Up here in Alaska, we have a "stay"against change 15 to the 8300-10 aviation inspector handbok guidance. Everywhere else in thelower 48 states the inspectors are to follow change 15. Change 16 is in the works but I have not seen it yet. Change 15 limits what the FAA inspector can approve on his own. Things that could be field approved a year ago , now much be sent to the ACO(Aircraft Certification Office) office for their concurrence and or approval of data. I was told this was done in a effort to standardize how field approvals are handled at all offices with standardization the goal. So right now, here in Alaska, we can get things approved that can't be done in the lower 48, but this is about to change I think.
Major alterations and major repairs have to have "FAA Aproved DATA" on the back. There are several ways to do this. 1)STC,2)TC 3)DER approved data 4)FAA/ASI (field approved data). AC 43.13-1B can be used as FAA APPROVED data witin the limitaitons spelled out on the inside of the front cover. The repair must meet three criteria.(1) it must be applicable to hte repair(2) it cannot be contrary to manufactureres data(3)yo must cite chapter, section and paragraph of hte part used. see the inside of the front cover of AC43.13-1B.... AC 43.13-2A is "acceptable data only and if cited must be field approved...if used for an alteration.period.
FAA field approvals
Moderators: GAHorn, Karl Towle, Bruce Fenstermacher
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H. Mark Smith
- Posts: 18
- Joined: Sat Dec 28, 2002 5:33 am
field approvals
IT's been a few years now since change 15 of the 8300.10 faa inspectors handbook guidance went into effect...in fact we are up to change 22 I think.We, (FAA ASI's) are still doing field approvals here in Alaska.AC 43-210 explains how to proceed with a field approval. I still get calls from A&P/IA's who ask if the FAA will approve this or that...If I think it is possible I tell them. Most of the time it boils down to this:
1) Is it a major change to the type design/ if yes then probably an STC is appropiate
ifNO, then is it a major or minor alteration or repair, if major, proceed on
if minor, logbook entry.The FAA ASI is supposed to give you an answer on this question. Sometimes they don;t know and have to go to the ACO to get help to decide.(Major/Minor)
I tell most people to prepare a field approval proposal and submit it to the FSDO.....make sure you address the 16 ICA's. This seems to be the most difficult part for A&P's, it really is mostly data on how the alteration will be maintained....so you need maint. manuals or other info on how to maintain the alteration for instance.
The FAA is in the process of becoming ISO9000 registered. This I believe is being pursued to insure STANDARDIZATION in Flight Standards..Policy, procedures on the EAST coast should be the same on the west coast and ALASKA.This lack of standardization has been a real problem and continues to be within within the FAA.
Part of the reason the Field approval process was tightend up was because there was serious lproblem with some FAA inspectors NOT following hand book guidance and FAA policy. There are stories of Lear jets having cargo doors field approved, with NO DATA !!!I know in Alaska there are a lot of pretty wild mods out there that were field approved. I saw a Cessna 170 with an IO-360, 200 h.p. Lycoming with an 84" Hartzell prop installled using the field approval process. The only way to retract an inproper field approval once it is issued, is for the FAA to issue an AD note and to my knowledge, this hasn;t happend....
Field approvals are known as "DEMAND WORK" . FAA inspectors get no points or "complexity" for doing field approvals and worse, we could get in serious trouble if we approve them inappropiately up to and including being held liable if we operate outside our FAA guidnace. Most of the inspectors like myself do field approvals because we came from industry, we were A&P/IA's and Pilots long before we went to work for the FAA. Most of us have 30 years + in industry before working for the FAA.Some of us still fly and work on our own aircraft, belong to the EAA, AOPA and the 170 Association. Most of us LIKE airplanes, and flying.....
IF an alteration results in changes to the published airplane performance data,ie. range, rate of climb, takeoff or landing distance for instance, an airplane flight manual supplement may be required. FAA inspectors can not approve AFM supplements, but the Aircraft Certification office can (ACO). This is accomplished thru a process known as a "co-ordinated field approval" or CFA.... Some other changes in the works are:
IN Alaska, external loads are allowed, like lashing loads to aircraft floats. FAA is currently looking into allowing external loads in the lower 48 as well.
FAA in Washington is working on making parts of AC 43.13-2A and some manufacturers manuals sections into FAA approved data, like the SRM sections of the Cessna 100 series manual.....FYI
1) Is it a major change to the type design/ if yes then probably an STC is appropiate
ifNO, then is it a major or minor alteration or repair, if major, proceed on
if minor, logbook entry.The FAA ASI is supposed to give you an answer on this question. Sometimes they don;t know and have to go to the ACO to get help to decide.(Major/Minor)
I tell most people to prepare a field approval proposal and submit it to the FSDO.....make sure you address the 16 ICA's. This seems to be the most difficult part for A&P's, it really is mostly data on how the alteration will be maintained....so you need maint. manuals or other info on how to maintain the alteration for instance.
