The International Cessna^® 170 Association

I don't know whether an IA or an A&P is required to do the logbook entry on a TC approved item, but I can tell you that, according to the FSDO here, no 337 is required, desired, or even hinted at on a standard installation of items approved on the TCDS.

Note that this does not speak to REPAIRS, only to installations.

For example, my airplane has Federal AWB 2500 wheel skis. They are approved on the TCDS. I specifically asked a FSDO inspector if I should submit a 337 to cover my butt. His response was, "Hell, no".

Folks thinking this stuff is gray areas is what got us into the whole field approval mess to start with.

If its a minor repair or alteration, it does not require a 337. If it's an installation that's approved on the TCDS, it does not require a 337. There is no grey area involved.

Now, if you replace half the fuselage with a comparable part, that is a major repair, not an installation. Different deal, and frankly, I don't know if that requires a 337 or not.

But, do not for a moment believe that EDO 2000 floats on a 170B require a 337 to cover the installation. I'd take that one to the bank.

Mike Vivion

I think its great when an FAA guy actually wants less paperwork

Go back and re-read FAR 1 and FAR 43, Appdx A, Major repairs, and Major alterations. Replacing half the fuselage is a major repair and requires a 337.

gahorn wrote:Go back and re-read FAR 1 and FAR 43, Appdx A, Major repairs, and Major alterations. Replacing half the fuselage is a major repair and requires a 337.

Here is the reg..

43-A b (1)
(1) Airframe major repairs. Repairs to the following parts of an airframe and repairs of the following types, involving the strengthening, reinforcing, splicing, and manufacturing of primary structural members or their replacement, when replacement is by fabrication such as riveting or welding, are airframe major repairs.

Please do not confuse "repair" with "replacement".

IF you "repair" the fuselage by fabricating parts or changing the design by patching you need the 337.

IF you buy all Cessna replacement parts you did not alter the aircraft. you do not need the 337.

Tom Downey wrote:

gahorn wrote:Go back and re-read FAR 1 and FAR 43, Appdx A, Major repairs, and Major alterations. Replacing half the fuselage is a major repair and requires a 337.

Here is the reg..

43-A b (1)
(1) Airframe major repairs. Repairs to the following parts of an airframe and repairs of the following types, involving the strengthening, reinforcing, splicing, and manufacturing of primary structural members or their replacement, when replacement is by fabrication such as riveting or welding, are airframe major repairs.

Please do not confuse "repair" with "replacement".

IF you "repair" the fuselage by fabricating parts or changing the design by patching you need the 337.

IF you buy all Cessna replacement parts you did not alter the aircraft. you do not need the 337.

Thanks for posting that, but (respectfully) I disagree with that final sentence, Tom.

To simplify the rule a little: Airframe major repairs. Repairs to the following parts of an airframe and repairs of the following types, involving the strengthening, reinforcing, splicing, and manufacturing of primary structural members or their replacement, when replacement is by fabrication such as riveting or welding, are airframe major repairs.

Unless JB Weld was used ...then that half-fuselage was replaced by riveting...and although it may have been made by Cessna....it is still a major repair and requires a 337 because it is primary structure. IMHO

George,

In the picture above the panel I am replacing is Cessna part that I bought from a Cessna parts supplier [part # 0512000-8].

Is your interpretation that if I use rivets I will have to fill out a 337 and if I use AN grade structual screws and nuts or JB Weld I will not have to fill out the 337?

Johneb

If you use rivets it is a repair to a primary structure and needs a 337. If you try to get around that by using an fasteners in place of the rivets it then becomes an alteration and you still need a 337.

