Missing 337s - When Opinions Collide

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kontiki

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Anybody got experience with missing 337s?

I bought my Grumman Tiger last August.

Per the airframe log, two owners ago (2007), an A&P replaced the McCaulley prop with a Sensenich Prop, per an STC. It's a good STC, I obtained a copy and permission to use it on my airplane.

Unfortunately, the A&P's 337 isn't in the records I obtained from the FAA.

I pulled the prop and verified all the P/Ns and S/Ns are correct. I thought it might be a good idea to have a complete set of records. The airplane is technically fine.

One DER buddy (structures at an airline) told me I could simply file a Missing 337.

I filled one out and took it to an IA for signature, and he's reluctant. He thinks I'm better off doing nothing. He said that the FAA would probably kick it back or go crazy and ground me or something.

Anybody got any helpful suggestions?

Anybody know how to get straight scoop from the FAA for questions like these?
 
The DER is right, and your mechanic is wrong. All your mechanic need do is review the STC, check the installation, and write it up as reviewed and in compliance with the STC. Send in the 337, and you're done -- the FAA isn't going to come after you over a lost 337 as long as the work was done right and you corrected the problem. OTOH, if the FAA ever gets involved and finds you have an undocumented alteration, you'll be the one who pays the price.

BTW, do you have a copy of the 337 the 2007 mechanic should have done to document the alteration? IOW, was it merely lost in transit between the 2007 mechanic and OKC, or was it not done at all? If the former, you need only send a new copy of that old 337 to OKC.
 
There were a few missing STCs when I bought my plane (Rosen visors, updated air vents, and something else). I followed the process Ron described; simple and no drama. It was maybe an hour of the mechanic's time to do it.
 
BTW, what's going to happen if you ever want to sell the plane, and the buyer (or the buyer's mechanic) catches this (pretty near 100% likelihood if the buyer knows what s/he's doing)?

This begs another question -- who did your pre-purchase inspection and didn't notice this? And what else did s/he miss? :eek:
 
Ron Levy said:
BTW, do you have a copy of the 337 the 2007 mechanic should have done to document the alteration? IOW, was it merely lost in transit between the 2007 mechanic and OKC, or was it not done at all? If the former, you need only send a new copy of that old 337 to OKC.
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I assume the A&P wrote one and it got lost in 2007, but I really don't know any more about it. I haven't tried to find the guy.

The mater got a little more complicated because the owner I bought it from (one owner after the STC) had the prop pulled and sent to Sensenich to be repitched, which changes the P/N; it went from a -62 to -63 (all acceptable under the STC). The log entry for that re-installation doesn't contain the P/N. But the previous owner kept the Sensenich Release Tag, which is how I picked up on the possibility the P/N rolled.

The shop that did the annual/pre-buy for me botched the log signoff by pasting in a signoff for another Grumman on the field. I went back and got it corrected once. They used the P/N & S/N from the 2007 log entry (before the pitch change) in their correction.

They did mention that they didn't see a 337 in the records, but they did see the log book entry and felt it was OK.

When it all sank in for me, I pulled the prop and reinstalled it, to confirm the P/N and SN installed and that all was done IAW the STC. My log entry reflects the correct P/N and S/N. Before doing that, I really couldn't say what was on the airplane.

Regarding what else might have been missed. Look for my thread on Powerflow Exhaust posted maybe last Sept.
 
In 1998, at my first annual inspection of my 1975 Piper Warrior, the mechanic discovered that the plane had Aeroflash strobes installed.

Unfortunately, there was no STC for Aeroflash strobes on a Warrior, and no 337. To my amazement (this was my first plane, and my first annual, and this shop had done the pre-buy inspection) the FAA forced me to REMOVE THE STROBES.

I was astounded. They were working just fine. They had been on the plane for 15 years. I begged them to let me at least keep the wiring in the wings, so that we could install the "proper" Whelen strobes without having to re-route the wiring. After he felt that I had performed the appropriate amount of groveling, the gummint drone "allowed" the wiring to stay.

Two things were learned that day:

1. I never did business with that shop again, and they went bankrupt soon thereafter.

2. I learned to NEVER volunteer information like that to the FAA. Once the drones find out about any paperwork issue, no matter how small, none of them will ever go out on the limb of common sense to save you.

Say nothing, keep your head down and feet moving.
 
Jay Honeck said:
In 1998, at my first annual inspection of my 1975 Piper Warrior, the mechanic discovered that the plane had Aeroflash strobes installed.

