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Thread: Major or minor.

  1. #1
    Eddie Foy's Avatar
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    Major or minor.

    Cessna 180 with EI MVP-50 engine analyzer. Can you legally install a Mitchell Oil press gauge as a secondary gauge? Does it require an STC? Is it a minor alteration with logbook entry or is a 337 required.

    According to 14 CFR 21.93, “A ‘minor change’ is one that has no appreciable effect on the weight, balance, structural strength, reliability, operational characteristics, or other characteristics affecting the airworthiness of the product. All other changes are ‘major changes’ (except as provided in paragraph (b) of this section).”
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    Eddie, use the flow chart in AC43.210A. Makes it easy to figure major/minor.


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    Eddie Foy's Avatar
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    Did that. My IA suggested the gauge then balked when it didn't come with an STC. I pitched the minor with logbook entry. He also seems to think that a minor requires a 337.

    I followed the tree and came up with minor/logbook. He was adamant that a minor requires a 337. I need backup to go back to him with.

    Quote Originally Posted by dgapilot View Post
    Eddie, use the flow chart in AC43.210A. Makes it easy to figure major/minor.


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    Last edited by Eddie Foy; 04-29-2019 at 03:28 PM.
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    Time to find another IA. I’ve got a presentation I give at IA seminars on Major/Minor if you want a copy. Send me a PM with your email.


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    Eddie Foy's Avatar
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    I am moving to Arkansas soon so won't have to use him again for annual. He does allow me to do almost all of my work under his supervision. That is worth alot.

    Email is lefoy84@yahoo.com.

    Quote Originally Posted by dgapilot View Post
    Time to find another IA. I’ve got a presentation I give at IA seminars on Major/Minor if you want a copy. Send me a PM with your email.


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    wireweinie's Avatar
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    You already have a 'certified' primary oil pressure gauge in the MVP. As long as that's operational and the requirements of the type certificate are met, the other gauge is just fun to have along. Log book entry only.

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  7. #7
    Eddie Foy's Avatar
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    Maybe he just had a brain fart. The gauge is in there. It is just not in the book. If the FAA is watching, my account has been hacked.


    Quote Originally Posted by wireweinie View Post
    You already have a 'certified' primary oil pressure gauge in the MVP. As long as that's operational and the requirements of the type certificate are met, the other gauge is just fun to have along. Log book entry only.

    Web
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    wireweinie's Avatar
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    Log entry: "Mitchell oil pressure gauge previously installed. Inspected installation and found it to be airworthy and meets the requirements of FAR 43 as a minor installation."

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    Eddie Foy's Avatar
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    I totally agree. What chaps my butt is that he recommended that I install it. I will show him all of these posts. I may just let it slide. Where I am going, there are two IAs on the field. Joe Edward's Airpark.

    http://cypresscreekairpark.com/


    Quote Originally Posted by wireweinie View Post
    Log entry: "Mitchell oil pressure gauge previously installed. Inspected installation and found it to be airworthy and meets the requirements of FAR 43 as a minor installation."

    Web
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    skywagon8a's Avatar
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    Quote Originally Posted by Eddie Foy View Post
    He also seems to think that a minor requires a 337.

    I followed the tree and came up with minor/logbook. He was adamant that a minor requires a 337. I need backup to go back to him with.
    Show him the top of this. Ask him what those four words in caps says. Particularly the first word.

    Click image for larger version. 

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    CenterHillAg's Avatar
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    Secondary oil pressure gauges are one of those things where you shrug and say, “I don’t know, it was in there when I bought it.” That’s one I gauge I always like to have as analog.

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    Skywagon8a, that's what I was going to say....find me the place on a 337 where it says "minor repair" form.
    John
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    The 337 is sort of weird. It has three or four different functions. I think I had my IA for over two years before I really understood it - and now, even though I am not turning a wrench full time, I see badly executed 337s all the time.

    Believe it or not, the most common is a major alteration without approved data. Some IAs think they can approve a major alteration.

    The FSDO has never been much help. My first 337 was for an instrument panel change - a minor alteration. Did the FSDO bounce it back? No. Did they file it with OKC? Doubtful. I should check.

    IAs are like the rest of us - average IQ is 100. Half are not that smart.

    opinion
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    Quote Originally Posted by Eddie Foy View Post
    I am moving to Arkansas soon so won't have to use him again for annual. He does allow me to do almost all of my work under his supervision. That is worth alot.

    Email is lefoy84@yahoo.com.
    Dont you have too many teeth left to move to Arkansas?

    MTV
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    I'm going to marry my cousin and move in with her. Her name is Paula Jones.
    Quote Originally Posted by mvivion View Post
    Dont you have too many teeth left to move to Arkansas?

