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Field Approvals

Here is some thing that our Fsdo put out at a meeting worth a try
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I did a number of 337s last fall on a TriPacer ground up rebuild exactly as outlined in this circular and filed them with the FAA in OKC. Some of the mods were approved STCs, but about half were based on previous field approvals that we copied and supplied as approved data. None were rejected or returned. We didn't even talk to the local FSDO. The process as outlined in AC 23-27 worked for us. This Circular covers "Substantiating parts or materials substitutions to maintain the safety of old and out of production aircraft".

-CubBuilder
 
Cub Builder, Who approved your field approvals? My understanding on filing 337s with OK City was ones not requiring a field approval. OK City simply files them. What modifications were your 337s on?
 
I guess I didn't explain that very well. We were using data from previously approved field approvals. Wrote that data up on the 337s referencing the previous approval for a like aircraft and supplied a copy of the 337 where the data was originally approved as an attachment to the 337s we filed.

As I'm sure you know, a field approval 337 will have the inspectors name, the approving FSDO and date of approval on it. Once you have a copy of the 337 with that data, you can copy it, reference that data, and do the same mod to the same model of aircraft using the data from the old 337 to demonstrate that the FAA has already approved the data.

Some clubs like the short wing Pipers or some people selling plans for mods will supply a copy of a 337 with their field approval, which can be copied and used as approved data. And of course you can get copies of the 337s on any aircraft from the FAA, so they can also be had that way.

So as to be clear on this, I am not an IA. I did the paperwork and wrote it up as the mechanic of record, then had the work inspected and the 337s signed by the one of the IAs I work with. I would have to go look at my records from this TriPacer, but I would guess we filed 5 or 6 337s using a previously approved field approval as the approved data. Maybe it will come back to bite me in the butt some day, but I believe I did exactly what is outlined in AC 23-27.

-CubBuilder
 
You might want to check with your FSDO on this. Previously approved 337s are acceptable data, not approved data, you still have to have the FSDO Inspector sign the 337 as a field approval.
 
I guess I didn't explain that very well. We were using data from previously approved field approvals. Wrote that data up on the 337s referencing the previous approval for a like aircraft and supplied a copy of the 337 where the data was originally approved as an attachment to the 337s we filed.

As I'm sure you know, a field approval 337 will have the inspectors name, the approving FSDO and date of approval on it. Once you have a copy of the 337 with that data, you can copy it, reference that data, and do the same mod to the same model of aircraft using the data from the old 337 to demonstrate that the FAA has already approved the data.

Some clubs like the short wing Pipers or some people selling plans for mods will supply a copy of a 337 with their field approval, which can be copied and used as approved data. And of course you can get copies of the 337s on any aircraft from the FAA, so they can also be had that way.

So as to be clear on this, I am not an IA. I did the paperwork and wrote it up as the mechanic of record, then had the work inspected and the 337s signed by the one of the IAs I work with. I would have to go look at my records from this TriPacer, but I would guess we filed 5 or 6 337s using a previously approved field approval as the approved data. Maybe it will come back to bite me in the butt some day, but I believe I did exactly what is outlined in AC 23-27.

-CubBuilder

Thats not how it works, you then need to get ANOTHER feild approval based on the old field approvals. You cant just send them in. Yes no one reads them in Ok.. but you dont have legle 337 without a new stamp in that block......
 
Thats not how it works, you then need to get ANOTHER feild approval based on the old field approvals. You cant just send them in. Yes no one reads them in Ok.. but you dont have legle 337 without a new stamp in that block......

Interesting. It may come back to bite us on the butt at some point in time. I guess the confusion comes from the wording on page 7 paragraph 4 of AC 23-27 where it says you can use a previous field approval as the "basis" for approval on your aircraft. It implies that it should be approved, does not clearly state that it is approved. Thanks for the interpretation. I know many are interpreting that as it "is" approved, as doing the paperwork that way was was recommended and signed by the IA we used.

-CubBuilder
 
I have only read 23-27 about a dozen times. Some very bright folks believe that previous field approvals are in fact approved data for these aircraft - I am not yet convinced, but have an open mind.