The FAA is in the process of becoming ISO9000 registered. This I believe is being pursued to insure STANDARDIZATION in Flight Standards..Policy, procedures on the EAST coast should be the same on the west coast and ALASKA.This lack of standardization has been a real problem and continues to be within within the FAA.
Part of the reason the Field approval process was tightend up was because there was serious lproblem with some FAA inspectors NOT following hand book guidance and FAA policy. There are stories of Lear jets having cargo doors field approved, with NO DATA !!!I know in Alaska there are a lot of pretty wild mods out there that were field approved. I saw a Cessna 170 with an IO-360, 200 h.p. Lycoming with an 84" Hartzell prop installled using the field approval process. The only way to retract an inproper field approval once it is issued, is for the FAA to issue an AD note and to my knowledge, this hasn;t happend....
Field approvals are known as "DEMAND WORK" . FAA inspectors get no points or "complexity" for doing field approvals and worse, we could get in serious trouble if we approve them inappropiately up to and including being held liable if we operate outside our FAA guidnace. Most of the inspectors like myself do field approvals because we came from industry, we were A&P/IA's and Pilots long before we went to work for the FAA. Most of us have 30 years + in industry before working for the FAA.Some of us still fly and work on our own aircraft, belong to the EAA, AOPA and the 170 Association. Most of us LIKE airplanes, and flying.....
IF an alteration results in changes to the published airplane performance data,ie. range, rate of climb, takeoff or landing distance for instance, an airplane flight manual supplement may be required. FAA inspectors can not approve AFM supplements, but the Aircraft Certification office can (ACO). This is accomplished thru a process known as a "co-ordinated field approval" or CFA.... Some other changes in the works are:
IN Alaska, external loads are allowed, like lashing loads to aircraft floats. FAA is currently looking into allowing external loads in the lower 48 as well.
FAA in Washington is working on making parts of AC 43.13-2A and some manufacturers manuals sections into FAA approved data, like the SRM sections of the Cessna 100 series manual.....FYI
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futr_alaskaflyer
- Posts: 369
- Joined: Sat Jan 21, 2006 6:27 am
good info
Really good info, I was curious how it seemed to be working differently up here than other places I've been.
Is this how most "non-standard" propellers are approved in Alaska? For instance, a 170B (which will remain nameless
) with an 80 inch McCauley on the stock engine and 8.50 tires? No STC...and that would not be a "minor" 
Is this how most "non-standard" propellers are approved in Alaska? For instance, a 170B (which will remain nameless
) with an 80 inch McCauley on the stock engine and 8.50 tires? No STC...and that would not be a "minor" -
H. Mark Smith
- Posts: 18
- Joined: Sat Dec 28, 2002 5:33 am
propeller approvals
I only check this web site occasionally ....propeller approvals can be difficult. There is an STC out there to install a McCauley 80" fixed pitch prop on a stock Cessna 170B. Alaska Propeller Specialists used to have one, now Kenmore Air Harbor has it I think.
Other props may be eligible for field approval if applicant can show:
(1) still meets the prop ground clearance in CAR3(actually measure it)
(2) the prop is compatible with the engine vibration wise.(look at the TCDS for the prop or call the MFG. for this info.)
(3) can't exceed 4" over largest approve diameter , otherwise you will have to show compliance with FAR36 (Noise)which is very costly.
The ACO has figured out how to do this by issuing an Aircraft Flight Manual Supplement imiting T.O.power to 5 minutes, the placarding the M.C.P. (max. Continous Power)
(4) If you go over 4" past biggest diameter approved,you may also have to show compliance with a flight test to demonstrate control, (very costly)
I'm shooting from the hip here but this should give you some idea.
Hope this helps....
Other props may be eligible for field approval if applicant can show:
(1) still meets the prop ground clearance in CAR3(actually measure it)
(2) the prop is compatible with the engine vibration wise.(look at the TCDS for the prop or call the MFG. for this info.)
(3) can't exceed 4" over largest approve diameter , otherwise you will have to show compliance with FAR36 (Noise)which is very costly.
The ACO has figured out how to do this by issuing an Aircraft Flight Manual Supplement imiting T.O.power to 5 minutes, the placarding the M.C.P. (max. Continous Power)
(4) If you go over 4" past biggest diameter approved,you may also have to show compliance with a flight test to demonstrate control, (very costly)
I'm shooting from the hip here but this should give you some idea.
Hope this helps....