My point was that they now essentially have sanction from above to just put it off on the mechanic, or on engineering.
Don't believe that's happening?
We are trying to get radio telemetry antennas approved on a Cub through one FSDO. The guy there says it would require a field approval, the airplane would have to go in the Restricted category, and that we really should get an STC. Now, that's after we showed him the External Load guidance for Alaska, which is signed by the Chief of the Flight Standards division in that Region, which specifically states that game tracking antennas are a minor alteration, and only require a logbook entry.
That's just one example.
Dave,
You CANNOT use what's happening in one FSDO to guage what may happen in another one. It's like night and day. Don't believe it? Try running something you're getting approved in ANC through the FAI FSDO, and see what happens. Sometimes there are vague similarities, most times, you'd think they all work for a different government.
MTV
I know what it is that FSDO inspectors are supposed to do. My point was that they now essentially have sanction from above to just put it off on the mechanic, or on engineering.
Don't believe that's happening?
We are trying to get radio telemetry antennas approved on a Cub through one FSDO. The guy there says it would require a field approval, the airplane would have to go in the Restricted category, and that we really should get an STC. Now, that's after we showed him the External Load guidance for Alaska, which is signed by the Chief of the Flight Standards division in that Region, which specifically states that game tracking antennas are a minor alteration, and only require a logbook entry.
That's just one example.
Dave,
You CANNOT use what's happening in one FSDO to guage what may happen in another one. It's like night and day. Don't believe it? Try running something you're getting approved in ANC through the FAI FSDO, and see what happens. Sometimes there are vague similarities, most times, you'd think they all work for a different government.
MTV
Dave Calkins
Registered User
Anchorage, Alaska
I think it's partly 'office policy' and partly how well the AMI's are trained.
Some of the guys here a willing to step right up to the edge of what is field-approvable, without fear, because they know where the line is. Some of the guys here will lock-up like WindowsME if a mechanic asks a tough question.
The point is: some of these guys know their stuff, and some of 'em know barely enough and end up bullying around their mechanics, then drop the "engineering" bomb on the guy.
That must be the training. These guys all go the the same classes in Oke City, right? I bet not all of 'em get good grades at those classes.
Sorry. I thought change 16 was supposed to 'level' the field. If the education were consistent, that would be so.
DAVE
Some of the guys here a willing to step right up to the edge of what is field-approvable, without fear, because they know where the line is. Some of the guys here will lock-up like WindowsME if a mechanic asks a tough question.
The point is: some of these guys know their stuff, and some of 'em know barely enough and end up bullying around their mechanics, then drop the "engineering" bomb on the guy.
That must be the training. These guys all go the the same classes in Oke City, right? I bet not all of 'em get good grades at those classes.
Sorry. I thought change 16 was supposed to 'level' the field. If the education were consistent, that would be so.
DAVE
mvivion
SPONSOR
Bozeman,MT
Dave,
Yep, I talked at length with the author of the change order, and he seems just about as amazed as everyone else.
Frankly, there is no leadership in the FAA, and no accountability, even considering their much vaunted "customer service initiative". Try that if you work in that district, and you'll never get anything else approved.
At least in some districts. Therein lies the problem: Inconsistency. What is airworthy in Anchorage should be airworthy in South Dakota.
MTV
Yep, I talked at length with the author of the change order, and he seems just about as amazed as everyone else.
Frankly, there is no leadership in the FAA, and no accountability, even considering their much vaunted "customer service initiative". Try that if you work in that district, and you'll never get anything else approved.
At least in some districts. Therein lies the problem: Inconsistency. What is airworthy in Anchorage should be airworthy in South Dakota.
MTV
Steve Pierce
BENEFACTOR
Graham, TX
Qualified applicant for airworthiness inspector starts out as a GS12 at $64,400 a year.
Mike, I am lucky that my PMI is the head AWI at the FSDO and has worked almost his entire life in GA. Amazing the difference in experimental and certified and what the saftey hazzard really is.
Mike, I am lucky that my PMI is the head AWI at the FSDO and has worked almost his entire life in GA. Amazing the difference in experimental and certified and what the saftey hazzard really is.
Dave Calkins
Registered User
Anchorage, Alaska
..........and they include the lobotomy.
bob turner
Registered User
A friend just sent me a blurb about a mechanic who was convicted for not adhering to a Lycoming service bulletin - on a part 91 aircraft. Opinion of blurb writer is that henceforth service bulletins regarded by the manufacturer as mandatory are the same as A/Ds.
