I just returned from an FAA IA seminar, 8 fun filled hours in a metal folding chair, some of the high lights are.
Any 337's dated before 10-1-55 are approved data.
So this means if you can get a copy of a rag wing to metalized wing, form 337, dated before 10-1-55 you don't need to buy the STC. Any form 337 before this date are like a free STC, would really be nice to know what was approved in the old days, like tow hitches?? or maybe an E225 Eng. (TCDS E-267)??, or a Lyc O-340??, maybe rear folding seats??
337 are free from the FAA, IF you know the N number of the plane the was modified.
On a more uglier note, the FAA guy said the field approval for my 8:50 tires only covered the original installation (done in the 80's) and does not cover replacing the tires with the same tires (which would need a new 337?). Also to put 6:00 back on will a new require a 337. Go figure?
Got to love (or hate) the FAA.
Jim
337's dated before 10-1-55
Moderators: GAHorn, Karl Towle, Bruce Fenstermacher
Why would you need another 337 to put 600x6s back on when
those are covered under the type certificate?
With this reasoning, if you did an alternator conversion under
a 337 and the alternator failed a few years later in service, you'd
have to submit for another field approval to put a replacement
alternator in...?
Or if you did a strobe light installation under a field approval and
the power supply failed, you'd have to get another 337 to put
a replacement power supply in?
If what he says is true, why do they make you add "continued
airworthiness & maintenance" instructions on a 337 if the 337
is no good if/when any of the field approved components in
question fail or wear out in service?
I call BS....
those are covered under the type certificate?
With this reasoning, if you did an alternator conversion under
a 337 and the alternator failed a few years later in service, you'd
have to submit for another field approval to put a replacement
alternator in...?
Or if you did a strobe light installation under a field approval and
the power supply failed, you'd have to get another 337 to put
a replacement power supply in?
If what he says is true, why do they make you add "continued
airworthiness & maintenance" instructions on a 337 if the 337
is no good if/when any of the field approved components in
question fail or wear out in service?
I call BS....
Bela P. Havasreti
'54 C-180
'54 C-180
Re: 337's dated before 10-1-55
I would have had to get ugly on that one is there a S/N on the tire that is recorded in the Field approval? NOjims170 wrote: a more uglier note, the FAA guy said the field approval for my 8:50 tires only covered the original installation (done in the 80's) and does not cover replacing the tires with the same tires (which would need a new 337?). Also to put 6:00 back on will a new require a 337. Go figure?
Got to love (or hate) the FAA.
Jim
Tim
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zero.one.victor
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Tom Downey
- Posts: 285
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Re: 337's dated before 10-1-55
You need to get the guys name and askjims170 wrote: On a more uglier note, the FAA guy said the field approval for my 8:50 tires only covered the original installation (done in the 80's) and does not cover replacing the tires with the same tires (which would need a new 337?). Also to put 6:00 back on will a new require a 337. Go figure?
Got to love (or hate) the FAA.
Jim
william.o'Brien@faa.gov
Is what he is putting out the truth?
I'll wager he has a different story next time you call.
what he is putting out is like saying the spark plugs in a engine conversion can't be replaced. he needs to get real. william O'Brien is his boss. like in D.C.
Tom Downey A&P-IA
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Dave Clark
- Posts: 894
- Joined: Mon Apr 22, 2002 6:25 pm
Jimjims170 wrote:Blue, I agree, but this guy was on a 3 month tour from the national office. Mr Bill O'Brien will be retiring next year, so maybe next years IA seminar will be different.
Jim
Did you happen to get his card or have his phone number? Or put me with the sponser of the refresher and I'll track him down.
Dave
Dave
N92CP ("Clark's Plane")
1953 C-180
N92CP ("Clark's Plane")
1953 C-180
Instruction for Continued Airworthiness, ICA
Bela,
Mr. O’Brien used a sex change story to justify why you needed a 337 to change back to the original configuration as a 337 modifies the original TC. He said if a male had a sex change to become a female, it would take another 337 major alteration, to go from female to male again. I did not have the guts to ask him HOW he knew this.
The key to fixing the replacement parts problem is in how the ICA is worded. ICA is Instructions for Continued Airworthiness. You will reference that an ICA is attached to the 337 in block 8, on the back of the 337. The ICA wording can not be included in block 8 as then the FAA would have to consider it Approved Data when an ICA is only Acceptable Data.
When you write the ICA for the strobe light installation you would need to list the required testing and inspection process and if the wing tip power supply failed to meet those requirements, replace it with the following part number, OR ITS EQUALENT PART. That last little statement will give you PMA approval to install a lower cost replacement power supply like an Aeroflash power supply. This last part was the FAA guy’s idea, not mine, but I do love a good loop hole to save a little money.
Another example given was a 337 to put on skis and then a few weeks later another 337 to put it on wheels again. To avoid this, the wording in block 8 must say that BOTH wheels and skis are approved for that aircraft and the ICA would give instruction for changing between the two configurations.
You can take older 337s for major alterations before the ICA policy started on 1-30-1998 and update them with an ICA if you feel there would be a benefit, like a lower cost part or if that part is no longer available. Also, 10 years from now you can revise the ICA if you want, with less or more inspection/testing intervals and of course slipping in some other minor wording changes if needed, like adding plastic bottoms on the skis, as an approved repair process, that were not available 10 years ago when the field approval was first done. SO, when writing an ICA, the goal should be to provide the owner operator with as much benefit as possible, basically you are writing a maintenance manual for that aircraft that will become Acceptable Data in the eyes of the FAA.