Scenario one: John goes with the bolts, this is now considered an alteration & as such requires a 337. Who can sign off (approved for return to service)? My understanding is that as an alteration it requires an FAA Inspector's sign-off ("field approval"). This would go in Box 3 of the form 337.
Scenario two: John sobers up,and realizes that rivets are the proper method of attaching the new skin. This is considered a repair & also requires a 337. Now who can sign off on that 337? It is an approved method of repair, so a field approval should not be required. Does an IA have to sign, or can the A&P who performed or supervised the work sign off on it?
Box 7 ( approval for return to service) on the bottom of the Form 337 has a buncha check-off boxes for sign-offer to choose from: FAA Flt Standards Inspector,FAA designee,Manufacturer,repair station, IA,Person approved by transport canada airworthiness group, and other. I don't see A&P listed, is he included in "other"?
And what's with the reference to Transport Canada? This is an FAA form.
( I'm so confused )

Eric

The reference to Canada might have something to do with the JAA (Joint
Airworthiness Authorities) bilateral agreement the FAA has with Transport
Canada (and various other countries).

zero.one.victor wrote:Scenario one: John goes with the bolts, this is now considered an alteration & as such requires a 337. Who can sign off (approved for return to service)? My understanding is that as an alteration it requires an FAA Inspector's sign-off ("field approval"). This would go in Box 3 of the form 337.
Scenario two: John sobers up,and realizes that rivets are the proper method of attaching the new skin. This is considered a repair & also requires a 337. Now who can sign off on that 337? It is an approved method of repair, so a field approval should not be required. Does an IA have to sign, or can the A&P who performed or supervised the work sign off on it?
Box 7 ( approval for return to service) on the bottom of the Form 337 has a buncha check-off boxes for sugn-offer to choose from: FAA Flt Standards Inspector,FAA designee,Manufacturer,repair station, IA,Person approved by transport canada airworthiness group, and other. I don't see A&P listed, is he included in "other"?
And what's with the reference to ransport Canada? This is an FAA form.
( I'm so confused )

Eric

No an A&P cannot sign off in Section 7. Commonly in our world, an IA signs this off in both cases you mention. Never had an FAA inspector volunteer to sign one off for me either. Don't know what other would include.

S2D wrote: No an A&P cannot sign off in Section 7. Commonly in our world, an IA signs this off in both cases you mention. Never had an FAA inspector volunteer to sign one off for me either. Don't know what other would include.

Here's a scenario:
An A&P does or supervises repair work (pre-approved by compliance with FAR guidelines &/or type certificate), or installation of an STC (pre-approved by STC). He signs off the work or installation in section 6 "conformity statement", it has a checkoff box for "US certificated mechanic". He then gets his local FAA guy (Primary Maintenance Inspector?) to countersign in section 7 "approval for return to service". Because there is no IA handy or he's pissed him off, or whatever. Most IA's are gonna want $ for their signature, whereas it's part of the FAA guy's job- no extra $ required.
That's my take on one possible way things could go.

Eric

I'm trying to follow your scenario. I believe the answer is that an A&P needs to have a Inspection Authorization in order to determine that the aircraft after it is modified by what ever approved method meets the TCDS, STC or previously approved 337 for that aircraft. The FAA guy is NOT going to sign for the IA because it's NOT his job and regardless of his qualifications he WON'T nor would he be ALLOWED to take on that responsibility. Remember the FSDO guy may not know a darn thing other that paperwork. When you ask for an approval he reviews your approved data and if you don't have that you need to go to a DER to obtain approved data. In short the FSDO inspector is only inspecting your paperwork not the work performed. The IA is inspecting the work performed.

Does that make sense?

That's exactly my point, Bruce. The A&P has performed work that is already "approved", either by STC or by the original TCDS & the FAR's governing repair work & acceptable methods thereof. This scenario is not a "field approval" situation. The A&P is signing off the work, the FAA rep would be signing off the paperwork in leiu of an IA.
Otherwise why have a checkoff box labelled "FAA flight Standards Inspector" in section 7? They already have a place for an FAA approval up in section 3 of the 337. This is where a "field approval" would be signed off. But even then, section 7 "approval for return to service" would still have to be signed off. On a field approval-type 337 in my airplane files, an A&P signed off section 6, the FAA signed off section 3, then an IA signed off section 7. And in that order, per the dates on each signature. But it seems like an FAA rep could have signed off section 7 instead if an IA was not involved--like I said, there's a pre-labelled box for him to check-off & sign.

Eric

You are probably right Eric. An FAA insp could probably do it in a situation where no IA was available. Getting one to do it would be another issure.