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Major or minor.

Eddie Foy

MEMBER
South Florida
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).”
 
Eddie, use the flow chart in AC43.210A. Makes it easy to figure major/minor.


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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.

Eddie, use the flow chart in AC43.210A. Makes it easy to figure major/minor.


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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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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.

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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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
 
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.


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
 
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
 
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/


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
 
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.

337printout.JPG
 

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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.
 
Skywagon8a, that's what I was going to say....find me the place on a 337 where it says "minor repair" form. :roll:
John
 
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
 
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.
 
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.
 
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
 
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.
 
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.
 
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
 
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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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.
 
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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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.
 
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.

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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