TSO, PMA, STC, 337, Field Approval, and Such

GlennAB1 said:
Technicality: There is no "request for approval".
However, the person who performs or supervised the major repair MUST prepare the 337
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Show me your reference.
 
Tom-D said:
When you do that, it is called " asking for a deviation to an STC"

You simply show the STC was for X-a aircraft. but will work just as good on X-b aircraft.
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I think the term "STC deviation" relates more to making a change to the STC approved data. Could be a major change, maybe a minor one. Using a different bolt than the one called out, for example. See link below, page 90, number 5. Denny Pollard is an ex FAA inspector.

https://books.google.ca/books?id=su...AEIXzAJ#v=onepage&q=faa stc deviation&f=false
 
JAWS said:
I think the term "STC deviation" relates more to making a change to the STC approved data. Could be a major change, maybe a minor one. Using a different bolt than the one called out, for example. See link below, page 90, number 5. Denny Pollard is an ex FAA inspector.

https://books.google.ca/books?id=suI6i_3x_dwC&pg=PA90&lpg=PA90&dq=faa+stc+deviation&source=bl&ots=qq5RgCxfi1&sig=yiS2tTfSp3ftkPGFbJ1hqntLjl4&hl=en&sa=X&ved=0ahUKEwjJpramje_VAhVq44MKHY8lCz0Q6AEIXzAJ#v=onepage&q=faa stc deviation&f=false
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Denny was at our FSDO. And there were reasons for his becoming ex.

Paul
 
Tom-D said:
Show me your reference.
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I believe we've been here before.
The 337 has instructions at the top, it refers to AC 43.9-1 (or subsequent revision thereof) for instructions and disposition of the 337.
I know you like to state that AC's are not mandatory and are only advisory.
But,
If the 337 is mandatory, it's instructions are also mandatory. Which means the AC must be followed.
AC 43.9-1F, 6. States:
"The person who performs or supervised the major repair or major alteration must prepare Form 337."
 
GlennAB1 gets the star...:)

6. FORM INSTRUCTIONS. The person who performs or supervises a major repair or major alteration must prepare Form 337. The form is executed at least in duplicate and is used to record major repairs and major alterations made to an aircraft, airframe, powerplant, propeller, appliance, or a component part thereof. The following instructions apply to items 1 through 8 of the form as illustrated in Appendix 1. The terms "Item" and "Block" are used synonymously in FAA documents relating to data collection on Form 337.
 
GlennAB1 said:
I believe we've been here before.
The 337 has instructions at the top, it refers to AC 43.9-1 (or subsequent revision thereof) for instructions and disposition of the 337.
I know you like to state that AC's are not mandatory and are only advisory.
But,
If the 337 is mandatory, it's instructions are also mandatory. Which means the AC must be followed.
AC 43.9-1F, 6. States:
"The person who performs or supervised the major repair or major alteration must prepare Form 337."
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When you send the 33 to your PMI are you not requesting they approve the modification by signing block #4?
When you as an A&P ask the A&P-IA to sign the return to service block, are you not making a request?

We all can read the 337 instructions at the top of the sheet, So I believe you missed the part where we were requesting a field approval. and that has nothing to do with block 6 & 7. AC 43-210 is the method that the FAA excepts

https://www.faa.gov/regulations_pol...x.cfm/go/document.list?omni=Home-ACs&q=43-210
 
AKBill said:
GlennAB1 gets the star...:)

6. FORM INSTRUCTIONS. The person who performs or supervises a major repair or major alteration must prepare Form 337. The form is executed at least in duplicate and is used to record major repairs and major alterations made to an aircraft, airframe, powerplant, propeller, appliance, or a component part thereof. The following instructions apply to items 1 through 8 of the form as illustrated in Appendix 1. The terms "Item" and "Block" are used synonymously in FAA documents relating to data collection on Form 337.
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How can that be enforced? How does the FAA know who wrote in the box? be real world.
 
AKBill said:
GlennAB1 gets the star...:)

6. FORM INSTRUCTIONS. The person who performs or supervises a major repair or major alteration must prepare Form 337. The form is executed at least in duplicate and is used to record major repairs and major alterations made to an aircraft, airframe, powerplant, propeller, appliance, or a component part thereof. The following instructions apply to items 1 through 8 of the form as illustrated in Appendix 1. The terms "Item" and "Block" are used synonymously in FAA documents relating to data collection on Form 337.
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"Prepare" is subject to interpretation, isn't it? I mean, it's certainly OK for the IA to have an office assistant, secretary or other "helper" actually do the typing at his direction, right? You really think the FAA's goal here was to insist that the IA actually type the data into the form personally with no assistance? I think the intent is to ensure the person performing the repair/alteration is involved in preparing the 337. As an attorney, if I have a paralegal or secretary draft a document for me that I review and sign, I take full responsibility for having "prepared" that document even though I did not necessarily type the information in myself.
 
