Rosen Sun Visor Install

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Arrow115

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Hey guys,

I bought some Rosen sun visors for my Piper Arrow. I was looking at the instructions and it seems simple enough to install but I noticed that it came with a STC. Does this mean that I need my a&p to sign off on it or can I install it as an owner? Sorry if this is a dumb question.
 
Arrow115 said:
Hey guys,

I bought some Rosen sun visors for my Piper Arrow. I was looking at the instructions and it seems simple enough to install but I noticed that it came with a STC. Does this mean that I need my a&p to sign off on it or can I install it as an owner? Sorry if this is a dumb question.
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Not a dumb question. You will have to have your IA inspect the installation and fill out, sign, and file a 337. Seems dumb, but is required.
 
John Collins said:
Not a dumb question. You will have to have your IA inspect the installation and fill out, sign, and file a 337. Seems dumb, but is required.
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This is one of those "why I am friends with my A&P" moments.
 
Dean V said:
You can't install them because it is not a listed owner preventative maintenace item. The STC is irrelevant.
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You *can* install them with IA approval of the work.

It is up to your IA if he determines the 337 paperwork is required, or if he will sign it off in the logs as a minor alteration.

The most common mistake installing Rosens is putting the bracket on backwards.

Jeff
 
unbelievable that to install a sun visor you need paper work and a mechanic sign off. Maybe, a pair of ray bans would take care of the sun.
 
cirrusmx said:
unbelievable that to install a sun visor you need paper work and a mechanic sign off. Maybe, a pair of ray bans would take care of the sun.
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Everything takes a mechanic signoff except for the limited PM stuff in the part 43 appendix. Depending on the aircraft it's not necessarily a trivial thing to install Rosens. It's not just the case that you can always just unscrew the viser that is there and put the Rosen on in it's place.
 
In general, if it comes with an STC, your IA must sign off the work and file the 337.
 
I appreciate everyone's responses. I left the Rosens in the plane for my IA to install. Seems silly for something that easy but I would rather play by the rules.

I am looking forward to seeing them installed. They seem to be well made and will be a big improvement over the factory visors.

Thanks again for clarifying my install question.
 
Norman said:
In general, if it comes with an STC, your IA must sign off the work and file the 337.
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Sign off, yes. It is up to the IA to determine if the alteration is major or minor. If minor, a 337 is not done (by definition, if a 337 is completed, it is considered a major alteration). What the STC establishes is the "approved data" for the alteration, after which the IA can make a determination if it is major or minor.

It could probably be argued that an owner changing the visors out for Rosen's really is just changing interior trim pieces and other interior finishes allowed to be changed without an IA, under preventative maintenance, as it does not require disassembly/alteration of structural components. Again, the STC reference (in lieu of a PMA) is the "approved data" that the owner could enter in the logbook.

I'm not an IA, and our Rosen's are logged by the IA (though I'm not sure if we did it via minor alteration or not). Just my thoughts that it isn't 100% clear that this isn't covered under owner maintenance.


Jeff
 
"Beats hell out of me, it was like that when I bought it."
 
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The FAA is going to tell you that the incorporation of an STC constitutes a major alteration. You can read and re-read Part 43 Appendix A (1)(i) through (xiii) until your eyes bleed and you're not going to find anything in there that says that. There are also going to be people that will tell you that you can not perform ANY alteration of any sort without some kind of "Approved Data" and that's basically true but there is a wide range of loosely worded approved data out there and the interpretation is generally left up to the guy signing the logbook.

Rosen has an STC mainly to just cover everyone's back, so that there isn't a question about approval and that's going to apply whether a 337 was filed or not. Furthermore, every Rosen installation that I have seen is one that an A&P can look at after the fact and determine by the instructions if it was installed correctly.

Yes, it's still a double whammy because you are paying the added cost of the STC and paying a mechanic for an endorsement but in the end there are no doubts that it is legal.
 
Far 21.113 (b) If a person does not hold the TC for a product and alters that product by introducing a major change in type design that does not require an application for a new TC under § 21.19, that person must apply to the appropriate aircraft certification office for an STC.

That is of course assuming a change is an alteration.
 
VanDy said:
That is of course assuming a change is an alteration.
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I'd say yes, change and alteration are synonymous but I think everyone would agree that, although Rosen did pursue and obtain an STC, the installation of their visors does not constitute a major change or alteration to the type design as defined in appendix A.
 
21.113 is the requirement for an STC, so by that regulation any STC is automatically a major change, 'I have called and asked my FSDO, and they said yes, STC=337 automatically.
 
