Is a Field approval good forever?

[Helmetfire]

I have a Super Cub that had 30-52N Brakes and 40-75D wheels installed. (Cessna 180 wheels/brakes). I removed those and installed the 199-62 wheel/brake kit from ABI which are basically the same thing.

Now for the legal part.... my logs aren't complete for the airframe, but a look on the FAA CD shows a field approval back in '89 for the "inspection of previous installation" of the aforementioned C-180 wheels/brakes. The only catch is, that was prior to being exported to Japan, AND it had a different tail number than it does now. (The serial number is the same)

The FA stamp in block 3 of the 337 reads like this:
The data/alteration herein complied with the applicable (the word Alteration is crossed out)
airworthiness requirements and is approved only for
the above described aircraft subject to conformity
inspection by a person authorized in FAR 43.7

The description in block 8 reads:
Inspected installation of previous installed 8:00x6 tires on Cleveland 600x6 wheels p/n 40-75D with
Cleveland brakes p/n 30-52N. This combination of wheels, tires brakes has been previously approved for
installation on other conventional type aircraft (Cessna 180)

So the question is: Can I install the 199-62 kit as a direct replacement for the C-180 wheels/brakes with a log entry citing previous approval?? Or do I need to buy the $265 Dodge STC for the installation?? I actually already bought the STC, but later found the FA...Airframes will give me my money back for the STC if I don't need it.

Thanks.

 

[skywagon8a]

The alteration is already approved on that airplane. You only need a log book entry for what is now a minor alteration.

 

[bob turner]

I partly agree. A Field Approval means that a major alteration is approved for that airplane - forever. It remains a major alteration, so you need a 337 every time you either alter or unalter. The difference is that, since it is already approved, you no longer need an FAA stamp in block 3 every time you change.

 

[wireweinie]

As long as you replace parts with the same part numbers, it's a log book entry. If you replace the 30-52N with, hypothetically, 30-52X assemblies, I would simply sign it off in the log book. Minor variation as long as fit and function are the same.

Web

 

[bob turner]

That is correct. Somehow I mis- interpreted your question. If you remove the Clevelands and put, say, 8:00x4s on it, you need a 337 for the alteration, since it is major. You can then return to the Clevelands any time you want, but it takes another 337. Most ignore it - but it is just like going back and forth on floats and skis - technically each time is a 337.

 

[S2D]

Bob
I have to disagree. It was a major alteration to get the initial modification. Now it is a minor to change back and forth. Case in point is skis, spray system, bushwheels and regular wheels etc. You don't have to make out a 337 each time you change. Just a logbook entry.

 

[bob turner]

Okay. I could be wrong. My impression is that each time a major repair or alteration is performed a 337 is required. When I remove my STC spades, I have made a major alteration, and must file a 337. Same when I put them back on.

I am not sure how a major alteration can become minor when it is removed. The definition of major/minor does not seem to have this kind of distinction

I will check further - I hate to be the possessor of incorrect info, let alone a poster of it.

 

[bob turner]

PS - checking with my PMI. He is not the last word, but better than mine.

 

[wireweinie]

If my airplane is on wheels, it is there because the manufacturer's data has been approved. When I install other wheels, skis, floats, etc and do so with a field approval, this becomes approved data for that particular aircraft. Therefore you can change between wheels and floats, for example, with a log entry. No further 337's are required.

Web

 

[bob turner]

So a major alteration becomes a minor something (Alteration? Repair? Change?) because there is approved data? Good to know. Next time I recover, I do not need a 337? Again, I may be totally screwed up here - probably time to get me straightened out.

 

[Gordon Misch]

Bob, My thought would be just implementing a previously approved 'configuration' rather than making an 'alteration', therefore logbook only? Sorta like doing a configuration change IAW the TCDS, it's already approved for the aircraft. Just the opinion of an amateur . . .

 

[mike mcs repair]

So a major alteration becomes a minor something (Alteration? Repair? Change?) because there is approved data? Good to know. Next time I recover, I do not need a 337? Again, I may be totally screwed up here - probably time to get me straightened out.

minor was my first thought also... but
hmmmm I was thinking that recover fabric angle also... hmmmm

 

[Gordon Misch]

Isn't recover specifically a major repair? Seems like I read that somewhere in the regs, but not certain.

