Does AFMS = Major Alteration ?

peter-h said:
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.

Is the Sandal 3500 already installed ?


I don't know what an ASI is but I did realise as much :)
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Aviation Safety Inspectors
 
Let me clarify. I do have an IA who is happy with the approved data from the Sandel IM alone.

What I didn't know is that a thus-prepared 337 goes to Oklahoma.

I thought that the only way to get a 337 which goes straight to Oklahoma, and which doesn't a field approval by an FSDO, and given that the only FSDO available to Europeans doesn't do field approvals, is the DER/8110-3 route.

Now I understand an IA can write out a 337 and that 337 goes to OK, with no further approval required. That would be a simple way to deal with it. But that is totally news to me.
 
peter-h said:
Let me clarify. I do have an IA who is happy with the approved data from the Sandel IM alone.

What I didn't know is that a thus-prepared 337 goes to Oklahoma.

I thought that the only way to get a 337 which goes straight to Oklahoma, and which doesn't a field approval by an FSDO, and given that the only FSDO available to Europeans doesn't do field approvals, is the DER/8110-3 route.

Now I understand an IA can write out a 337 and that 337 goes to OK, with no further approval required. That would be a simple way to deal with it. But that is totally news to me.
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Peter,

All 337's used to go to the local FSDO for "quality assurance" first and then forwarded to Oklahoma City. Now, only 337's requiring field approval so that the data can be "FAA approved" go to the FSDO, all others with approved data go direct to Oklahoma City and are filed, without "quality assurance". I would expect that some 337's without approved data are filed directly with Oklahoma City as a result.
 
I would expect that some 337's without approved data are filed directly with Oklahoma City as a result.
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Who decides whether the approved data is sufficient?

If it is the IA then the approved data which goes with the 337 is by definition sufficient.

If it is the FAA who decides, then a lot of 337s will not have sufficient approved data - unless it was done by a DER; is that correct?

To make the installation definitely legal as far as my aircraft is concerned, is the involvement of an IA, and him being satisfied with the approved data, sufficient?
 
peter-h said:
Who decides whether the approved data is sufficient?

If it is the IA then the approved data which goes with the 337 is by definition sufficient.

If it is the FAA who decides, then a lot of 337s will not have sufficient approved data - unless it was done by a DER; is that correct?

To make the installation definitely legal as far as my aircraft is concerned, is the involvement of an IA, and him being satisfied with the approved data, sufficient?
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Who decides whether the approved data is sufficient?

The person signing off the installation.

If it is the IA then the approved data which goes with the 337 is by definition sufficient.

Yes.

If it is the FAA who decides, then a lot of 337s will not have sufficient approved data - unless it was done by a DER; is that correct?

That's a loaded question that can have a multitude of answers depending upon a particular situation.

To make the installation definitely legal as far as my aircraft is concerned, is the involvement of an IA, and him being satisfied with the approved data, sufficient?

Either that or an approval by a certified repair station (14 CFR Part 145).

 
Good clear answers - thank you.

I have actually seen a 337 prepared by an FAA RS and that one was sent straight to OK, so that makes sense.

That "loaded question" was merely a reference to the grey area which has been discussed endlessly, here and on every other forum... like the difference between Major and Minor alterations.

Is it possible to find out which 337s have been filed on a particular aircraft?
 
peter-h said:
Good clear answers - thank you.

I have actually seen a 337 prepared by an FAA RS and that one was sent straight to OK, so that makes sense.

That "loaded question" was merely a reference to the grey area which has been discussed endlessly, here and on every other forum... like the difference between Major and Minor alterations.

Is it possible to find out which 337s have been filed on a particular aircraft?
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Yes, you can order a CD with all the airworthiness and registration info on a particular N number from the FAA.

http://162.58.35.241/e.gov/ND/AirRecordsND.asp?cmd=new
 
My comments are in Green.


Who decides whether the approved data is sufficient?

The person signing off the installation.

Agree


If it is the IA then the approved data which goes with the 337 is by definition sufficient.

Yes.