Unfortunately, there was no STC for Aeroflash strobes on a Warrior, and no 337. To my amazement (this was my first plane, and my first annual, and this shop had done the pre-buy inspection) the FAA forced me to REMOVE THE STROBES.

I was astounded. They were working just fine. They had been on the plane for 15 years. I begged them to let me at least keep the wiring in the wings, so that we could install the "proper" Whelen strobes without having to re-route the wiring. After he felt that I had performed the appropriate amount of groveling, the gummint drone "allowed" the wiring to stay.

Two things were learned that day:

1. I never did business with that shop again, and they went bankrupt soon thereafter.

2. I learned to NEVER volunteer information like that to the FAA. Once the drones find out about any paperwork issue, no matter how small, none of them will ever go out on the limb of common sense to save you.

Say nothing, keep your head down and feet moving.
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We could also make the analogy that every small owner motel is a fleabag, but that would be unfair, right?

FWIW, while I worked at the agency we had a few cases of missing paperwork, and even one case of the wrong engine installed on a Bonanza.

We worked with the owners to correct the situation and get everything into compliance, and even on the Bonanza getting a special approval done through a local DER.

Not all Inspectors are evil.
 
to echo the comments by anonymous above, I've been helped many times by fsdo staff, especially in kansas city, in fixing decade's-old paperwork problems. We discussed what i had found on the plane and they would indicate that if we sent them a 337 worded such and such they could sign it, and avoid wording things on this or that way. I've never had the feeling they are out to get me. In stark contrast to the CASA where we now live.
 
RotorAndWing said:
Not all Inspectors are evil.
Click to expand...

So you just have to ask yourself....do you feel lucky?

Sorry, the risk is entirely on the aircraft owner, and you have no way of knowing what kind of treatment you might receive from the FAA. Far better to keep your mouth shut, your head down, and your feet moving.
 
Jay Honeck said:
So you just have to ask yourself....do you feel lucky?

Sorry, the risk is entirely on the aircraft owner, and you have no way of knowing what kind of treatment you might receive from the FAA. Far better to keep your mouth shut, your head down, and your feet moving.
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Apples and oranges You had something installed on your plane that wasn't authorized and had to remove it. The OP has something that is authorized but without the full required documentation. As stated above the remedy is simple and without risk. The risk here would be not to come into compliance.
 
I have found when I pulled the records of my plane, that not all the 337's were scanned when they were sent to me. I can tell this because I have scans of back sides of 337s for which the front isn't there. If you have YOUR copy of a 337 that you have confidence was submitted, I'd not be as worked up about it as one that neither the FAA nor YOU seem to have any proof actually was created.

The FAA can always find something that's illegal.

My plane has tons of 337s on file. It's amusing watching 60 years of history. Overhead panels installed (not present anymore nor do I know when it was removed). Auto pilot installed and then removed and another installed, etc....
 
Jay Honeck said:
So you just have to ask yourself....do you feel lucky?

Sorry, the risk is entirely on the aircraft owner, and you have no way of knowing what kind of treatment you might receive from the FAA. Far better to keep your mouth shut, your head down, and your feet moving.
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Really has nothing to do with luck. You are comparing two different situations. You had non compliant equipment installed on a plane. He has compliant equipment but is one piece of paperwork away from a compliant installation. All the FAA wants is their damned piece of paper so the file is neat and compliant and when they go through some audit, they won't get caught by their boss. Understand the bureaucrat's prime motivation, to collect their paycheck with the minimum hassles possible. Note I didn't say work possible, many actually enjoy doing their job, they just don't want a hassle or jeopardize their pay grade and/or chance for promotion.

In this situation the course of action is obvious and simple, file the 337 and complete the file. The FAA doesn't particularly go around holding people punitively responsible for what they don't know, but once you know it, they do hold you responsible to fix it.

Consider this: If the FAA went to the airport to do their random walk through and notice something that gets them to do a compliance investigation and they find there s no 337 filed for this installation. At that point, what would their action be? They would put a sticker on it and tell you no further operations until you bring it into compliance. That's it, no fines, no suspensions, no prison, no medical inquest.... Just bring it into compliance.
 
Jay Honeck said:
So you just have to ask yourself....do you feel lucky?

Sorry, the risk is entirely on the aircraft owner, and you have no way of knowing what kind of treatment you might receive from the FAA. Far better to keep your mouth shut, your head down, and your feet moving.
Click to expand...

Same with owner motels. I see them and keep going till I find a name brand I know will be clean, comfortable and safe. :rolleyes:
 
If the installation was properly logged, STC'd, inspected and signed off by an IA, what purpose does the 337 serve?
Why would the OP getting said document get him into hot water more than going 'naked'?

