337 challenges

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337 challenges

Post by 6843 »

Hi All,

I recently talked to my AI about submitting a 337 to install 8.50 tires. I provided a copy of a previously approved 337 (found in the archives) under the impression it would make my application "almost" automatic. My AI replied a few years ago the FAA told FSDO's anyone approving a 337 would be personally responsible/liable for the approval and, as a result, (at least the Scottsdale, AZ) the FSDO was not approving any 337 applications. Has anyone else heard this? Are 337's being processed by other FSDOs? If other FSDOs are approving 337s, am I allowed to submit an application to a FSDO in another state?

Thanks for sharing your experiences,
Dave
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Re: 337 challenges

Post by a64pilot »

6843 wrote: Sat Jan 23, 2021 12:10 pm Hi All,

I recently talked to my AI about submitting a 337 to install 8.50 tires. I provided a copy of a previously approved 337 (found in the archives) under the impression it would make my application "almost" automatic. My AI replied a few years ago the FAA told FSDO's anyone approving a 337 would be personally responsible/liable for the approval and, as a result, (at least the Scottsdale, AZ) the FSDO was not approving any 337 applications. Has anyone else heard this? Are 337's being processed by other FSDOs? If other FSDOs are approving 337s, am I allowed to submit an application to a FSDO in another state?

Thanks for sharing your experiences,
Dave

I was told the same thing by my PMI a few years ago, about the personally responsible thing, It’s BS, you can under the same logic sue them for not processing a field approval, but I think it’s a good excuse for them.
The truth is they are somewhat judgement proof based on their assets, or lack of anyway. Now if they won the lottery or inherited millions, then maybe a Lawyer would pursue a case against them.

I was told of you really want it, to peruse a one time STC, which of course puts the issue onto a DER, and your pocketbook.

The truth varies from FSDO to FSDO, I believe big tires are pretty much if a non issue in AK for instance.
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Re: 337 challenges

Post by 6643 »

Just a little clarification:

What you need is a field approval. The 337 is merely the form you file to record a major repair or major modification. Every 337 needs approved data. In your case, the approved data is the field approval.

One thing you can try (besides another IA) is to get an A&P to fill out a 337 covering the installation. The FAA provides guidance on filling them out (AC 43.9-1F) and you want to be sure you either cover each point, or can explain why it isn't applicable. One hot section is the instructions for continued airworthiness. Also, any interaction between your mod and other installed mods, like wheel pants or extenders.

Take your 337 and the previously approved 337 to the FSDO and talk to the PMI. Have the A&P or IA accompany you if you can.

If you can do this in the same FSDO as the previously approved one, they'll have a harder time denying it.

If they approve, they will fill in block 3 on your 337 and you're good to go. An IA will have to sign off the installation as complying with the data you supplied, but bears no liability beyond that.
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Re: 337 challenges

Post by 8233 »

I have used a DER for a few things on mine just to avoid the whole FSDO equation. If a DER approves it and gives you a 8110-3, your mechanic can install and send the 337 straight to OKC since a DER approval means it was FAA approved.

If you want, you can contact him and he can tell you if he can help. His fees are very reasonable for what I have had done. I have used him for Grove axles, Odyssey battery and also for a prop that came on my 120 that was on the TCDS for a C-85 but not for a C-90.

https://dc65stc.blogspot.com/?fbclid=Iw ... tM-xWjcM0U

I'm sure there are others on here that would say it's not needed and they are right depending on the FSDO. In my case, it would have cost me more to have my IA try to take the 337 through FSDO than what I ended up paying a DER.

YMMV
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Re: 337 challenges

Post by 6643 »

8233 wrote: Sat Jan 23, 2021 3:06 pm DER approval means it was FAA approved.
The work product of a DER is another form of approved data. It is generally used to support a field approval. I have never tried to use it as stand alone approval, but I don't think mailed-in 337's receive a lot of scrutiny in OKC...

Here is my course material on approved data:

Types of Approved Data

Approved data to be used for major repairs and major alterations may be one or more of the following.

1. Type Certificate Data Sheets
2. Aircraft Specifications
3. Supplemental Type Certificates (STC's) (Note: Persons interested in using an STC must have approval in accordance with 49 U.S.C., section 44704, from the holder of the STC prior to it's use.)
4. Airworthiness Directives (AD's)
5. Manufacturer's FAA Approved Data (DOA)
6. Designated Engineering Representative (DER) Approved Data With FAA Form 8110-3, Statement of Compliance (Note: This type of data usually requires additional approval.)
7. Designated Alteration Station (DAS) Approved Data
8. Appliance Manufacturer's FAA Approved Manuals (Excluding Installation Instructions)

AC 43.13-1, Acceptable Methods, Techniques, and Practices (Aircraft Inspection and Repair), may be used directly as approved data (for repairs only) without further approval only when there is no manufacturer repair or maintenance instructions that address the repair and the user has determined that it is:
• appropriate to the product being repaired;
• directly applicable to the repair being made; and
• not contrary to manufacturer's data.

AC 43.13-2, Acceptable Methods, Techniques, and Practices – Aircraft Alterations may be used as approved data for major alterations when the AC chapter, page, and paragraph are listed in block 8 of FAA Form 337 when the user has determined that it is:
• appropriate to the product being altered;
• directly applicable to the alteration being made; and
• not contrary to manufacturer's data.