The FAA can disagree with the decision made by the IA, but since there is no longer any quality assurance, it is highly unlikely that the matter will come to their attention. It is more likely that a subsequent IA inspection discovers a problem and recommends that the discrepancy be resolved.


If it is the FAA who decides, then a lot of 337s will not have sufficient approved data - unless it was done by a DER; is that correct?

That's a loaded question that can have a multitude of answers depending upon a particular situation.

I have seen several 337's that in my opinion don't have "Approved Data", for example quoting an STC for a strobe that the STC only applies to one model aircraft but is installed in another make and model. Of course, my opinion carries no weight except if it is on my airplane. I have used a DER once in obtaining "Approved data" for an antenna installation on a pressurized aircraft when I operated a Repair Station, but routine use of a DER for most GA applications is very rare indeed. Most installations of equipment that are considered major modifications are covered under a STC or STC with an AML or via field approval.
 
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for example quoting an STC for a strobe that the STC only applies to one model aircraft but is installed in another make and mode
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Why is that a problem, necessarily?

Let's say there is an STC for a Sandel 3500 for a Cessna 421C, where the STC shows a connection to a KLN94.

Why cannot that STC be used as approved data for an installation of a Sandel 3500 in say a PA28 which also has a KLN94?

(assume for simplicity that the only connections between the Sandel and the rest of the aircraft are a) to the KLN94 and b) to the aircraft power supply, via a circuit breaker).

It would seem to me that such an STC would be worth as much (or as little) as approved data as the Sandel IM showing the KLN94 connection.
 
peter-h said:
Why is that a problem, necessarily?

Let's say there is an STC for a Sandel 3500 for a Cessna 421C, where the STC shows a connection to a KLN94.

Why cannot that STC be used as approved data for an installation of a Sandel 3500 in say a PA28 which also has a KLN94?

(assume for simplicity that the only connections between the Sandel and the rest of the aircraft are a) to the KLN94 and b) to the aircraft power supply, via a circuit breaker).

It would seem to me that such an STC would be worth as much (or as little) as approved data as the Sandel IM showing the KLN94 connection.
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STC (Supplemental Type Certificate) provides approved data for the major modification to a TC based on a specific make and model of aircraft approved by the FAA. If your make and model is not approved in the STC, then the data is not approved for your installation. However, often an STC for one make-model can be used as data in a field approval and if the FSDO inspector signs it off, then it is approved on a one time basis for your installation. Often the strategy of obtaining approval is to STC the appliance for one make and model and then others use the STC as a basis for a follow on approval. This is the way most GPS units were approved. It still required a field approval for each installation. Now, GPS can often be installed as a minor modification or thru the STC process with an AML (Approved Model List). The later process is used by Garmin, Aspen, H Bendix King, and others and is the preferred method of installers, since the STC and AML provide approved data for a wide range of installations without involving a field approval.
 
Let's be clear -- in the absence of a field approval (from a FSDO or DER), when an IA uses data which is not completely make/model/system-specific (like an STC) to the installation being done and signs a 337 based on that basis, the IA is putting his/her ticket on the line. If the FAA should later come to review that 337 and disagree with the IA's conclusion that the data were not both approved and applicable, the IA could be doing a rug-dance.

However, 337's using "approved data" in any form are, unlike requests for field approval, no longer reviewed at the FSDO, and merely sent straight to the repository at Oklahoma City, so the likelihood of such a review is not great unless something brings it to their attention (say, because the new installation catches fire in flight or something like that). In that sense, the FAA has placed great faith and trust in the IA's in the field to get it right, and most IA's I know take that seriously. As a result, if you can get an IA (or FAA-Certified Repair Station) to sign off the installation of that EHSI in your plane using the Sandel Installation Manual as "approved data," you're covered. The only remaining problem is finding an IA (or repair station) on your side of the pond who is familiar enough with this item and your plane to do that.
 
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when an IA uses data which is not completely make/model/system-specific (like an STC) to the installation being done and signs a 337 based on that basis, the IA is putting his/her ticket on the line. If the FAA should later come to review that 337 and disagree with the IA's conclusion that the data were not both approved and applicable, the IA could be doing a rug-dance.
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How do AML STCs work?

