This came today from my PMI. Thought that you all might be interested. He also attached several pdf files which I don't know how to attach to this post.
I realize this may not apply to all of you but, in case you find a need to request a field approval, I hope this will help. I know it’s a lot of info, but if you can get through it; it will speed up the process for us, and you too. Attached is guidance we now use for major alterations. The 337 data package should be reviewed and approved by the FSDO before beginning work.
Data Package:
Complete the 337 with the 16 elements as shown in figure 5-1 of 8300.16 (see note on page 20), provide all drawings and approved data to complete a Field Approval data package. Fig 3-1(page 4) is a flow chart that shows the approval process overview. (I attached a sample 337 with an acceptable format, more or less depending on the alteration, but it must have the 16 ICA elements or it will be returned).
The FAA will then use the Major Alteration Job Aid to determine if it can be field approved, requires an STC or will be a coordinated field approval with the ACO (Aircraft Certification Office). This document is found on-line via a hyper-link in order 8300.16. (All copies attached is subject to revision).
If your proposed alteration/repair will require engineering evaluation it is referred to as a
coordinated field approval. This is determined by the Major Alteration Job Aid (located on page 13 for Normal category aircraft, Operational Characteristics, item D5; which is attached above and also can be accessed via this link:
http://www.faa.gov/about/office_org/headquarters_offices/avs/offices/afs/afs300/ ). Include enough information for the engineers at the ACO to be able to make a determination. If they find the alteration acceptable they will provide you with a Memorandum that will become part of the 337.
Additional Information:
DER Note: The FAA inspector does not have to approve an alteration on a 337 as long as a DER has substantiated ALL of the elements of the alteration (8300.16 Chapter 2). (It will be noted on the 8110-3 whether the data is approved for the
entire alteration or not. If not, then the DER approved data (8110-3) will not be for the installation portion of the alteration. It will then require field approval which will complete the process. If the 8110-3 includes ALL elements of the alteration,
including the installation, it does not need to be sent to the FSDO for field approval).
NOTE: FAA Order 8110.37 addresses field approvals by reinforcing that DERs are not authorized to perform them. It also recommends including a note in the body of FAA Form 8110-3 that states, “This approval is for engineering design data only and is not an installation approval.” This does not prevent the data from being used as the basis for a major alteration or repair. When sufficient DER data has been obtained, the approval process applicable to the alteration is complete; the product can then be inspected for conformity and approved for return to service. The person performing the alteration, rather than the DER, is then responsible for conforming and approving the installation. DER data is not a field approval, but is approved data that, like other approved data, can be used in the performance of major alterations or repairs without further approval if the data addresses the entire alteration or repair. In this case, you do not need to request a field approval from the FAA. FAA Order 8300.16 provides guidance on this subject and is available at
http://www.airweb.faa.gov/rgl.
Advisory Circular 43-210 is still referenced in the FAA Order and has a field approval check list in Appendix 1.
Appendix 2 of AC 43-210 contains a sample compliance checklist. Use this list when reviewing applicable regulations to show compliance in the alteration. It takes some research, but will ensure that the data package will be less likely to be rejected when you submit it.
A 337, incorporating an STC as approved data, does not need to be sent to our office (for approval) as long as it is approved for that aircraft via S/N, N-number or on the approved model listing; however, it still needs to include the 16 ICA elements.
A minor alteration as defined, does not require a 337. See 14 CFR 43 Appendix A for major alterations and repairs to airframe, propellers, powerplants and appliances.
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Principal Maintenance Inspector
Federal Aviation Administration