    MTV
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    Just make sure your house has wheels on it and dogs under it
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    I am sure nobody even reads the 337s when they get to OKC nowadays. There is an Aeronca that was recovered in Polyfiber by the non A&P owner under an IA's supervision. Supervision is an extremely poor word choice for this occasion. IA told the owner to fill out the 337. Owner asked what to put on it. "Copy each page of the polyfiber manual and include that with the 337". Guess what is in the records for that Aeronca? Yup. The Polyfiber manual.
    You can't get there from here. You have to go over yonder and start from there.
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    Quote Originally Posted by Eddie Foy View Post
    I am moving to Arkansas soon so won't have to use him again for annual. He does allow me to do almost all of my work under his supervision. That is worth alot.

    Email is lefoy84@yahoo.com.
    If you got a job flying out of Mena you're gonna need more and bigger airplanes.
    You can't get there from here. You have to go over yonder and start from there.
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  19. #19
    Eddie Foy's Avatar
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    My days of flying for hire are long gone!
    Quote Originally Posted by N86250 View Post
    If you got a job flying out of Mena you're gonna need more and bigger airplanes.
    "Put out my hand and touched the face of God!"

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    Speaking of IAs, here's one for the books.

    Scheduled a test flight today in a sort of tired looking 170. It hadn't flown for a decade, but I was ready - fresh fuel, fresh annual . . .

    But before climbing in, I decided to look at the logs. No entries - none! There was an invoice - 12 hours to get paperwork squared away, and a lot of notes and receipts on 8 1/2x11 sheets, including an unsigned annual.

    Owner said the IA was waiting for a test flight before signing.

    So we called the IA - "I am in a meeting - will get right back to you." That was 3 1/2 hours ago.

    I have no problem with a mechanic's signature on a separate sheet. You can scratch a legal document on a tractor fender - but the local FAA has problems with entries made on loose sheets of paper. I personally need to see some semblance of a signature on a log entry before I climb aboard. I think the insurers do too.

    No wonder the FAA wants IAs to have some recurrent training.
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  21. #21
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    Quote Originally Posted by bob turner View Post
    Speaking of IAs, here's one for the books.

    Scheduled a test flight today in a sort of tired looking 170. It hadn't flown for a decade, but I was ready - fresh fuel, fresh annual . . .

    But before climbing in, I decided to look at the logs. No entries - none! There was an invoice - 12 hours to get paperwork squared away, and a lot of notes and receipts on 8 1/2x11 sheets, including an unsigned annual.

    Owner said the IA was waiting for a test flight before signing.

    So we called the IA - "I am in a meeting - will get right back to you." That was 3 1/2 hours ago.

    I have no problem with a mechanic's signature on a separate sheet. You can scratch a legal document on a tractor fender - but the local FAA has problems with entries made on loose sheets of paper. I personally need to see some semblance of a signature on a log entry before I climb aboard. I think the insurers do too.

    No wonder the FAA wants IAs to have some recurrent training.
    Bob,

    Doesn't sound like training is the issue there.....sounds like he knows exactly what he's doing.

    MTV
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    skywagon8a's Avatar
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    Quote Originally Posted by mvivion View Post
    Bob,

    Doesn't sound like training is the issue there.....sounds like he knows exactly what he's doing.

    MTV
    There are provisions for this sort of thing. The IA should have signed the log for what he did along with mentioning that he gave the owner a letter stating that a test flight needed to be completed. After the test flight the owner would sign the log and the annual would then be complete.
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    Quote Originally Posted by skywagon8a View Post
    There are provisions for this sort of thing. The IA should have signed the log for what he did along with mentioning that he gave the owner a letter stating that a test flight needed to be completed. After the test flight the owner would sign the log and the annual would then be complete.
    And a test flight is only needed before carrying passengers.


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    Okay - that makes sense. Let’s see if the IA will do that. I would be comfortable with that approach, but not testing before a signature.

    I learn stuff every single day here.
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    Quote Originally Posted by skywagon8a View Post
    There are provisions for this sort of thing. The IA should have signed the log for what he did along with mentioning that he gave the owner a letter stating that a test flight needed to be completed. After the test flight the owner would sign the log and the annual would then be complete.
    Yes, but that wasn't the case, according to what Bob wrote......

    MTV
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    Remember, a mechanic “approves” the aircraft for service (43.9), the pilot is the one that actually returns it to service (91.7).

    “Test flight” requirements are in 91.407(b). Note that 91.407 (a) requires the maintenance record entry BEFORE operation of the aircraft.


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    skywagon8a's Avatar
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    Quote Originally Posted by mvivion View Post
    Yes, but that wasn't the case, according to what Bob wrote......

