Does AFMS = Major Alteration ?

[peter-h]

I am working through the installation drawings for a Sandel 3500 in a Socata TB20GT.

The only STC is for a Cessna 421C.

Sandel say that an AFMS is mandatory for the 3500 (understandable).

What is not clear is whether there is the slightest chance of doing this as a Minor Alteration.

One can install a Garmin 430W (e.g.) in that way, but that comes with an AML STC.

There is a document floating around which lists the 3500 and implies it is a Major Alteration. I also see an extract from it in the back of the 3500 installation manual.

However, one contact I have in the US certification scene informs me that that document was cancelled and no longer applies. He has no more details - at least not until I throw some money at this.

If it has to be a Major Alteration then my only option is the DER/8110-3/337 route because the NY IFO is no longer processing 337s for US registered aircraft outside the USA.

 

[poadeleted20]

Whether or not a flight manual supplement is required has nothing to do with whether something is a "major alteration" or not. The issues are whether the installation itself is considered a "major alteration," and whether or not you have "approved data" for the installation of that component in that aircraft. Since it sounds like you do not have such "approved data," you're going to have to get the installation approved on a Form 337. If the NY IFO isn't doing such approvals, then I think you'll have to get a DER involved.

 

[peter-h]

Can anybody offer a view on whether replacing a KI-525 HSI with a Sandel 3500 EHSI is a Major Alteration?

I have had conflicting views, from both avionics installers and FAA IAs.

Notably, all UK installers say it is a Major Alteration, but then they would say that because they say that about just about everything

I can certainly find an IA who will sign it off as a logbook entry, but does that make it legal?

There is no STC for my aircraft but there is a ton of approved data in the form of interconnection schematics for various avionics, in the Sandel IM.

 

[RotorAndWing]

Can anybody offer a view on whether replacing a KI-525 HSI with a Sandel 3500 EHSI is a Major Alteration?

I have had conflicting views, from both avionics installers and FAA IAs.

Notably, all UK installers say it is a Major Alteration, but then they would say that because they say that about just about everything

I can certainly find an IA who will sign it off as a logbook entry, but does that make it legal?

There is no STC for my aircraft but there is a ton of approved data in the form of interconnection schematics for various avionics, in the Sandel IM.

Without an STC you will need to have the installation Field Approved IMO.

It's up to the installer (the person signing off the work) to make the determination. Since you will need an AFMS to go with the installation then it will need to be "Field Approved".

 

[John Collins]

Peter,

It appears that the FAA put their guidance on these and other subjects on line at: http://fsims.faa.gov/PICResults.aspx?mode=EBookContents

If you do a search on the above site for EFIS, you will come up with http://fsims.faa.gov/PICDetail.aspx?docId=5FA5237B49DF80078625760800658B77

That will point you to Info 0847 at http://www.faa.gov/other_visit/avia...afety/info/all_infos/media/2008/info08047.pdf

Which in turn references the old superceded guidance at http://www.faa.gov/other_visit/avia...fety/info/all_infos/media/2008/FSAW95-09E.pdf

From what little reading of the above I have done indicates install of an EFIS system is classified as a major modification.

 

[John Collins]

Whether or not a flight manual supplement is required has nothing to do with whether something is a "major alteration" or not. The issues are whether the installation itself is considered a "major alteration," and whether or not you have "approved data" for the installation of that component in that aircraft. Since it sounds like you do not have such "approved data," you're going to have to get the installation approved on a Form 337. If the NY IFO isn't doing such approvals, then I think you'll have to get a DER involved.

Ron,

I agree with your posts and offer the following additional comments. All major modifications require "approved data" and are documented on the 337 form. In cases where the data is acceptable data but not approved data, a field approval is required. The signature of the FAA Inspector in block 3 indicates approval of the data, for this one time change. There are many forms of data that are considered approved data, see the list below for approved data and note that even this list is not all-inclusive.