 

[T.J.]

In answering the original question....No. Any FAA PMI down the road may override and cancell a previously approved F.A. I've seen it happen.

 

[S2D]

So a major alteration becomes a minor something (Alteration? Repair? Change?) because there is approved data? Good to know. Next time I recover, I do not need a 337? Again, I may be totally screwed up here - probably time to get me straightened out.

Thats a very good question Bob. And something that should be taken up at the next IA seminar. But I think Gordon might have the correct answer. Once you've covered your aircraft once with a specific process that is considered a major alteration unless it was exactly like the original in that case it would have been a major repair.. The next time you do it it becomes a major repair, not alteration if done exactly like the last time you did it..
Replacing the wheels or skis or ..... never was a major repair.

 

[SuperClub]

I've been told by the Feds that if you remove a modification that was previously installed via a FA or other means, you need to create a paper trail by saying that the mod documented on the previous 337 no longer applies. So, at the time that you remove the wheels/brakes that were installed and field approved, the new 337 should explain that the old 337 is cancelled.
But, clearly, if you'd like to keep the old 337 active if you ever intend to return it to that configuration, just make that clear in the 337. Just like skis/wheels..
The key is to explain that in the text of the work performed, and you will leave no doubt as to the intent. I've been surprised at what can be explained and laid out.
Things changed when they no longer required you to submit each 337 to the local FSDO; we would often get input on how to clarify the verbage and make it better. Now, who knows..

 

[barijr]

I would never let an FAA inspector revoke a field approval unless that specific item was grossly allowed to become un-airworthy. That leaves the mechanic and approver of the 337 in a bad way. Maintenance wise etc.. JMO.

 

[wireweinie]

Fabric recovering is listed as a major repair in part 43, appendix A, (b), (1), (xxvii) "Replacement of fabric on fabric covered parts such as wings, fuselages, stabilizers, and control surfaces."
But if you want me to do a 337 to simply revert to another legal configuration, you're going to need to show me an FAR that requires just that. If you don't like the 'skis' analogy, just think about converting from a generator to an alternator using a field approval. If the owner wanted to go all original, you can re install the generator and make a log entry describing the change from the configuration listed on that particular 337 to a configuration listed in the TC. Later, you can even go back to the alternator as long as you follow the installation as described in the 337. It's all legal as long as you make the correct log entry and weight and balance changes, as usual.

Web

 

[bob turner]

I don't think you have to keep the old 337 "active". Approved data is approved data, and can be used to substantiate a major anything.

I think the question here is: is an alteration minor if it is approved for your airplane by field approval or type certificate, or previously applied STC? I suspect the answer is in the definition of major alteration. No longer sure.

 

[wireweinie]

Type certificated data allows the mod as a log book entry. A good example is the lower door windows and camera holes in Cessnas. I can install them as long as I follow the data provided in the Cessna manual. NOT a major. Field approvals are for mods that are not covered by factory data. Once that 337 is approved, it becomes approved data, for that aircraft. If the feds want you to not use that 337, on that aircraft, they can recind it. And that does happen occasionally. Read part 43 for the description of major modifications. Major repairs are a different subject and the specific types of repairs considered 'major' are also listed under part 43. Keep in mind that the repairs that are considered major are always required to be described on a 337. Not only does this list the repair in the fed records, it requires an IA sign off which means a different set of eyes seeing and approving the repair.

Web

 

[bob turner]

My PMI did not get back to me. One of the old timers who runs a repair station told me that they addressed this in an IA class, and decided that if it was in the type certificate data sheets, it was a logbook entry, and if it was a field approval or STC, each time it is added or removed it is a 337 event. The 337 does not need to be FAA approved, except for the initial field approval.

I still don't know for sure, but am currently of the opinion that once an event is determined to be a major alteration or a major repair, no amount of paperwork can make it a minor alteration or a minor repair.