The A/C explicitly says you can use automotive hydraulic hoses with a logbook entry. It also says that it itself is approved data, but does not really explain what that means. The body is confusing, but it, along with Order 8100.1 seem to indicate that the ASI should be approving substitution field approvals.


Opinion: with documents like this, be careful about making definitive statements. One IA may interpret them one way, and another IA may see things differently. Ambiguous writing does not lend itself to certainty.
 
Here is a reference from a meeting in Nashville Tn i have spoke to the inspector before we sent in the 337 for the B&C alternator and he said fill out 337 let IA sign off put all ready approved 337 in its complete form with my 337 and mail it to OKC and its done


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I can see that for parts, but not changes.

So can I replace the J-5 elevator system with the PA-18 elevator system as it says in that article? I already have a letter saying I can use the J-3 STC as data and another previously approved 337 for the same mod- but told I cannot get it approved.

Tim
 
Approved data means no field approval. Acceptable data, or a basis for approval, generally means an ASI has to sign it. But if you get a letter from an ASI allowing a differnt interpretation, you are probably golden.

You can mail anything you want to OKC - they just file it, probably using temp workers or something. My FSDO used to review my 337s, and would often pick up minor errors. They refuse to do that now. It is a strange form - you have to sign and date it twice. They want to be sure you are sure. Or something.

So if you choose to interpret aomething in your favor - say, like the word "basis" in a document that says it is approved data if you do exactly as it says, and send the 337 to OKC, then nobody will probably ever challenge you - even if the rest of the world disagrees with your interpretation.

Opinion.
 
It says you may use those approvals as the basis for the approval on your aircraft. I have sat in many meetings with the people who drew this AC up and I think people are reading things into it. Seems pretty straight forward to me.
 
I disagree - the appendices are straightforward, but the main body is written to cause confusion, and as you can see, it has caused confusion.
 
Ok the FAA folks told me that for repairs, previous field approvals can be used as approved data, but for Modifications they can only be "acceptable data". seems confusing. But I know that you can't just copy an old field approval as data and send it in without a new stamp in box 3. That practice used to be common but always has been illegal. I'm surprised any IAs would sign off on that now. maybe in the 1980s. I've seen many older Piper's rebuilt with nothing but copies of other plane's 337s as data...even for the STCs......not legal...never was.
 
Caveat: pre some date around 1955 337s are approved data. Certain other categories of 337s are approved data. Repairs done in accordance with 43-13 or manufacturer drawings (major repairs) are approved data, and the 337 goes to OKC without the stamp in block 3. If it is approved data it does not need the ASI approval.

Opinion.
 
Bob, Repairs done via 43-13 would not need a field approval. Aircraft got new airworthiness certificates every year up until 1956 or so. Therefore they see any modification done prior to that date approved data. You can also lose your Airworthiness Cert. and have them inspect your airplane and issue another one. At that point any mod done is approved. This could be a catch 22 but a long time DAR told me about this method.
 
It says you may use those approvals as the basis for the approval on your aircraft. I have sat in many meetings with the people who drew this AC up and I think people are reading things into it. Seems pretty straight forward to me.[/QUOTE

My own "opinion" is that Steve is correct. Very strightforward and clear. I've already done it with no problems. In fact I remember after my first reading of the AC thinking, "WOW! Something from the Feds that makes perfect sense and is very easy to understand."
 
Well, I agree with Ole Bob, but when you haul an approved 337 in there and ask the ASI if he will stamp it on the basis of that prior field approval, does he have to? AC 23-27 could be interpreted that way.
 
Let's not lose this thread. I am about to press the issue gently - my latest application has been "in" for over two months, with no official response, and has been pawed over by three ASIs.

What would help me is contact with some friendly person who was in on the 23-27 deal. My PMI is saying unofficially that they cannot do it if the block on that figure says ENG or STC. My interpretation is that it should be on a case by case basis, using ACs as a guide.

The FAA really shoud be giving us better guidance. Either do away with field approvals, or make it so they have to give us a written response with precise reasons, and an appeal process.
 