Ain't no field approvals happening down here - they demand an STC - even if you already have acceptable data!
Ain't no field approvals happening down here - they demand an STC - even if you already have acceptable data!
Steve Pierce
BENEFACTOR
Graham, TX
Kase, That was for the DFW area.
Dave Calkins
Registered User
Anchorage, Alaska
HOly crap!
I'm screwed, I've got 2 FA's in the mix right now. A call is in order.
I know a DER, but he's a fresh one and limited to powerplant installations and a couple other small areas. $99/hour.
PS. Kase, if you knew me, you'd know I'm not the type.
....maybe if they become ''...kindler and gentler..." or more "...service-oriented..."
great!
I'm screwed, I've got 2 FA's in the mix right now. A call is in order.
I know a DER, but he's a fresh one and limited to powerplant installations and a couple other small areas. $99/hour.
PS. Kase, if you knew me, you'd know I'm not the type.
....maybe if they become ''...kindler and gentler..." or more "...service-oriented..."
great!
Pro from Dover
Registered User
Rhome, Texas
Field Approval
My PMI is in the same office as Steve Pierce's except his standard answer is no. As a result I've called the manager (Steve's PMI) and had to go around my guy. Regardless, I'm still getting field approvals accomplished.
We were looking at a field approval on a Bonanza recently and my PMI said he would do a field approval if we got a DER to do all of the front work. If that's the case we don't need the PMI. DER data is approved data.
My lament, is that if the PMIs are going to do less and less, then have less of them or pay them less. It seems that my guy spends an inordinate amount of time in training classes throughout the year. It also seems very apparent that the folks in OKC scare the yogurt out of these guys and encourage them to say no to any request. A PMI has reams upon reams of FAA Orders as guidance yet the A&P only has FAR 21, 23, 43, etc. Seems sort of odd...
Another thing I'd like to see is to have a central repository for all field approvals granted to help A&Ps support the fleet. Another spin would be that any field approval older than ten years to be considered approved data. That would be a big help.
How about this, have the FAA provide a decent search engine comparable with Tdata and Avantext that would help the aircraft shops eliminate the need to throw down $500-$1000 every year for AD search packages. Heck the FAA creates this stuff. Why do we need to support a third party and pass the charge on to our customer. They're paying taxes too...
I've heard somewhere that the FAA wants to be out of the FSDO business by 2012 or so. The FAA is also working on getting out of the Part 147 A&P school oversight business. I teach part time and the school folks are talking to the OKC and Wash. offices to accomplish that in the next few years. The FAA is also looking at a revamping of the Part 65 A&P certification. Not like the ill fated Part 66 but rather a different tack. Lots of working groups talking about that sort of stuff.
I don't think our taxes will go down though...
There, I feel better now...
My PMI is in the same office as Steve Pierce's except his standard answer is no. As a result I've called the manager (Steve's PMI) and had to go around my guy. Regardless, I'm still getting field approvals accomplished.
We were looking at a field approval on a Bonanza recently and my PMI said he would do a field approval if we got a DER to do all of the front work. If that's the case we don't need the PMI. DER data is approved data.
My lament, is that if the PMIs are going to do less and less, then have less of them or pay them less. It seems that my guy spends an inordinate amount of time in training classes throughout the year. It also seems very apparent that the folks in OKC scare the yogurt out of these guys and encourage them to say no to any request. A PMI has reams upon reams of FAA Orders as guidance yet the A&P only has FAR 21, 23, 43, etc. Seems sort of odd...
Another thing I'd like to see is to have a central repository for all field approvals granted to help A&Ps support the fleet. Another spin would be that any field approval older than ten years to be considered approved data. That would be a big help.
How about this, have the FAA provide a decent search engine comparable with Tdata and Avantext that would help the aircraft shops eliminate the need to throw down $500-$1000 every year for AD search packages. Heck the FAA creates this stuff. Why do we need to support a third party and pass the charge on to our customer. They're paying taxes too...
I've heard somewhere that the FAA wants to be out of the FSDO business by 2012 or so. The FAA is also working on getting out of the Part 147 A&P school oversight business. I teach part time and the school folks are talking to the OKC and Wash. offices to accomplish that in the next few years. The FAA is also looking at a revamping of the Part 65 A&P certification. Not like the ill fated Part 66 but rather a different tack. Lots of working groups talking about that sort of stuff.
I don't think our taxes will go down though...
There, I feel better now...