I have experience as a beauracrat, but I am misunderstanding something here.
 
Jaybird180 said:
If the installation was properly logged, STC'd, inspected and signed off by an IA, what purpose does the 337 serve?
Why would the OP getting said document get him into hot water more than going 'naked'?

I have experience as a beauracrat, but I am misunderstanding something here.
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It meets the regulatory requirements outlined Appendix B to Part 43—Recording of Major Repairs and Major Alterations to notifiy the FAA, in the OP's case, that a major alteration (as defined in part 43 Appendix A) was applied to this specific airframe.
 
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tsts4 said:
It meets the regulatory requirements outlined Appendix B to Part 43—Recording of Major Repairs and Major Alterations to notifiy the FAA, in the OP's case, that major alteration (as defined in part 43 Appendix A) was applied to this specific airframe.
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I believe he was posing the question rhetorically, but yes, that's the answer lol, it completes the file.
 
Let's give this a little thought. What does the top of the 337 say ... MAJOR Repair or MAJOR modification. Back in the stone ages when most of us were in liquid form, the Feds got a little bitchy about hanging a Model T engine on a J3 and flying it about, so they ginned up a list of what is major (FAR Part 43 Appendix A). Most of us are pretty rigid when it comes to the stuff that is enumerated in this list, but let's take the propeller in question.

In the parlance of the FAA, the propeller is an "accessory" to an engine. The FAR is quite specific that a major alteration is, "(iii) Installation of an accessory which is not approved for the engine."

So the question begs itself, what does "approved" mean? I believe the answer is quite simple ... when an STC is issued specific to an engine or engine/airframe combination, that in and of itself bears FAA signatures for "approval". As such, the installation of an STC'd propeller on an engine for which approval is granted by the STC documentation becomes a MINOR modification and as such a logbook entry by an A&P (not necessarily an IA) is all that is required.

/Asbestos suit on/

Jim
 
tsts4 said:
Apples and oranges You had something installed on your plane that wasn't authorized and had to remove it. The OP has something that is authorized but without the full required documentation.
Click to expand...

*sigh* Yes, you're right, of course.

Some ramblings on this issue... In the real world, there is no difference between the two scenarios. My Aeroflash-brand strobes had been in the plane for 15 years, and worked fine. The OP's propeller is working just fine, too. From a functionality standpoint, it is apples and apples. We both needed to obtain a piece of paper to prove that what was already working was "safe".

The flaw in the system is that the FAA holds something like strobe lights to essentially the same standards as the flight-critical propeller. One is largely cosmetic, and a non-issue if it fails. The other is essential to flight -- yet they are treated much the same: No paperwork? Remove it.

Now this is obviously absurd, to any sentient being. Strobes are...LIGHTS. They blink. That's IT. Propellers, on the other hand, make the plane go. It's a really big deal if it fails. They aren't comparable in importance.

But in the FAA's world, they are completely comparable, and of equal importance. We all know that the only real difference between the two scenarios is which piece of paper must be obtained, and from which bureaucrat. But, of course, since paperwork is all the FAA actually produces, obtaining retroactive "approval" is a big deal in their world.

In the OP's case, it should be a simple paperwork issue to resolve -- but you really never know. In my case, it was not, and I paid dearly. As a new owner in 1998 it was my baptism by fire into the bizarro world of the FAA.

And that, in a nutshell, is what drove me into the wonderful world of experimental aircraft. I am SO glad that I will never, ever have to deal with that bureaucratic Bravo Sierra again. YMMV.
 
JHW said:
to echo the comments by anonymous above, I've been helped many times by fsdo staff, especially in kansas city, in fixing decade's-old paperwork problems. We discussed what i had found on the plane and they would indicate that if we sent them a 337 worded such and such they could sign it, and avoid wording things on this or that way. I've never had the feeling they are out to get me. In stark contrast to the CASA where we now live.
Click to expand...

Which KC FSDO are you talking about???? This one???
http://www.oig.dot.gov/sites/dot/files/pdfdocs/cc2001221.pdf

I would tell anyone when talking with a FSDO exercise the same caution you would use when dealing with the IRS. Yes, many of the people there are good people, but if you get "that guy/gal" your life can become very complicated and expensive, even with something like AOPA legal which will probably only cover to the point where you see a judge. Something as minor as inquiring about missing 337s can turn into a 91.403 violation.
 
weirdjim said:
Let's give this a little thought. What does the top of the 337 say ... MAJOR Repair or MAJOR modification. Back in the stone ages when most of us were in liquid form, the Feds got a little bitchy about hanging a Model T engine on a J3 and flying it about, so they ginned up a list of what is major (FAR Part 43 Appendix A). Most of us are pretty rigid when it comes to the stuff that is enumerated in this list, but let's take the propeller in question.