Tim,
Down here in Maine our FSDO won't even hear about fiel approvals. Been that way for some time

Good luck. Joe
 
Well, I agree with Ole Bob, but when you haul an approved 337 in there and ask the ASI if he will stamp it on the basis of that prior field approval, does he have to? AC 23-27 could be interpreted that way.

It is my understanding that an ASI does not "have to" sign any field approval if he/she does not want to. It is their personal choice. It could be because there is something wrong with the application or just as simple as "I don't want to". In the latter case take it to the guy at the next desk. If you are sure that your application is valid, keep it moving up the rungs of the ladder.

Let's not lose this thread. I am about to press the issue gently - my latest application has been "in" for over two months, with no official response, and has been pawed over by three ASIs.

What would help me is contact with some friendly person who was in on the 23-27 deal. My PMI is saying unofficially that they cannot do it if the block on that figure says ENG or STC. My interpretation is that it should be on a case by case basis, using ACs as a guide.

The FAA really shoud be giving us better guidance. Either do away with field approvals, or make it so they have to give us a written response with precise reasons, and an appeal process.

It is my understanding, I don't have the AC in front of me, that if the block says ENG or STC then the FSDO guy, who has been asked to field approve the 337, should be the one to contact engineering. Engineering will then either approve or provide guidance towards completion. This has been my experience in the past.

The application having been "in" for over two months with no response is inexcusable. I though that they were supposed to act within 30 days. I once installed a set of floats on a plane that had been approved on that same type of plane on a 337 which was dated prior to that cutoff date in 1955. Three months after I sent in the 337 my PMI called and told me he needed to inspect the installation. He came and looked it over and pretended to be reading the log books. Then he said that he didn't feel comfortable and would not approve the 337. I called a friend, who happened to be the regional director at the time. The 337 was approved and the PMI mysteriously transferred to Singapore. Don't read anything into this. I'm just saying.
 
anyone hear if the 'new' changes have been made yet?? as of a week or so before AK trade show the FAA guy I spoke with said Washington was a week or two away from having new rules written/worked out..... anyone know where to look?? do they get put up on the fed register or such???
 
Steve - the handbook, like most stuff of this nature, is anything but "cut and dry". 8100.1 clearly states that each application should be considered on a case by case basis, and references AC 23-27, in addition to stating that the ASI should use ACs to make decisions.

The handbook indeed says that if an applicant thinks the restrictions of figure 4-65 do not apply, he can ask the ASI to call or e-mail the ACO for guidance. A telephone call can get around the restrictions.

If the FAA intends to not issue field approvals, they shoud just be honest about it and say so.
 
Thanks to Mike for finding this - I searched for "field approvals" in the title, and this one did not come up.

AC 43-210 is an interesting document - it says, first, that statements containing " shall" and "will" reflect "regulatory intent" , whatever that is, and goes on to say that a field approval request can be denied for only one or more of four stated reasons. It says the ASI "will" respond in writing with a stated reason.

But if they can ignore AC 23-27, which is "approved data", then they can surely ignore one that speaks of "regulatory intent".

Opinion.
 
8100.1 has a cut and dry check list of what can and can not be approved, what must go to engineering and what needs an STC. If it is addresses in that check list/flow chart then I am going to push till it is done.I arm myself with their own documents. I asked before and never got an answer,what are you trying to field approve?
 
any updates?????....

only heard something about a 5? step process now?? with your local AND DC feds???? 90 DAYS to find out if it will be approved or NOT!
 
Mike:
Basically, what they are telling us is, forget it. They do not want to do field approvals and they will not do them. They will make the rules/regulations so complicated no one will be willing to pay for the paperwork. Your guvment at work.
However, you can be assured, the suits and the PC correct bureaucrats in DC are doing a hell of a good job of passing rules/regulations to protect the flying public! Yea Right!
How many years have we been doing field approvals under the old rules/regulations? Did it work? I think it did.
Their primary purpose to is to protect their jobs. Period.
Most of the folks that write the rules/regulations wouldn't know a PA-18 from a Cessna 150. But, they know enough to write regulations controlling the issuance of field approvals for these planes. That is impressive!
Wish I was that smart.:wink:
Forget the field approvals, its a done deal.
 
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