They are obviously not system-specific.

Europe (EASA) does not recognise FAA AML STCs, pointing to various reasons why they are bogus. OK, EASA is a master in work creation, but unless I am missing something, a AML STC makes the "system specific" approved data idea meaningless. An AML STC could list a C172 and a PA28-181, with the 172 bare and the PA28 equipped better than a 1970s 747 :)
 
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Ron Levy said:
Let's be clear -- in the absence of a field approval (from a FSDO or DER), when an IA uses data which is not completely make/model/system-specific (like an STC) to the installation being done and signs a 337 based on that basis, the IA is putting his/her ticket on the line. If the FAA should later come to review that 337 and disagree with the IA's conclusion that the data were not both approved and applicable, the IA could be doing a rug-dance.

Not Really,

However, 337's using "approved data" in any form are, unlike requests for field approval, no longer reviewed at the FSDO, and merely sent straight to the repository at Oklahoma City, so the likelihood of such a review is not great unless something brings it to their attention (say, because the new installation catches fire in flight or something like that). In that sense, the FAA has placed great faith and trust in the IA's in the field to get it right, and most IA's I know take that seriously. As a result, if you can get an IA (or FAA-Certified Repair Station) to sign off the installation of that EHSI in your plane using the Sandel Installation Manual as "approved data," you're covered. The only remaining problem is finding an IA (or repair station) on your side of the pond who is familiar enough with this item and your plane to do that.
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The question really is your interpretation of AC43,13 when it says we can use the manufacturers installation instructions as approved data if there is no other data.

1. PURPOSE. This advisory circular (AC) contains methods, techniques, and practices acceptable to the
Administrator for the inspection and repair of nonpressurized areas of civil aircraft, only when there are no
manufacturer repair or maintenance instructions. This data generally pertains to minor repairs. The repairs
identified in this AC may only be used as a basis for FAA approval for major repairs. The repair data may
also be used as approved data, and the AC chapter, page, and paragraph listed in block 8 of FAA form 337
when:
a. the user has determined that it is appropriate to the product being repaired;
b. it is directly applicable to the repair being made; and
c. it is not contrary to manufacturer’s data.

Does that statement give you authority to change from a analog system to a electronic system, I believe I would seek my FSDO's guidance on it before I'd bet my IA ship on it.
 
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peter-h said:
How do AML STCs work?

They are obviously not system-specific.

Europe (EASA) does not recognise FAA AML STCs, pointing to various reasons why they are bogus. OK, EASA is a master in work creation, but unless I am missing something, a AML STC makes the "system specific" approved data idea meaningless. An AML STC could list a C172 and a PA28-181, with the 172 bare and the PA28 equipped better than a 1970s 747 :)
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The STC installation instructions can have aircraft make-model specific instructions, although that is not always necessary. The STC AML holder needs to prove to the FAA that the STC can apply to each aircraft on the AML. Often you will see an AML released that has 300+ make/models on it and later expanded to 450+ and later again to 600+. The nice thing about the STC with the AML, it gets the FSDO largely out of the field approval business and expedites the installation and paperwork process.
 
John

I have no problem understanding how an AML STC complies with the FAA interpretation of ICAO certification requirements.

STC is an STC...

I am just saying that the contents of such an STC cannot possibly contain meaningful approved data for 600 airplane types, let alone the variety of equipment within them. I don't understand how the AML concept could ever have been introduced or justified, given the apparently otherwise strict regs for modifications.

Anyway this is probably going off at a tangent since Sandel don't have any STCs of any sort - apart from one for a Cessna 421C.

Peter
 
peter-h said:
Anyway this is probably going off at a tangent since Sandel don't have any STCs of any sort - apart from one for a Cessna 421C.

Peter
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If I were trying to gain approval for this application of the Sandel, I would be trying for a deviation of that STC to be used on your aircraft, using the data contained in the STC for the 412.
 
The Sandel 3500 IM contains just one page from the STC. The # is SA01815LA. Presumably I cannot see the contents of the STC unless I purchase it or get permission from Sandel to use it, correct?