In the parlance of the FAA, the propeller is an "accessory" to an engine. The FAR is quite specific that a major alteration is, "(iii) Installation of an accessory which is not approved for the engine."

So the question begs itself, what does "approved" mean? I believe the answer is quite simple ... when an STC is issued specific to an engine or engine/airframe combination, that in and of itself bears FAA signatures for "approval". As such, the installation of an STC'd propeller on an engine for which approval is granted by the STC documentation becomes a MINOR modification and as such a logbook entry by an A&P (not necessarily an IA) is all that is required.

/Asbestos suit on/

Jim
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You are confusing approval of the actual work with approval of the data used for the alteration. The STC is merely approval of the design/materials for the major alteration. The regulations require the person performing the alteration to document how the alteration was done, and that is done on the 337. Once the work is competed, it must be inspected by an IA for conformity with the approved data, and that inspection is also documented on the 337. That is why the 337 for an STC'd major alteration need not go through the FSDO for further approval -- the data are already approved.

OTOH, a non-STC'd major alteration must be approved by the FSDO. In that case, the Airworthiness Inspector signing the 337 is approving the design data of the alteration, while the A&P performing the work signs the 337 to certify it was done as described on the back, and the IA signing the 337 is certifying that the work performed by the A&P was checked for conformity with the design data.

But in either case, for what the regs define as a "major alteration" (see Appendix A to Part 43 for what constitutes a "major alteration"), the FAA wants more certification than for a minor alteration that the work was in fact done according to approved data, and that's where the 337 comes in.
 
Blackhawk said:
Which KC FSDO are you talking about???? This one???
http://www.oig.dot.gov/sites/dot/files/pdfdocs/cc2001221.pdf

I would tell anyone when talking with a FSDO exercise the same caution you would use when dealing with the IRS. Yes, many of the people there are good people, but if you get "that guy/gal" your life can become very complicated and expensive, even with something like AOPA legal which will probably only cover to the point where you see a judge. Something as minor as inquiring about missing 337s can turn into a 91.403 violation.
Click to expand...

:rolleyes2:
 
weirdjim said:
Cheap shot. But then again, that's your stock in trade.

Jim
.
.
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pot_calls_kettle_black.jpg
 
Blackhawk said:
Which KC FSDO are you talking about???? This one???
http://www.oig.dot.gov/sites/dot/files/pdfdocs/cc2001221.pdf

I would tell anyone when talking with a FSDO exercise the same caution you would use when dealing with the IRS. Yes, many of the people there are good people, but if you get "that guy/gal" your life can become very complicated and expensive, even with something like AOPA legal which will probably only cover to the point where you see a judge. Something as minor as inquiring about missing 337s can turn into a 91.403 violation.
Click to expand...

That wasnt my experience. When we delevoped an stc for comanche shoulder harnesses and another for gear warning lights they were nothing but helpful. When my ercoupe had corrorion issues and i couldnt drive those huge rivets in the middle of the spar, i asked about using close tolerenced bolts and they helped us make it happen. If thats not a major mod i dont know what is. No complaints here.

Btw Jay the concern with lights is not that they wont flash, its that they can cause fires.
 
Blackhawk said:
If you're rolling your eyes because you don't think a FSDO would do so you are mistaken. I've seen pilots violated for much, much less.
Click to expand...

Please post the "much, much less" violations here so we can read. I happen to know first hand what it takes to write a violation and what is involved in processing such a violation, and it's not a simple process.

The internet is full of myths of pilots getting violated for the smallest infraction.
 
Ron Levy said:
You are confusing approval of the actual work with approval of the data used for the alteration. The STC is merely approval of the design/materials for the major alteration. The regulations require the person performing the alteration to document how the alteration was done, and that is done on the 337. Once the work is competed, it must be inspected by an IA for conformity with the approved data, and that inspection is also documented on the 337. That is why the 337 for an STC'd major alteration need not go through the FSDO for further approval -- the data are already approved.

OTOH, a non-STC'd major alteration must be approved by the FSDO. In that case, the Airworthiness Inspector signing the 337 is approving the design data of the alteration, while the A&P performing the work signs the 337 to certify it was done as described on the back, and the IA signing the 337 is certifying that the work performed by the A&P was checked for conformity with the design data.