4) Approved Data. Substantiating and descriptive technical data, used to make a major repair or alteration that is approved by the Administrator. The following list, although not all-inclusive, contains sources of approved data:

a) Type Certificate Data Sheets (TCDS).

b) Supplemental Type Certificate (STC) data, provided it specifically applies to the item being repaired/altered. Such data may be used in whole or part as included within the design data associated with the STC.

c) Appliance manufacturer’s manuals or instructions, unless specifically not approved by the Administrator, are approved for major repairs.

d) Airworthiness Directives (AD).

e) FAA Form 337, which has been used to approve multiple identical aircraft (only by the original modifier).

NOTE: Aviation safety inspectors (ASI) no longer approve data for use on multiple aircraft.
f) U.S. Civil Aviation Authority (CAA) Form 337, dated before October 1, 1955.

g) FAA-approved portions of SRMs.

h) Designated Engineering Representative (DER)-approved data, only when approval is authorized under his/her specific delegation.

i)

Organization Designation Authorization (ODA)-approved data, when the major alteration is performed specific to the authorization granted.

j) Data in the form of an Appliance Type Approval issued by the Minister of Transport Canada for those parts or appliances for which there is no current Technical Standard Order (TSO) available. The installation manual provided with the appliance includes the Transport Canada certificate as well as the date of issuance and an environmental qualification statement.

k) Foreign bulletins, for use on U.S.-certificated foreign aircraft, when approved by the foreign authority.

l) Data describing an article or appliance used in an alteration which is FAA-approved under a TSO. As such, the conditions and tests required for TSO approval of an article are minimum performance standards. The article may be installed only if further evaluation by the operator (applicant) documents an acceptable installation which may be approved by the Administrator.

m) Data describing a part or appliance used in an alteration which is FAA-approved under a Parts Manufacturer Approval (PMA). An STC may be required to obtain a PMA as a means of assessing Airworthiness and/or performance of the part.

NOTE: Installation eligibility for subsequent installation or reinstallation of such part or appliance in a type certificated (TC) aircraft, other than the aircraft for which Airworthiness was originally demonstrated, is acceptable, provided the part or appliance meets its performance requirements and is environmentally and operationally compatible for installation. The operator/applicant must provide evidence of previously approved installation by TC, STC, or field approval on FAA Form 337 that will serve as a basis for follow-on field approval.
n) Any FAA-approved Service Bulletins (SB) and letters or similar documents, including DER approvals.

o)

Foreign bulletins as applied to use on a U.S.-certificated product made by a foreign manufacturer located within a country with whom a Bilateral Agreement (BA) is in place and by letter of specific authorization issued by the foreign civil air authority. The Bilateral Web site is located at: http://www.faa.gov/aircraft/air_cert/international/bilateral_agreements/baa_basa_listing.

p) Other data approved by the Administrator.

q) AC 43.13-1, current edition, for FAA-approved major repairs on non-pressurized areas of aircraft only when the user determines that it is:

· Appropriate to the product being repaired;
· Directly applicable to the repair being made; and
· Not contrary to the airframe, engine, propeller, product, or appliance manufacturer’s data.
r)

AC 43.13-2, current edition, for FAA-approved major alterations on non-pressurized areas of aircraft 12,500 lbs gross weight or less only when the user determines that it is:

· Appropriate to the product being repaired;
· Directly applicable to the alteration being made; and
· Not contrary to the airframe, engine, propeller, product, or appliance manufacturer’s data.
s) Service and repair data provided by small airplane manufacturers, although, in most cases, not specifically approved, has provided for continued Airworthiness of their product. Service experience in using this data when performing major repairs to non-pressurized airplanes that are 12,500 pounds or less maximum certificated takeoff weight, and were originally TC’d before January 1, 1980, has proven to be very reliable if followed and not deviated from. Follow-on TC’d of the same model airplane, or a derivative thereof (may be assigned a later TC date), is considered to meet this criteria. When the data is used in this manner, the manufacturer’s data (with page, paragraph, etc.) must be referred to in block 8 of FAA Form 337.