I find it hard to see how it could be useful though. A pilot I know has a 421C and I have flown in it, and it hardly be more different an aircraft to mine. The original avionics in a 421C are large instruments, so the Sandel 4500 would seem a more obvious install.

To me, the most notable thing w.r.t. approved data is that all connections to my aircraft are described in the 3500 IM.
 
Tom-D said:
Does that statement give you authority to change from a analog system to a electronic system, I believe I would seek my FSDO's guidance on it before I'd bet my IA ship on it.
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Mechanical versus electronic presentation is not the issue. The Sandel EHSI is TSO'd as a primary heading indicator, so it's an acceptable instrument for 91.205(d) purposes and installation in certified aircraft as a replacement for a mechanical HI. The only question is whether the Sandell Installation Manual instructions constitute "approved data" for the installation, and as you note, the AC says it is, so the only question is whether the IA signing the 337 is comfortable with the installation instructions.
 
Ron Levy said:
Mechanical versus electronic presentation is not the issue. The Sandel EHSI is TSO'd as a primary heading indicator, so it's an acceptable instrument for 91.205(d) purposes and installation in certified aircraft as a replacement for a mechanical HI. The only question is whether the Sandell Installation Manual instructions constitute "approved data" for the installation, and as you note, the AC says it is, so the only question is whether the IA signing the 337 is comfortable with the installation instructions.
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You missed the part where the AC never says it is approved data to make any modifications. that statement is all about repairs,

modifications/ alterations is what we are doing here, and that is covered in 43. (A) And as close as you can come to this, is a mod to the electrical system, IMHO this application doesn't fit that description.

But as you pointed out, it is up to the A&P-IA on scene to determine if it is a major modification and what the proper course of action would be.

If this were in my hangar I would have had legal paper on it in a matter of a few days. as a field approval using the installation instructions as acceptable data to request FSDO approval

But I don't have to deal with an ICO that refuses to do their job.

OBTW, what's the difference between a Analog gauge and a mechanical one? (for this purpose)
 
Ron Levy said:
Mechanical versus electronic presentation is not the issue. The Sandel EHSI is TSO'd as a primary heading indicator, so it's an acceptable instrument for 91.205(d) purposes and installation in certified aircraft as a replacement for a mechanical HI.

I missed this the first read, The Sandal EHSI may be TSO'ed and it may meet the requirements of 91,205, but I do not believe it meets the type design for the Aircraft, thus it is not a authorized replacement part.

The only question is whether the Sandell Installation Manual instructions constitute "approved data" for the installation, and as you note, the AC says it is, so the only question is whether the IA signing the 337 is comfortable with the installation instructions.
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If it does meet 91,205, and it is not a change to the type design, then we don't need authorization to use it.
 
There is only that one C421 STC.

Sandel inform me that these products go in under a field approval, which I think I understand now :)
 
This document (which appears to be the major reference for the Major v. Minor Alteration decision) states

B. Alterations Requiring a Flight Manual Supplement. Alterations requiring a flight manual supplement or operations limitations changes must be coordinated with the ACO, unless the Flight Standards (AFS) inspector has been specifically authorized by AFS to sign the document(s).

Doesn't this mean it is a Major Alteration?

It refers to all EFIS products being Major but an EHSI is not an EFIS.

The flow chart on page 18 of the PDF is quite interesting. I can see a route to a Minor Alteration (if an IA agrees), the FSDO field approval route (not available in Europe), and the ASI route (which presumably is the DER / 8110-3 option).
 
The portion of the document to which you refer covers field approvals from FSDO's, and you shouldn't be needing field approval from a FSDO if you already have "approved data" in the form of the Installation Manual, in which case that portion of that document wouldn't apply.
 
Ron Levy said:
The portion of the document to which you refer covers field approvals from FSDO's, and you shouldn't be needing field approval from a FSDO if you already have "approved data" in the form of the Installation Manual, in which case that portion of that document wouldn't apply.
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Ron,

There is no indication that the Installation Manual in question is "Approved Data". A statement similar to the one quoted below in the GNS400W series install manual would be required, and it is not present in the Sandel Manual. In fact the Sandel IM describes a sample AFMS and an example 337 to be used for field approval.