Tom-D said:
When you send the 33 to your PMI are you not requesting they approve the modification by signing block #4?
When you as an A&P ask the A&P-IA to sign the return to service block, are you not making a request?

We all can read the 337 instructions at the top of the sheet, So I believe you missed the part where we were requesting a field approval. and that has nothing to do with block 6 & 7. AC 43-210 is the method that the FAA excepts

https://www.faa.gov/regulations_pol...x.cfm/go/document.list?omni=Home-ACs&q=43-210
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How do they sign block 4? What version are you working with?

This has been current since 2006.

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JAWS said:
I think the term "STC deviation" relates more to making a change to the STC approved data.
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That is exactly what you are doing when you use the STC on a different model aircraft. You are deviating from the models approved.
 
bnt83 said:
How do they sign block 4? What version are you working with?

This has been current since 2006.
Pardon,, block #3..
Form_337.pdf

This is the PDF form used to fill out a 337 and print to send to the FAA
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Glad to see you back Tom
Now for all the good people of POA ,would you add your opinion on why It can be easier to be compliant in the repair and maintenance of CAR3 certified aircraft and especially older legacy ones.
 
Tom-D said:
How can that be enforced? How does the FAA know who wrote in the box? be real world.
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It's not a question of being enforced or who wrote or typed the words in the box. All it means is the person authorizing the repair/alteration has submitted the information/data and has approved the process has been completed per the description of work.
bradg33 said:
"Prepare" is subject to interpretation, isn't it? I mean, it's certainly OK for the IA to have an office assistant, secretary or other "helper" actually do the typing at his direction, right? You really think the FAA's goal here was to insist that the IA actually type the data into the form personally with no assistance? I think the intent is to ensure the person performing the repair/alteration is involved in preparing the 337. As an attorney, if I have a paralegal or secretary draft a document for me that I review and sign, I take full responsibility for having "prepared" that document even though I did not necessarily type the information in myself.
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Correct see my statement above
 
Tom-D said:
When you send the 33 to your PMI are you not requesting they approve the modification by signing block #4?
When you as an A&P ask the A&P-IA to sign the return to service block, are you not making a request?

We all can read the 337 instructions at the top of the sheet, So I believe you missed the part where we were requesting a field approval. and that has nothing to do with block 6 & 7. AC 43-210 is the method that the FAA excepts

https://www.faa.gov/regulations_pol...x.cfm/go/document.list?omni=Home-ACs&q=43-210
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As I've stated long ago, always approved 337's myself, probably hundreds, never sent one to "my" PMI, never had one questioned by the FAA.
 
GlennAB1 said:
As I've stated long ago, always approved 337's myself, probably hundreds, never sent one to "my" PMI, never had one questioned by the FAA.
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Maybe I'm misunderstanding. Are you saying you just grant your own field approvals when you make a major modification or repair without approved data?
 
bradg33 said:
Maybe I'm misunderstanding. Are you saying you just grant your own field approvals when you make a major modification or repair without approved data?
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Working for an airline, following our approved General Maintenance Manual, we are authorized to Approve for Return to Service for repairs accomplished using acceptable data. Furthermore, at the airline I currently work, we don't fill out 337's at all.
 
GlennAB1 said:
Working for an airline, following our approved General Maintenance Manual, we are authorized to Approve for Return to Service for repairs accomplished using acceptable data.
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Ok, got it. Sounds like a "unique to the airlines" kind of thing.
 
different rules....different folks....o_O

it dun workie that way for part 91 folk.....outside the repair station environment.
 
weirdjim said:
Uh, yes sir. I wasn't aware it was an amazing fault to admit to ignorance.

Jim
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Many of these things apply worldwide, or nearely so.

Each country's regulator can have their own TCDS. Each TCDS may or may not contain import requirements. Since a DAR has to find the airplane airworthy to issue certificate of airworthiness (or an export CofA) these must be available to review. The catch is, say we have a French built transport category jet in China we want imported into the USA, the TCDS will typically state on it "must be demodified/modified per ____________". The French OEM does not have to give you the kit or the instructions to do it so it may very well be a $500k set of English placards and a few manuals in that kit and the OEM has you by the balls and you must take it to them. It could be a different stall warning system or some other system that is required by the FAA. Since the airplane is in China all the records would have to be translated into English. Any Chinese STCs/major repairs would either have to be FAA validated or removed (unless there is a bilateral agreement which I don't think there is). A letter from Chinese registry stating the airplane has been deregisted and a valid FAA registration is also required for C of A.
 