 

[peter-h]

Thank you all.

Is an EHSI an "EFIS"?

There are no altitude/speed indications.

 

[Tom-D]

Whether or not a flight manual supplement is required has nothing to do with whether something is a "major alteration" or not. The issues are whether the installation itself is considered a "major alteration," and whether or not you have "approved data" for the installation of that component in that aircraft. Since it sounds like you do not have such "approved data," you're going to have to get the installation approved on a Form 337. If the NY IFO isn't doing such approvals, then I think you'll have to get a DER involved.

There are a couple questions we should be asking, ( I have never read the installation instruction)

Does these instructions include any modifications included in 43-A as major modifications. ?

Is the Sandel thingie an authorized replacement part. ( I don't think it is, but?)

If it has an STC for the Cessna twin, can that engineering be used as a deviation to place the Sandel into the Op's aircraft on a field approval?

If the flight manual must be rewritten the FAA's policy is to require flight testing to prove the aircraft/equipment will preform to the new flight manuals numbers. think a one time STC and all the $ involved to get that approved.

My approach to this would be, The aircraft is in the UK, he has a IA who will sign it off as a log book entry, as a minor mod, go with that. and if/when the aircraft comes back to the US do the paper work as a late entry with XXX number of hours flown as equipped.

But then again the FAA could require you to pull it. you never know until you shop for a FSDO who will approve it.

 

[Tom-D]

Ron,

I agree with your posts and offer the following additional comments. All major modifications require "approved data" and are documented on the 337 form. In cases where the data is acceptable data but not approved data, a field approval is required. The signature of the FAA Inspector in block 3 indicates approval of the data, for this one time change. There are many forms of data that are considered approved data, see the list below for approved data and note that even this list is not all-inclusive.

when the equipment manufacturers installations instructions are provided, the 43,13 will not be excepted at FSDO.

Check Para 4(c) in your reference.

none of the aircraft MM will have specific instructions for installing this equipment, it was not invented when the manuals were written.

The 43,13 does not provide engineering data for any structure, it will describe how to develop that data but it will not give it to you. because the AC is generic in nature and applies to all aircraft.

the equipment manufacturers instructions are specific to the equipment thus it will be acceptable to FSDO, for approval, if they do or not is another question.

 

[peter-h]

I cannot use an FSDO. I am in Europe (UK) and the only FSDO which deals with these "foreign lands" is the NY IFO, and they have stopped doing field approvals a couple of years ago.

AFAIK the only route for a Major Alteration (apart from flying to the USA; some 30hrs each way ) is the DER/8110-3 one. I can do that - for maybe $1000 or two, maybe less. I have never done it. I know UK avionics shops charge it out at about $2000, but they have to prepare some drawings first.

I do want to be legal, not because I think there will be any ramp check anywhere in the world which would ever dig this deep, but for insurance reasons I always keep the paperwork straight and very complete.

The Major v. Minor alteration debate has been running long before I first discovered Usenet and rec.aviation.owning and I think I appreciate that much of it will never be settled, and I know that a lot of mods are done (quite properly) in the USA as logbook entries which here in Europe are blown up to massive paperwork, but I am seeking advice/pointers for this specific case.

If a reasoned line can be put together for it being a Minor, and if I can get an IA to sign it off (which I can, based on that reasoning), then I am happy.

The pic of my panel is here

 

[Tom-D]

If a reasoned line can be put together for it being a Minor, and if I can get an IA to sign it off (which I can, based on that reasoning), then I am happy.

The pic of my panel is here

didn't I see where your IA will sign it off as a minor? using his authority to use the manufacturers instructions as approved data.

see


4) Approved Data. Substantiating and descriptive technical data, used to make a major repair or alteration that is approved by the Administrator. The following list, although not all-inclusive, contains sources of approved data:

a) Type Certificate Data Sheets (TCDS).

b) Supplemental Type Certificate (STC) data, provided it specifically applies to the item being repaired/altered. Such data may be used in whole or part as included within the design data associated with the STC.

c) Appliance manufacturer’s manuals or instructions, unless specifically not approved by the Administrator, are approved for major repairs.

d) Airworthiness Directives (AD).

e) FAA Form 337, which has been used to approve multiple identical aircraft (only by the original modifier).