"The installation instructions and other data contained within this manual are FAA approved under 400W/500W Series AML STC SA01933LA, which is applicable for implementation within airplanes that are type certificated only under Civil Air Regulation 3 (CAR 3) or 14 Code of Federal Regulations (CFR) Part 23."
 
John,

Aren't Garmin saying that merely because their IM is an integral part of their AML STC?

Otherwise, why does the FAA offer the option of the IM being approved data? If such an IM was approved data only in conjunction with an STC, the IM itself would become redundant (as approved data) because the STC would make a much better approved data :)

Ron,

I don't have the FSDO option anyway, in Europe. For me, it has to be done as a Minor alteration, or via the DER/8110-3/337/Oklahoma route.

Incidentally, doesn't a Minor alteration need approved data also, in the form of e.g. a TSOd instrument? You cannot just fit stuff from a hardware store.

Peter
 
It been a while since I commented, but this installation is a considered a major alteration for a couple of reasons. 1) It requires a flight manual supplement which can only be approved the Aircraft Certification Office. 2) The data is not FAA approved for this make and model and will installed in the aircraft drawing electrical power.

The STC is FAA approved with a full list of Instructions for Continued Airworthiness (ICA). However in this case the installation instructions are not FAA approved until block 3 on the FAA Form 337 is signed by an FAA Inspector since the STC does not apply.

No inspector can just approve this installation because FAA Order 8900.1 does not support it. The FAA Inspector can not approve the flight manual supplement and will have to send the 337 for the installation to the ACO as part of the supporting data package.

Keep in mind this is NOT a minor alteration and the A&P who signs block 6 is responsible to ensure he or she has FAA approved data to perform the install. And already mentioned the IA in block 7 (QA) will have to insure the data is approved and the flight manual supplement is also approved.

Can the installation be accomplished? Yes, but first all the correct paperwork must be approved and signed off.

As I understand it the aircraft is out of the country, but that does not make any difference. The local IFO will perform the same function as a FSDO inspector because the aircraft still hold an N-number and falls under the requirements of the Code of Federal Regulations (CFRs).

In some cases the local FSDO may NOT have the experience or knowledge to support a field approval such as this and will default to the another FSDO/IFO or contact the ACO for assistance. Concerning primary instruments many ACOs will want a one time STC to insure all the CFR requirements are met. Please keep in mind the requirements for a filed approval or STC are the same, it’s the time to get approval that may be different.

ASI means: Aviation Safety Inspector. Your local FSDO or IFO inspector are sometimes referred to as your Principle Inspector (PI) and your Princile Maintenance Inspector is called PMI.

Something to keep in mind if you use a Designee Engineering Representative (DER) they have limits or function codes for certain things they can do. The approve data on a FAA Form 8110-3 is only for that part or section and may not cover the whole installaiton. READ the notes on the front page of the 811-3 to see what the data covers. Having a signed 8110-3 does not allow a person to install something. With the 8110-3 in hand submit it to the local FAA with a FAA Form 337 as a complete package including your 16 steps for the ICA to be signed off in block 3 by the ASI. Now you will have approved data to perform the install.

One last word of caution. If an IA signs block7 and sends the FAA Form 337 to aircraft records and later the FAA has issue with it there is only to ways to correct the 337. 1) The ACO issues an AD against the aircraft by serial number. 2) Another 337 is issued to fix the first one. Either way the owner is going to be upset and if the data was not approved the IA may be in a world of hurt. This is one problem with sending 337’s directly to aircraft records, the FSDO/IFO used to by the IA’s QA department.

Just one man's opinion.
 
I did finally work out that the need for an AFMS means it cannot be done as a Minor.

I have no FSDO option in Europe.

Can you recommend a DER who does this type of work? That is how it is done over here.
 
Peter,

Even if the NY FSDO won't do a field approval, I assume they can forward your request to the ACO who should be able to do it.
 