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GlennAB1 said:
Actually, if you look at AC 43.9-1F, 6., c., the FAA determines that the data used to perform the "major" conforms to accepted industry practices... not approved.
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That is not the verbiage typically stamped in block 3 by the FAA (337 form).
 
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GlennAB1 said:
Actually, if you look at AC 43.9-1F, 6., c., the FAA determines that the data used to perform the "major" conforms to accepted industry practices... not approved.
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Correct, but by signing Block 3 of the 337, the FAA is creating "Approved" data that the IA can use to complete and file the 337 and return the airplane to service. If the IA already had approved data, the field approval wouldn't be necessary.
 
"The data identified herein complies with aplicable airworthiness requirements and is approved only for the above described aircraft subject to conformity inspection by a person authorized in FAR 43.7 signed inspector signiture and office number" was on my last field approval.
 
hotprops said:
Glad to see you back Tom
Now for all the good people of POA ,would you add your opinion on why It can be easier to be compliant in the repair and maintenance of CAR3 certified aircraft and especially older legacy ones.
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FAR 43, makes no difference in the repair requirements of either. WE as part 91 operators, or maintainers don't have much to do with certification of any of the parts or aircraft.
Maybe I'm missing the point, But what do you mean by "easier to be in compliance" both must follow the FARs 43 & 91 So how can there be a difference to us?
 
bradg33 said:
Correct, but by signing Block 3 of the 337, the FAA is creating "Approved" data that the IA can use to complete and file the 337 and return the airplane to service. If the IA already had approved data, the field approval wouldn't be necessary.
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TRUE. And to get back to topic, when you send the 337 to FSDO you are making request they approve the information
 
weirdjim said:
Uh, yes sir. I wasn't aware it was an amazing fault to admit to ignorance.

Jim
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Show me a person who knows every thing about aviation, I'll show you a person who scares me.
 
GlennAB1 said:
Working for an airline, following our approved General Maintenance Manual, we are authorized to Approve for Return to Service for repairs accomplished using acceptable data. Furthermore, at the airline I currently work, we don't fill out 337's at all.
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Certified repair station rules. not part 91 rules.
 
Here is a problem I'm working on today /week
I installed a 0-320- on a PA-28 doing the paper work, I see that this engine has 2 STC added during overhaul.
I have in the paper work packet from the over hauler 4, 337s 2 for each STC.

How do I know if a 337 was sent to the FAA?

I called the overhaul shop, they could not tell me if they had sent one in.
 
Tom-D said:
Here is a problem I'm working on today /week
I installed a 0-320- on a PA-28 doing the paper work, I see that this engine has 2 STC added during overhaul.
I have in the paper work packet from the over hauler 4, 337s 2 for each STC.

How do I know if a 337 was sent to the FAA?
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How does that concern you? Are you the repair station police? Not your responsibility.
 
GlennAB1 said:
How does that concern you? Are you the repair station police? Not your responsibility.
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Easier and quicker to fix now than in 1, 2, 3,...... years. I would do the same, well worth a phone call.

Besides, maybe the paperwork needs an airframe and registration before it can be completed and sent in. Not a big deal in my opinion.
 
Tom-D said:
That is exactly what you are doing when you use the STC on a different model aircraft. You are deviating from the models approved.
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Can you give a source or reference? I still don't get it. I can see using STC data from one aircraft as a basis for a field approval on a totally different aircraft not covered by the original STC. The STC should still be under the control and responsibility of who ever owns it.
 
JAWS said:
Can you give a source or reference? I still don't get it. I can see using STC data from one aircraft as a basis for a field approval on a totally different aircraft not covered by the original STC. The STC should still be under the control and responsibility of who ever owns it.
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My belief is simple, the application list for the STC is a part of the data package. To change that you must request the deviation on a 337. when this is approved, it becomes a field approval to be use on the aircraft stated in block 1
Normally when the STC is still active and being supported, you can call the owner and request the model you are working on be added.
I'd only use the deviation method when the STC is no longer supported.
 
Tom-D said:
My belief is simple, the application list for the STC is a part of the data package. To change that you must request the deviation on a 337. when this is approved, it becomes a field approval to be use on the aircraft stated in block 1
Normally when the STC is still active and being supported, you can call the owner and request the model you are working on be added.
I'd only use the deviation method when the STC is no longer supported.
[/QUOTE}

Have you ever really done this, or is it a "belief" only?
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flyingron said:
Doubtful. 12.5 for oxygen issues is based on where the p02 cross a couple of major numerical limits.
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flyron it was understood it was for ox issues and for a brief time 13k was going to be used .just a old rumor I keep throwing around
 
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