 

[wireweinie]

Some one still needs to show me the FAR that says it has to be done that way. I'll never take any ones word on these issues. Especially when it's not backed up in writing.

Web

 

[bob turner]

Ok - I am learning a lot. First thing I learned is the reason a change covered by the type certificate does not require a 337 is that, by definition, such changes are not major alterations.

Second thing I learned is this:

Field approvals are not covered under a regulation. The field approval process is covered under FAA policy in FAA Order 8300.10 Volume 2 Chapter 1

Therefore, we will not be finding an FAR that covers Web's questions - at least I don't think we will.

So the remaining question: If you remove a field approved mod or an STC'd mod, have you made a major alteration? I am still odd man out on this question, and still think the answer is yes.

 

[S2D]

Where's flip flop when we need him.

 

[skywagon8a]

Bob,
Are you aware that each FAA inspector who is authorized to issue "Field approvals" has attended special classes in Oke City in order to be authorized to issue FAs? And, that his/her decision to actually sign a FA is voluntary? The "boss" can not tell them to sign the FA. He/She has to feel comfortable with the mechanic, and the process which the mechanic is requesting and only then do they voluntarily sign the FA.

Knowing this, I do not see how any other FAA inspector would be allowed to rescind another's FA. Just because the "other" FAA inspector doesn't feel comfortable with the FA is no reason to render another FAA inspector's sign off invalid.

You as an IA don't necessarily like what another IA signs off. Which of the two of you is correct? Your opinion or the other guy's? The same is true of FAA inspectors.

 

[barijr]

Just because a change is on the TCDS does not mean it's not a major alteration. If it's a powerplant, fuel mod, wing tip etc.. Some will require a 337 signed by an IA. JMO. Again on the field approval, if some inspector wanted to rescind my FA i would have a big problem with that.

 

[bob turner]

No - the definition of a major mod starts out by saying something like "any alteration not in the type certificate data sheets . . .". So if any change is listed it is by definition not major.

 

[bob turner]

For major alterations, the regulations do require the use of FAA-approved technical data and the completion of a Form 337. Section 43.7(b) of the Federal Aviation Regulations,
14 C.F.R. § 43.7(b), in conjunction with section 65.95(a)(1), 14 C.F.R. § 65.95(a)(1), require that major alterations be done in accordance with technical data approved by the FAA.
And, section 43.9(d) requires that, for a major alteration, the maintenance entry must be made as prescribed in appendix B to part 43-and this requires the completion of the FAA Form 337. It is in block 8 of Form 337 (Description of Work Accomplished) where a reference to FAA-approved data would appear, including any applicable field approval of technical data.

Section 1.1 of the Federal Aviation Regulations defines major alteration as follows:
Major alteration means an alteration not listed in the aircraft, aircraft engine, or propeller specifications-
(1) That might appreciably affect weight, balance, structural strength, performance, powerplant operation, flight characteristics, or other qualities affecting airworthiness; . . .

That is from a letter by FAA counsel to ACK explaining how to use 43-13 as approved data. It says two things to me - one is that there is an FAR combination that requires a 337 for a major alteration, and also that when you remove a major mod, returning to type certificate configuration, it is not a major alteration. When you put it back on, you need, by regulation, a 337, but since it is already approved, just the IA signature is required.

So I was half right?

 

[S2D]

So what you are saying is if I get my 26 inch Goodyear tires Field approved for my PA-11, every time I switch to skis, I have to make out a 337 to switch back to the tires. Hate to tell you, but after the first installation, a pilot can do it and sign the logbook. The 337 field approval is a permanent part of the Records unless the FAA rescinds it.

 

[Gordon Misch]

How about this as a simple approach?
Item A, previously written up as a major alteration using approved data (STC, Field Approval) is removed, and Item B, previously approved by TCDS is installed. In each case there is a logbook entry referencing the respective documentation (337 or TCDS). Then later, Item B is removed and Item A reinstalled. How about a logbook entry "Reinstalled Item A in accordance with (the prior) 337 dated xxx". Again, I'm just a layman, but I don't see how repetitive 337's would be indicated?