 

[poadeleted20]

Is an EHSI an "EFIS"?

No, it isn't.

 

[poadeleted20]

The Major v. Minor alteration debate has been running long before I first discovered Usenet and rec.aviation.owning and I think I appreciate that much of it will never be settled, and I know that a lot of mods are done (quite properly) in the USA as logbook entries which here in Europe are blown up to massive paperwork, but I am seeking advice/pointers for this specific case.

If a reasoned line can be put together for it being a Minor, and if I can get an IA to sign it off (which I can, based on that reasoning), then I am happy.

As stated above, the FAA considers this a major alteration. That means a 337 to document the installation, and "approved data" (see the list John posted above) referenced on that 337, with an IA's signature at the bottom. While you may find some maverick or unknowledgable A&P to sign it off as a minor alteration in the logbook, any FAA scrutiny will result in bad times for you.

Choose wisely.

 

[peter-h]

I should add that every interconnection between the Sandel and the rest of the aircraft is documented in the back of the Sandel 3500 IM.

If the IM is not sufficient approved data for this type of installation, it's hard to see what could be.

 

[Tom-D]

If the IM is not sufficient approved data for this type of installation, it's hard to see what could be.

I see no reason they shouldn't be, but that is the IA's responsibility to determine, the local IA has the authority to use the Sandel IM as approved data, and do the modification, and record it on a 337.

I see no reason FSDO should be involved.

 

[Tom-D]

any FAA scrutiny will result in bad times for you.

Choose wisely.

How could that happen when the aircraft is in the UK?

 

[peter-h]

Modifications need to be legal everywhere - for insurance reasons. If there is a high value claim, the insurer would well check the paperwork.

There is no known regulatory ramp checking (where somebody looks for certification issues) in Europe. Pilot licenses get checked, sure. But aircraft/equipment certification cannot be done on travelling aircraft because obviously nobody carries their 337s etc with them

Insurance is the thing to watch.

What you write, Tom-D, is interesting and this has been my understanding. However it is normal here in Europe to take the view that an IA has zero discretion; only a DER is allowed to use intelligence. That is clearly wrong, but where is the line drawn? A lot of people refuse to stick their neck out.

 

[jesse]

Modifications need to be legal everywhere - for insurance reasons. If there is a high value claim, the insurer would well check the paperwork.

There is no known regulatory ramp checking (where somebody looks for certification issues) in Europe. Pilot licenses get checked, sure. But aircraft/equipment certification cannot be done on travelling aircraft because obviously nobody carries their 337s etc with them

Insurance is the thing to watch.

What you write, Tom-D, is interesting and this has been my understanding. However it is normal here in Europe to take the view that an IA has zero discretion; only a DER is allowed to use intelligence. That is clearly wrong, but where is the line drawn? A lot of people refuse to stick their neck out.

Any chance you could cite a single aviation insurance claim that was denied because of something being incorrectly logged as a minor alternation instead of a 337? Or a single instance of a claim being denied for any sort of similar reason?

If the insurance companies made a habit of doing that they would be able to deny almost every claim. If you look hard enough, for long enough, you'll find an issue with the paperwork of nearly every aircraft out there.

 

[peter-h]

I don't live in the USA so No for US insurers. Also if somebody had hassles getting paid out they are not going to advertise it on pilot forums

 

[jesse]

I don't live in the USA so No for US insurers. Also if somebody had hassles getting paid out they are not going to advertise it on pilot forums

Actually I'd be willing to bet that if someone got screwed and their claim was denied and the insurance refused to pay it - it would become a publicly known issue pretty fast.