    MTV
    Well it really was Mike. A verbal from the IA to the owner that it needs a test flight first before signing, is the same as not signing anything, as not even doing the inspection. If the owner crashes on his test flight without any signatures from the IA, then the IA is off the hook and the owner is in violation for flying an aircraft which has an expired annual inspection. The IA is required to sign for his inspection with a list of the unairworthy items. He also is supposed to supply the owner with a letter listing the unairworthy items. In this case a test flight to determine (whatever he felt needed determining). Then the "test" pilot signs the log saying that he flew it and found it satisfactory. After that the annual is complete. In this example it is the "test pilot's" signature that declares the airplane airworthy and the annual complete. No a verbal without a signature does not an airworthy airplane make.
    An annual sign off does not have to say that the airplane is airworthy.
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    Major or minor.

    Quote Originally Posted by skywagon8a View Post
    Well it really was Mike. A verbal from the IA to the owner that it needs a test flight first before signing, is the same as not signing anything, as not even doing the inspection. If the owner crashes on his test flight without any signatures from the IA, then the IA is off the hook and the owner is in violation for flying an aircraft which has an expired annual inspection. The IA is required to sign for his inspection with a list of the unairworthy items. He also is supposed to supply the owner with a letter listing the unairworthy items. In this case a test flight to determine (whatever he felt needed determining). Then the "test" pilot signs the log saying that he flew it and found it satisfactory. After that the annual is complete. In this example it is the "test pilot's" signature that declares the airplane airworthy and the annual complete. No a verbal without a signature does not an airworthy airplane make.
    An annual sign off does not have to say that the airplane is airworthy.
    If the annual sign off doesn’t say it is airworthy, it’s not legal to fly it, other than on a Special Flight Permit, and there is no SFP purpose to do a test flight. You would need to go Experimental Show Compliance. There can’t be a test flight with unairworthy items (legally). All items need to be signed off or the airplane doesn’t meet the requirements of 91.409 for an annual. An IA or mechanic can’t tell an owner the aircraft needs a test flight. The owner or pilot needs to determine if he needs to comply with 91.407(b), and there is nothing in an inspection (by itself) that would trip that requirement. A mechanic can say a flight that meets 91.407(b) needs to be done before carrying passengers, but that is the only thing a mechanic can say regarding test flight. The only limitation is “before carrying passengers”.

    Years ago I had an argument with the guys in Cirrus engineering. The shop I was running did a repair on the leading edge of a Cirrus. The 8110-3 DER approved repair said that a test flight needed to be done by a Cirrus test pilot. I told them that as long as that requirement was on the repair, it could not be done with the aircraft holding a Standard Airworthiness Certificate since I couldn’t sign off the repair until the flight was complete and the airplane didn’t comply with 91.407 without a sign off. I ended up putting the airplane in Experimental Show Compliance to satisfy the test flight, and the owner was unhappy now that his nice shines Cirrus not only had damage history, but the record also showed that it held an Experimental certificate, if only for a few hours.


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  29. #29
    skywagon8a's Avatar
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    I'll have to bow out of this discussion. Years ago I had an airplane which needed a permanent airworthiness certificate issued since it had been in storage since the early 1950s. There was one item which required a flight before it could be signed off. At this time I can't recall what that was. Something to do with the Hartzell controllable props I think. I signed off the annual with that one discrepancy, issued the letter and the FAA issued a permanent airworthiness certificate. Then the test flight was done. I do not recall any special airworthiness being issued for the flight.
    The sign off only said that the annual inspection had been accomplished except for...... Nothing about being airworthy.
    N1PA

  30. #30
    Eddie Foy's Avatar
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    That is the way it is in the Air Force. If an aircraft undergoes some major maintenance like a double engine change on an A-10, mx will sign it off as airworthy but it requires a test flight by a pilot that is qualified to do them. Only then is it returned to the schedule.

    Quote Originally Posted by dgapilot View Post
    Remember, a mechanic “approves” the aircraft for service (43.9), the pilot is the one that actually returns it to service (91.7).

    “Test flight” requirements are in 91.407(b). Note that 91.407 (a) requires the maintenance record entry BEFORE operation of the aircraft.


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    All of this information is useful.

    Does the owner have any recourse if this guy refuses to sign any of the work he did, or the annual?

    And is a typed name enough with an IA #, or does there have to be some version of a signature? Now that I look at these great responses, I am sorry I didn't start a new thread.
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    Quote Originally Posted by bob turner View Post
    All of this information is useful.

    Does the owner have any recourse if this guy refuses to sign any of the work he did, or the annual?