Over the past 5 years I have tried several times to get a new FAA approved AFMS for my KLN94, authorising the flying of GPS approaches. My present AFMS authorises only BRNAV enroute, no approaches.

I tried several avionics shops and all had to abandon it. I got more feedback from the last one, which got a total run-around from the NY IFO.

That project was abandoned, but it's no big deal because almost every foreign airport which has Customs also has an ILS, and anyway one can fly conventional approaches using the GPS, so flying pure GPS approaches is not yet operationally relevant in Europe.

The only avionics shop which was probably able to do it also uses the DER route, but they were too busy.
 
Who decides if an instrument requires an AFMS?

Here in Europe, if the aircraft is EASA registered (mine is US reg) there is no AFMS for a Sandel 3500.
 
You don't want me to write a detailed answer ;)

You need a Euro IR .... audiogram in both ears (passes for each ear), 7 exams, 50hrs dual training, etc. Very few people do it. In fact when I first looked at the IR (c. 2001) the only option was all the 14 ATP exams, even for a PPL.

I do have a UK CAA PPL and medical too, so can fly a G-reg worldwide, VFR only. I run CAA and FAA Class 1 medicals concurrently (renewed with the same doctor) as an insurance policy against more cr*p in Europe.

But a N to G transfer would be very very expensive. I think my US-rebuilt engine would have to be opened up and "inspected" and "recertified" by an EASA company.

The G to N transfer cost thousands...
 
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And the whole problem could be solved by one FSDO/ICAO doing its freaking job. what a bunch of Federal BS.
 
peter-h said:
I did finally work out that the need for an AFMS means it cannot be done as a Minor.

I have no FSDO option in Europe.

Can you recommend a DER who does this type of work? That is how it is done over here.
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Peter you really don’t need a DER to write up a Flight Manual Supplement (FMS) the DER cannot approve it, only the ACO can. I work in the Western Pacific region and the Flight Test Branch approves all FMS, as do other ACOs Flight Test Branches around the country. You can contact the Flight Test Branch directly and speak to the engineer that will work on your request in advance to see what they need. However keep in mind your 337 with the FMS attached will have to go thru the London IFO in your case. I have forwarded several FMSs to Flight Test for approval that mechanic/owners have provided. The ACO will make the necessary changes, approve them and send them back with a memo. This isn’t rocket science.

As far as the installed is concerned as long as this will not be the primary and be a secondary or backup insturment you can refer to the installational manual for the install and reference the manaul by part number and revision. The manual comes with an ICA which can also be referenced.

I am going to be in Frankfurt on February 9, 2011 teaching the IA renewal course if you can attend I would be happy to walk you thru the process and provide some contact information for you off line.
 
Many thanks Stache - emailed.

So a DER doesn't help if an AFMS is deemed mandatory. You still have to find an FAA office to push it through.

I've just noticed that the extract from AC43-210 posted earlier (on what constitutes Approved Data) is apparently out of date. The current doc appears to be here - is this correct? I don't see that it changes anything much.

I am still trying to establish what determines whether an AFMS is mandatory. There are certainly installations in the USA, done by big-name shops, which don't have an AFMS.
 
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peter-h said:
I've just noticed that the extract from AC43-210 posted earlier (on what constitutes Approved Data) is apparently out of date. The current doc appears to be here - is this correct? I don't see that it changes anything much.

I am still trying to establish what determines whether an AFMS is mandatory. There are certainly installations in the USA, done by big-name shops, which don't have an AFMS.
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The copy you reference is the latest version of AC 43-210 on the FAA website. It describes the AFMS requirements.
 
It indeed does, but

a. An aircraft alteration that changes the operating limitations or procedures necessary for safe operation is a major alteration and must include an AFMS if the aircraft has an Aircraft Flight Manual (AFM).
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would mean a lot of avionics do not need an AFMS.

In particular an EHSI which does no more than the old HSI (in terms of its outputs) does not appear to meet the above requirement for an AFMS.

Is it possible to write to an FSDO and ask them these questions? Presumably the answer would be legally valid.
 
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