It seems as if people constantly say insurance won't pay if X or Y isn't perfect. Thing is - I've never heard of that actually happening.

 

[Tom-D]

What you write, Tom-D, is interesting and this has been my understanding. However it is normal here in Europe to take the view that an IA has zero discretion; only a DER is allowed to use intelligence. That is clearly wrong, but where is the line drawn? A lot of people refuse to stick their neck out.

Does your aircraft have a N number? If so, it is required that it meets the US rules. not the EU's

And it's with in the authorization of the A&P-IA to return to service any major repair or modification they have approved data to do so. SO, it is back in the hands of the A&P-IA that you have, to determine if he has that data.

 

[poadeleted20]

How could that happen when the aircraft is in the UK?

It's an N-reg airplane and the FAA has inspectors there. If there's any accident, the FAA will become part of the investigation, and it is at least theoretically possible for him to be ramped.

Of course, I get the idea that Peter wants to be legal, and isn't one of those "I don't care whether it's illegal, I just want to know if I might get caught" folks, so getting the paperwork right seems to be a priority for him.

 

[RotorAndWing]

FWIW, an "N" registered plane getting a ramp inspection in a foreign country would be the same as a ramp inspection in the US, i.e. certificates check. The inspector would not start looking through the aircraft and questioning avionics installations.

As far as the OP question, the best advice is to have the unit properly installed. I realize there are problems with a N registered plane in Europe when it comes to paperwork, but that's the choice the owner has made.

 

[Tom-D]

As far as the OP question, the best advice is to have the unit properly installed. I realize there are problems with a N registered plane in Europe when it comes to paperwork, but that's the choice the owner has made.

Why can one FSDO refuse to do Field approvals ?

that is the root problem in this case.

 

[RotorAndWing]

Why can one FSDO refuse to do Field approvals ?

that is the root problem in this case.

Short answer: It's up to the individual Inspector to decide whether he will grant a Field Approval.

It would be appropriate to call the IFO (as in the original question) and talk directly with the Airworthiness Supervisor. He could best advise the OP which route to take to get the paperwork done.

 

[TMetzinger]

I have a serious sense of deja vu here - weren't we discussing something just like this a year ago?

I'd almost think it would be worth it to ferry the airplane here, do the work, get it signed off, and then send it back.

 

[peter-h]

I have just called an inspector at the NY IFO and he says that an HSI or EHSI is a primary indicator and these cannot be installed unless there is an engineering approval with an STC.

This is clearly not the practice in the USA...

 

[poadeleted20]

I have just called an inspector at the NY IFO and he says that an HSI or EHSI is a primary indicator and these cannot be installed unless there is an engineering approval with an STC.

This is clearly not the practice in the USA...

On what do you base that statement? Even here in the States, FAA approval of any primary flight instrument in a certified airplane (i.e., not Experimental) is required, in the form of either original certifiation equipment list, STC, PMA, or field approval.

 

[Tom-D]

I have just called an inspector at the NY IFO and he says that an HSI or EHSI is a primary indicator and these cannot be installed unless there is an engineering approval with an STC.

This is clearly not the practice in the USA...

are you saying the NY IFO told you that a STC was required?

 

[Tom-D]

On what do you base that statement? Even here in the States, FAA approval of any primary flight instrument in a certified airplane (i.e., not Experimental) is required, in the form of either original certification equipment list, STC, PMA, or field approval.

What does the PMA have to do with gaining approval to use a HSI as a replacement for a Attitude indicator ?

If the HSI were an authorized replacement part it wouldn't be a modification of the aircraft.

but your right, it does not require an STC.

 

[peter-h]

are you saying the NY IFO told you that a STC was required?

Yes. .

 

[poadeleted20]

What does the PMA have to do with gaining approval to use a HSI as a replacement for a Attitude indicator ?

Nothing, but that wasn't the question, and it's not what Peter is trying to do, and even if he was, there isn't any way in the world to do it by STC, field approval, or any other means, since 91.205(d) unequivocably requires an attitude indicator for IFR operations.