All,
My experience and short-term advice:
I have been run through the ringer by three inspectors at the local FSDO, threatened with criminal charges and 709 action and investigated and bullied for selling non-TSO'd shoulder harnesses.
However, after following the FAA's customer service initiative and being persistent with documentation and letters for the past 15 months (and receiving legal representation via PAMA) we are finally getting close to a resolution.
The long and short of it is that some FAA inspectors will "shoot off of the hip" and be wrong. The FAA management needs WRITTEN documentation to do anything about these renegade inspectors. This is where the Customer Service Initiative is mandatory. This is where persistence and documentation is mandatory.
Things can change. They seem to be changing at the local FSDO.
Vickie
My experience and short-term advice:
I have been run through the ringer by three inspectors at the local FSDO, threatened with criminal charges and 709 action and investigated and bullied for selling non-TSO'd shoulder harnesses.
However, after following the FAA's customer service initiative and being persistent with documentation and letters for the past 15 months (and receiving legal representation via PAMA) we are finally getting close to a resolution.
The long and short of it is that some FAA inspectors will "shoot off of the hip" and be wrong. The FAA management needs WRITTEN documentation to do anything about these renegade inspectors. This is where the Customer Service Initiative is mandatory. This is where persistence and documentation is mandatory.
Things can change. They seem to be changing at the local FSDO.
Vickie
Dave Calkins
Registered User
Anchorage, Alaska
Vickie, I'm sorry to hear that your FAI inspectors' incompetence had you in full 'defense' mode. It makes me angry to think of that. It almost seems personal. Remember what those 2 pigs did to Bob Hoover???
I'm glad to hear that you may end this story on a positive note.
I have a positive note to add. This shows that my regional FSDO is trying.
I called my PMI to find out where I stand on several approvals, but he's been outta town for a week and will be for another. The receptionist put me in touch with my PMI's supervisor, who allowed me to broach the subject of my field approvals to him. He said they are very busy with air carrier stuff, and probably wouldn't be able to asign another inspector so I'd have to wait another week. He however gave me a verbal go-ahead on my mods. About 10 minutes after hanging up with him, another "private" phone number showed on my phone. I have been asigned a different ASI to handle my stuff.....YEAH!!!
So, they're actually getting stuff done here, still.
It seems that they are so busy and feel their mission is air-carrier compliance issues, so my little shop's field-approvals are not at the top of the list.
I'll be shmoozing my DER friend and making other friends of other DER's.
I'm just glad that it's not my job to slow down all the aviating that I can until I retire with a pension and a plaque. Those guys have it hard.
DAVE
I'm glad to hear that you may end this story on a positive note.
I have a positive note to add. This shows that my regional FSDO is trying.
I called my PMI to find out where I stand on several approvals, but he's been outta town for a week and will be for another. The receptionist put me in touch with my PMI's supervisor, who allowed me to broach the subject of my field approvals to him. He said they are very busy with air carrier stuff, and probably wouldn't be able to asign another inspector so I'd have to wait another week. He however gave me a verbal go-ahead on my mods. About 10 minutes after hanging up with him, another "private" phone number showed on my phone. I have been asigned a different ASI to handle my stuff.....YEAH!!!
So, they're actually getting stuff done here, still.
It seems that they are so busy and feel their mission is air-carrier compliance issues, so my little shop's field-approvals are not at the top of the list.
I'll be shmoozing my DER friend and making other friends of other DER's.
I'm just glad that it's not my job to slow down all the aviating that I can until I retire with a pension and a plaque. Those guys have it hard.
DAVE
bob turner
Registered User
Hard to believe that shoulder harness problem, especially now that pre-1979 lightplanes can have SAE shoulder harnesses.
I heard a similar story - there is a guy who makes truly beautiful 5-point harnesses for the experimental crowd. As far as I am concerned, they are every bit as good as Hooker. As the story goes ( I cannot vouch for veracity) the feds told him there was no way he would ever get TSO (or PMA, or whatever), and then the fed he was dealing with retired and went to work for a seatbelt company.
Seatbelts ought to be easy - there should be a standard test, a quality control program, and market competition. My opinion.
I heard a similar story - there is a guy who makes truly beautiful 5-point harnesses for the experimental crowd. As far as I am concerned, they are every bit as good as Hooker. As the story goes ( I cannot vouch for veracity) the feds told him there was no way he would ever get TSO (or PMA, or whatever), and then the fed he was dealing with retired and went to work for a seatbelt company.
Seatbelts ought to be easy - there should be a standard test, a quality control program, and market competition. My opinion.