Here are some links with more info I got from the Spokane, WA FSDO web site.
The first link has info on the FAA seminar I attended. The next two links deal with the whole field approval process: AC 43-210. Bill O’Brien wrote the ICA policy; he is very knowledgeable about the process. As an IA, this seminar was the most enlightening IA renewal seminar yet. In my 20+ years of attending IA seminars it seems to me that for the most part that the wording in the Regulations has stayed the same but the interpretations may differ depending who’s currently on the throne.
Jim
http://www.faa.gov/about/office_org/fie ... eminar.pdf
http://www.faa.gov/about/office_org/fie ... /fsdo/spo/
http://www.airweb.faa.gov/Regulatory_an ... 43-210.pdf
Mr. O’Brien used a sex change story to justify why you needed a 337 to change back to the original configuration as a 337 modifies the original TC. He said if a male had a sex change to become a female, it would take another 337 major alteration, to go from female to male again. I did not have the guts to ask him HOW he knew this.
The key to fixing the replacement parts problem is in how the ICA is worded. ICA is Instructions for Continued Airworthiness. You will reference that an ICA is attached to the 337 in block 8, on the back of the 337. The ICA wording can not be included in block 8 as then the FAA would have to consider it Approved Data when an ICA is only Acceptable Data.
When you write the ICA for the strobe light installation you would need to list the required testing and inspection process and if the wing tip power supply failed to meet those requirements, replace it with the following part number, OR ITS EQUALENT PART. That last little statement will give you PMA approval to install a lower cost replacement power supply like an Aeroflash power supply. This last part was the FAA guy’s idea, not mine, but I do love a good loop hole to save a little money.
Another example given was a 337 to put on skis and then a few weeks later another 337 to put it on wheels again. To avoid this, the wording in block 8 must say that BOTH wheels and skis are approved for that aircraft and the ICA would give instruction for changing between the two configurations.
You can take older 337s for major alterations before the ICA policy started on 1-30-1998 and update them with an ICA if you feel there would be a benefit, like a lower cost part or if that part is no longer available. Also, 10 years from now you can revise the ICA if you want, with less or more inspection/testing intervals and of course slipping in some other minor wording changes if needed, like adding plastic bottoms on the skis, as an approved repair process, that were not available 10 years ago when the field approval was first done. SO, when writing an ICA, the goal should be to provide the owner operator with as much benefit as possible, basically you are writing a maintenance manual for that aircraft that will become Acceptable Data in the eyes of the FAA.
Here are some links with more info I got from the Spokane, WA FSDO web site.
The first link has info on the FAA seminar I attended. The next two links deal with the whole field approval process: AC 43-210. Bill O’Brien wrote the ICA policy; he is very knowledgeable about the process. As an IA, this seminar was the most enlightening IA renewal seminar yet. In my 20+ years of attending IA seminars it seems to me that for the most part that the wording in the Regulations has stayed the same but the interpretations may differ depending who’s currently on the throne.
Jim
http://www.faa.gov/about/office_org/fie ... eminar.pdf
http://www.faa.gov/about/office_org/fie ... /fsdo/spo/
http://www.airweb.faa.gov/Regulatory_an ... 43-210.pdf
Approved data 337, 10-1-55
http://www.faa.gov/library/manuals/exam ... 001_00.pdf
Form 337s before 10-1-55
Here is the link which list what is approved data, the info is on the first page.
Jim
Form 337s before 10-1-55
Here is the link which list what is approved data, the info is on the first page.
Jim
on our research aircraft at work, when we modify them we certify them in multiple category. so when they are equipped for work they are in Restricted category, take it all off and you are in standard category. instead of an ICA sheet we use a "conversion manual", specific to each airplane type. we reference the "latest revision" of the conversion manual in the 337, then I can update them as needed. does the same thing as an ICA sheet like described above, just a bit more involved.
this way I can leave the wiring and hardpoints installed even while in std category, because I say how that is done in the conv. manual.
before we did this, we worded the 337's to show how to go back and forth from std to restr and back, I still do that sort of thing for ferry tank installations. now we are a little more involved but it works the same and keeps the federales happy.
Hans
this way I can leave the wiring and hardpoints installed even while in std category, because I say how that is done in the conv. manual.
before we did this, we worded the 337's to show how to go back and forth from std to restr and back, I still do that sort of thing for ferry tank installations. now we are a little more involved but it works the same and keeps the federales happy.
Hans
'56 "C170 and change"
'52 Packard 200
'68 Arctic Cat P12 Panther
"He's a menace to everything in the air. Yes, birds too." - Airplane
'52 Packard 200
'68 Arctic Cat P12 Panther
"He's a menace to everything in the air. Yes, birds too." - Airplane
The last 3 IA seminars that I have been to Mr. O’Brian was the key note speaker and he was the person who wrote most of the ICA so I would take him at his word. Did he give you the VCR in the biz jet story? And what is your RA number?
Bill
- Hi Bill, Yes on the VCR story, not sure on the RA number thing???
But I do remember the first rule, no sleeping in class.
It really does not help to sit in the back when he has a wireless mic and walks around the room.
Jim