 

[peter-h]

My reading of that document posted by John Collins is that IF a Sandel 3500 is a Major Alteration then XYZ apply, but it doesn't (to me) actually say that every Sandel 3500 installation is a Major Alteration.

 

[Tom-D]

but that wasn't the question, and it's not what Peter is trying to do,.

What do you believe he is trying to do ?

 

[Tom-D]

Yes. .

This is the biggest problem the FAA has, ASIs making the rules as they go along.

 

[peter-h]

What do you believe he is trying to do ?

Replacement of a KI-525 HSI with a Sandel 3500 EHSI, incidentally done in such a way that all connections to the aircraft's avionics are as documented in the 3500 IM.

This is the biggest problem the FAA has, ASIs making the rules as they go along.

I don't know what an ASI is but I did realise as much

 

[Hiperbiper]

Would not the Sadel Installation/Service manual AND the 337 from a like-kind installation be enough to satisfy the FAA with a 337 for that airframe?

As I remember; the FAA (somewhere) said Approved Data (installs) could be used in other installs as long as the form-fit-function remained undisturbed.

Again; this kind of problem is why the Experimental crowd has access to EFIS that costs $3000.00 and will do all and more than the Cretified units costing $20G...and we just install them and fly...

I hope you get everything worked out Peter

Chris

 

[peter-h]

Would not the Sadel Installation/Service manual AND the 337 from a like-kind installation be enough to satisfy the FAA with a 337 for that airframe?

I do know of one pilot in the USA with a (fairly similar though not identical) TB20 and a Sandel 3500. I asked him if he could get the details from his avionics shop, but apparently the shop refused to give it to him, saying they haven't got the time.

He does have a curious installation however, where both the Garmin GPS and the 3500 can be used to control the WX-500 stormscope display. As the WX-500 has only one input (AFAIK) for the display format control, I suspect that shop wired the two RS232 signals together, which "could work" if there is no data most of the time I work in datacomms and plenty of our customers have done that sort of thing, accidentally

There are other TB20 / 3500 installs here in the UK which I am trying to locate. The issue is that the vast majority of owners don't care about keeping details of work done, and the avionics shops are reluctant to supply the work pack. In fact I am about to retrieve a load of papers from the original Socata dealer here who went bust a couple of years ago.

Having said all that, I don't think a DER will cost more than $1000, which is OK.

I am currently looking for a freelance avionics specialist who is familiar with this kind of stuff and who is willing to informally check my drawings (not for free) before they go off to the DER.

 

[poadeleted20]

Replacement of a KI-525 HSI with a Sandel 3500 EHSI, incidentally done in such a way that all connections to the aircraft's avionics are as documented in the 3500 IM.

...and that ain't the same as trying to replace the attitude indicator with an EHSI.

I don't know what an ASI is

In this context, it's an "Aviation Safety Inspector," the official title of an FAA Inspector, including both Operations and Airworthiness subspecialities (and a few others, as well).

 

[poadeleted20]

Would not the Sadel (sic) Installation/Service manual AND the 337 from a like-kind installation be enough to satisfy the FAA with a 337 for that airframe?

It should, but it's up to the IA approving the installation whether or not s/he is satisfied that the data in the Sandel Installation Manual are sufficient for the purpose. I suspect Peter's problem is lack of such an IA, not lack of approved data. But there will have to be a 337 to document the installation, and it will have to cite the "approved data" for the installation, be it the Installation Manual, an STC, or other source. Further, once the IA signs that 337, it goes straight to the repository in Oklahoma City, and is not reviewed by the NY IFO or any other FSDO, so local misconceptions don't get involved. The problem arises only if the IA involved doesn't have what s/he considers "approved data" for the installation, in which case a "field approval" from either the local FSDO or a DER is necessary. Peter seems to believe he's in that corner, but I'm not convinced the problem is lack of "approved data" rather than lack of a sufficiently knowledgable IA.