FAA FIELD APPROVAL (FAA FORM 337) issued for duplication of identical aircraft may be used as approved data only when the identical alteration is performed on an aircraft of identical make, model, and series by the original modifier. (I recall the form 337 used to have a block you could check if you were applying for multiple approvals, sort of like a personal STC.)

FAA Form 337's approved in 1955 or earlier may be used as approved data.

Previously approved 337s from 1956 and later can be used as acceptable data in support of a field approval.
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Re: 337 challenges

Post by 8233 »

Interesting John. I always understood that the approval of a DER was essentially a field approval meaning you don't have to involve FSDO but the AP or IA does have to properly document the work performed on the 337 and mail it into OKC. I look at a DER for alterations, etc as I would a DPE for ratings. Neither work for the FAA but they have completed the necessary steps to speak on behalf of the FAA when it comes to certain subject areas.

Have I been looking at this wrong?
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Re: 337 challenges

Post by 4004 »

The FSDO management structure has changed in the last 5-10 years. I needed a field approval a few years ago and my contact at the FSDO (not the usual PMI) had retired - I had developed the contact at the FSDO and used him for numerous field approval - some had to be forwarded to ACO for coordination. We had both worked at Langley but years apart - me at NACA and he when it morphed into NASA.

When I called about the more recent field approval and asked for the area PMI, I was told we don't do that anymore- you just send it in and the "Front Line Manager" (FLM) assigns the FA to whomever he wants to handle it, however, the Inspector asked what the FA was about and I discussed it - it was not a slam dunk - rather complicated having to do with shoulder strap installation referencing the technical data from an STC kit with the owners permission. The Inspector said send it to me and I'll discuss with the FLM since I understand what your doing and possibly the FLM will permit me to process (found out he's an avionics contact)! FA came back approved, as written, with no changes required!

So, I suggest you have your info ready and call the FSDO and ask to speak with an Inspector or even the FLM. Present your case as Owner/Operator, you have nothing to loose. The IA maybe sensitive to the protocol etc. but you as O/O can go direct. Even when I was working with my "friend" and I knew that the ACO would have to be involved, I would call the applicable ACO and speak with the cognizant engineer and get a tacit approval of my approach. Possibly Jody will comment but your case just depends on your local FSDO and not complicated, oh yeah, I think you asked about other FSDOs - yes I have heard that one O/O or A&P can/may send a FA to any FSDO but I've never tried to or needed to. 2C
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Re: 337 challenges

Post by 6643 »

8233 wrote: Sat Jan 23, 2021 10:37 pmHave I been looking at this wrong?
I don't know. From my own knowledge I could argue it both ways. The stickler is the wording "Note: This type of data usually requires additional approval." How do you find out if additional approval is required? I'd say, "ask the FSDO to sign block 3"...
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Re: 337 challenges

Post by 8233 »

John, which document are you pulling out that info that you pasted above pertaining to types of approved data?

I went down a rabbit hole doing some reading around the topic but couldn't find what you referenced. I did find some other things that depending on the scope of the alteration or repair, the DER approval can be considered a full field approval but the A&P/IA is responsible for assuring conformity of installation to the approved design data including any required ICAs. Sounded like it really depended on the scope of the major alteration or repair in respect to whether the data is beyond the authority of the DER to approve or not. In my case, the DER was designated a vintage DER and the types of alterations fell into his approval authority. That's how it reads to me anyway. Always learning...
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Re: 337 challenges

Post by a64pilot »

I think unless things have changed there is “Approved” data, and data that may be “Acceptable” to the administrator.
I believe for instance 43.13 which you would think is the Bible, is only data that May be acceptable, it is NOT approved data.
you would think if anything was it would be, but it’s not, or didn’t used to be anyway.

There are many,many disciplines of DER. DER is of course a designated engineering representative, they are for all intents and purposes the FAA.
However the FAA has oversight.

For example say your Certifying a brand new airplane, in theory y9u can have the FAA conduct the Certification test flights, it is after all their job.
If you go that route you will never be Certified, they are just too busy what with all the T times and Fridays off etc so they never get to you.

So you get a DER and pay them conduct the test flights and write reports, the FAA review the reports and almost always will come fly a few, very few and never any dangerous test points to validate the DER’s work and then your done, at least with test flights anyway.

So you hire a DER to design a shoulder harness system because there is no STC for your airplane, he does so, and it goes to the FAA who will after letting it grow mold for awhile almost always sign off on it and you get a one time STC for seat belts or maybe a field approval.

The FAA doesn’t like field approvals, especially repetitive ones, they want an STC, that way it doesn’t cut into T times etc.


So in theory you take a previously approved 337 that was used to document a field approval to the FSDO along with your filled out 337, and if he’s in a good mood and you display an acceptable amount of respect, then odds are he’ll sign off your field approval.

Now the owner really doesn’t have a dog in this fight, this is between the FAA and the IA, so as an owner I wouldn’t even show up, in my opinion it’s likely that you would do more harm than good being there.

Usually these things are done when a PMI is visiting the IA’s business and not by visit to the FSDO
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