    And is a typed name enough with an IA #, or does there have to be some version of a signature? Now that I look at these great responses, I am sorry I didn't start a new thread.
    Requires a signature. 43.9 and 43.11 both require the mechanic to make a record entry with his signature and certificate number. Years ago, a fellow mechanic/IA wouldn’t sing off on work he had done because the owner wouldn’t pay him. The guy lost his certificates for violation of 43.9. Not only didn’t he get paid, but he was out of work for 3 years until he could get his IA back. Not getting paid is a civil matter to be taken up with the local courts. Signing for work done on an airplane is an FAA matter.

    Only recourse is to turn him into the feds.


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    Hardtailjohn's Avatar
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    As long as the mechanic doesn't approve it for service in accordance with 43.9, I wouldn't think there's one damned thing they can do.
    John
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  34. #34

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    I was gonna point out
    §91.409 Inspections.

    (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had—
    (1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by §43.7 of this chapter; or

    If it hasn't been inspected in years it needs a signature before it is legal to fly. FAA ferry permit or IA sign off it has to have a signature.
    You can't get there from here. You have to go over yonder and start from there.
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    I believe a mechanic is obligated by law to sign if he has done "work." An inspection is not "work" in that sense, so I suppose a mechanic can get through an inspection and simply say NO.

    I am not sure of that.

    Instructors are under the same obligation. I made a student insist on a signature in one of those neat group ground instruction events. The ground school said NO, so I sent the student back with the FAR in hand. He got his signature.
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    I am wrong. The mechanic is required to enter work done, but a signature is only required if the aircraft is released to service:

    43.9
    (4) If the work performed on the aircraft, airframe, aircraft engine, propeller, appliance, or component part has been performed satisfactorily, the signature, certificate number, and kind of certificate held by the person approving the work. The signature constitutes the approval for return to service only for the work performed.
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    43.11 seems to require a signature one way or the other. Not sure of that; I shall re-read the whole thing.

    (a) Maintenance record entries. The person approving or disapproving for return to service an aircraft, airframe, aircraft engine, propeller, appliance, or component part after any inspection performed in accordance with part 91, 125, §135.411(a)(1), or §135.419 shall make an entry in the maintenance record of that equipment containing the following information:
    (1) The type of inspection and a brief description of the extent of the inspection.
    (2) The date of the inspection and aircraft total time in service.
    (3) The signature, the certificate number, and kind of certificate held by the person approving or disapproving for return to service the aircraft, airframe, aircraft engine, propeller, appliance, component part, or portions thereof.

    Emphasis is mine. "Shall" means the same thing as "must."

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    Quote Originally Posted by Eddie Foy View Post
    I'm going to marry my cousin and move in with her. Her name is Paula Jones.
    Welcome to 'The Natural State' ! The house trailer, inbreeding and dogs under the house are nice but optional. Don't get caught in a situation requiring you to
    'call the hogs' and not be up to speed, though. (Trust me.)

  39. #39
    mvivion's Avatar
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    Quote Originally Posted by skywagon8a View Post
    Well it really was Mike. A verbal from the IA to the owner that it needs a test flight first before signing, is the same as not signing anything, as not even doing the inspection. If the owner crashes on his test flight without any signatures from the IA, then the IA is off the hook and the owner is in violation for flying an aircraft which has an expired annual inspection. The IA is required to sign for his inspection with a list of the unairworthy items. He also is supposed to supply the owner with a letter listing the unairworthy items. In this case a test flight to determine (whatever he felt needed determining). Then the "test" pilot signs the log saying that he flew it and found it satisfactory. After that the annual is complete. In this example it is the "test pilot's" signature that declares the airplane airworthy and the annual complete. No a verbal without a signature does not an airworthy airplane make.
    An annual sign off does not have to say that the airplane is airworthy.
    My point was, at the very least I'd want the IA to sign something to the effect that the plane is "safe" to test fly. No way I'd get in an airplane that a mechanic is afraid to put his signature in the logbooks......

    MTV
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    Me neither. But if a guy holds himself out to be an IA, and the owner lets him do almost all the things he wanted (he did not do a prop overhaul, but he wanted to because of the "age" of the fixed pitch prop), then at the end he should be prepared to sign something.

    I did not follow all the scraps and invoices, but apparently he did 4500 bucks worth of work, not counting the new weigh-in, which he sub-contracted.

    I was a bystander - but I was uneasy about the process. I have been neighbors with the dad for 40 years, and was willing to fly the bird. They put in all new fuel, a new gascolator, did a 45 minute ground run, changed the brake fluid, borescoped . . . If it all goes south, I will look at the scraps of paper to see exactly what was done. If he signs the annual with a "list" requiring the test flight, I will test it.
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