But in either case, for what the regs define as a "major alteration" (see Appendix A to Part 43 for what constitutes a "major alteration"), the FAA wants more certification than for a minor alteration that the work was in fact done according to approved data, and that's where the 337 comes in.
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I cited chapter and verse of the regs, part 43/A. Cite your reference for the difference between an STC and the work necessary to accomplish it. THe STC itself gives the installation instructions, and if followed, the approval has already been done. Minor modification.

Ya know, Levy, I don't see IA after your name, nor even A&P. When you get them, then come back and tell us all about it.

Jim
 
weirdjim said:
I cited chapter and verse of the regs, part 43/A. Cite your reference for the difference between an STC and the work necessary to accomplish it. THe STC itself gives the installation instructions, and if followed, the approval has already been done. Minor modification.

Jim
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Actually, by definition an stc is a major mod just because an stc exists. Silly, yes, but thats the way it is. That said, the 337 for an stc is a 2 minute job so whats the big deal. I've always guessed that the rationale is around facilitation ofnfuture AD applicability.
 
Jay Honeck said:
Jim is opinionated as hell (that's why we all like him) -- but I've never known him to take a cheap shot.

Speaking of which -- Jim, you bringing your new bride back to OSH this year?
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YOU CALLING MY BRIDE A CHEAP SHOT?????

(Just kidding. We blew our wad this year sending her to France to take a graduate course in 15th century French cathedral organs. She came back with the French version of turista and a SNOTTY hacking cough. Probably OSHKOSH next year, we are trying to do the other person's passions in alternate years.)

Jim
 
weirdjim said:
Let's give this a little thought. What does the top of the 337 say ... MAJOR Repair or MAJOR modification. Back in the stone ages when most of us were in liquid form, the Feds got a little bitchy about hanging a Model T engine on a J3 and flying it about, so they ginned up a list of what is major (FAR Part 43 Appendix A). Most of us are pretty rigid when it comes to the stuff that is enumerated in this list, but let's take the propeller in question.

In the parlance of the FAA, the propeller is an "accessory" to an engine. The FAR is quite specific that a major alteration is, "(iii) Installation of an accessory which is not approved for the engine."

So the question begs itself, what does "approved" mean? I believe the answer is quite simple ... when an STC is issued specific to an engine or engine/airframe combination, that in and of itself bears FAA signatures for "approval". As such, the installation of an STC'd propeller on an engine for which approval is granted by the STC documentation becomes a MINOR modification and as such a logbook entry by an A&P (not necessarily an IA) is all that is required.

/Asbestos suit on/

Jim
Click to expand...

Might want to research that first sentence...
 
I challenged everyone to find the FAA definition of modification.
 
RotorAndWing said:
Please post the "much, much less" violations here so we can read. I happen to know first hand what it takes to write a violation and what is involved in processing such a violation, and it's not a simple process.

The internet is full of myths of pilots getting violated for the smallest infraction.
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You mean like a right hand pattern violation when no one was in the area and there was a sick passenger? (15 day suspension). Right hand pattern when a CFI followed the traffic ahead of him instead of causing a conflict? (15 day suspension). I am very familiar with both of these cases and I know of others. Most of these don't make it to the NTSB judge data base as the pilots involved don't have the deep pockets necessary.
I don't know what world you live in, but every FSDO I have dealt with in almost 30 years of flying has "that guy/gal" who will bust you in a heartbeat. Most of the inspectors won't, but a few will. You don't know which one is which until it is too late.
Again, I reference the KC FSDO and the Inspector General report I mentioned as well as the NTSB report noted in the IG report.
Bob Hoover ring a bell as well? But hey, those are just myths.
 
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I filled out about 15 of them last week. Then the TFE731 #2 low pressure turbine rotor blades emegency AD grounded many aircraft powered by said engines...
 
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Blackhawk said:
You mean like a right hand pattern violation when no one was in the area and there was a sick passenger? (15 day suspension). Right hand pattern when a CFI followed the traffic ahead of him instead of causing a conflict? (15 day suspension). I am very familiar with both of these cases and I know of others. Most of these don't make it to the NTSB judge data base as the pilots involved don't have the deep pockets necessary.
I don't know what world you live in, but every FSDO I have dealt with in almost 30 years of flying has "that guy/gal" who will bust you in a heartbeat. Most of the inspectors won't, but a few will. You don't know which one is which until it is too late.
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:rolleyes2:
 
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