VanDy said:
21.113 is the requirement for an STC, so by that regulation any STC is automatically a major change, 'I have called and asked my FSDO, and they said yes, STC=337 automatically.
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The flawed logic here is the assumption that Rosen was required to pursue an STC for this product. The primary error was that the FAA should have refused to issue an STC for a product/installation that did not, by any actual reading of the regs, constitute a major alteration. Same with the Precise-Flow air vent kit and other similar products.
 
VanDy said:
Far 21.113 (b) If a person does not hold the TC for a product and alters that product by introducing a major change in type design that does not require an application for a new TC under § 21.19, that person must apply to the appropriate aircraft certification office for an STC.

That is of course assuming a change is an alteration.
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Jeff Oslick said:
The flawed logic here is the assumption that Rosen was required to pursue an STC for this product. The primary error was that the FAA should have refused to issue an STC for a product/installation that did not, by any actual reading of the regs, constitute a major alteration. Same with the Precise-Flow air vent kit and other similar products.
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I understand what you are getting at, but how does that change the fact that a requirement of an STC is a major change?
 
cirrusmx said:
unbelievable that to install a sun visor you need paper work and a mechanic sign off. Maybe, a pair of ray bans would take care of the sun.
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This can't possibly be why people think its too expensive to fly their own airplane... :mad2::mad2::mad2:
 
VanDy said:
...I have called and asked my FSDO, and they said yes, STC=337 automatically.
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Which is exactly what I said they were going to tell you in my first post. The bottom line is, if you have a pair of Rosen visors that were installed on a logbook entry with no 337 filed you're not going to encounter any grief. No insurance claims are going to be denied and nobody is going to tag your aircraft as unairworthy and strand you on a fuel stop in Gila Bend Arizona.

But....having purchased the Rosen visors you have already PAID for the STC and no honest mechanic is going to rake you over the coals or force you to take a second mortgage out on your house just to fill out the silly paper and send it to Oklahoma City. So may as well just do it.
 
Only once did I encounter STC paperwork in the box that did not need to be filed. It was a prop for a PA-32 that was also listed on the TCDS.

A quick conversation with my PMI, and the STC was filed.....in the trash.:yes:
 
My NY Yankees cap is the easiest to install. It works on any plane and it has siesta mode for those long flights.

José
 
The sun visor on this Champ was discarded from an A320 and didn't come with an STC.

DSCN4540.JPG
 
VanDy said:
I understand what you are getting at, but how does that change the fact that a requirement of an STC is a major change?
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What you stated is not a "fact". It would not be the first time a FSDO read the regs incorrectly. 21.113 does not prevent the FAA from issuing an STC for a product that does not require a major alteration for installation.
 
Jeff Oslick said:
What you stated is not a "fact". It would not be the first time a FSDO read the regs incorrectly. 21.113 does not prevent the FAA from issuing an STC for a product that does not require a major alteration for installation.
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BINGO!
 
The question becomes, are you going to install the visors as a minor alteration or as a STCed item?

As an IA/repair station inspector the choice is easy, I'll spend the 5min and the stamp. If I was "just" an A&P I might have a different view.

Regardless, an A&P will be required in nearly every case as the old "form, fit, function" test will typically have the rosen visors not being the same as the OE units putting the swap firmly in the "alteration" category.
 
Sorry for the delayed update, my IA submitted the paperwork to the FAA during the annual. All is well. After seeing the install, it seems silly that it requires this much paper work. Oh well.

By the way, if you are on the fence about spending the money on Rosens. Do it. Huge improvement over the factory visors. I haven't had to wear sunglasses since they went in. The Rosens also look better than the old factory visors.
 
Arrow115 said:
Sorry for the delayed update, my IA submitted the paperwork to the FAA during the annual. All is well. After seeing the install, it seems silly that it requires this much paper work. Oh well.

By the way, if you are on the fence about spending the money on Rosens. Do it. Huge improvement over the factory visors. I haven't had to wear sunglasses since they went in. The Rosens also look better than the old factory visors.
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When the A&P-IA signed block 7 approving return to service they were insuring that the installation was made IAW the instructions given in the STC instructions.
There is nothing prohibiting anyone from installing the visors, filling out the 337 and handing it to the -IA.
 
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I took the 310 version and put them in as a minor mod to the Navion.
 
Arrow115 said:
Hey guys,

I bought some Rosen sun visors for my Piper Arrow. I was looking at the instructions and it seems simple enough to install but I noticed that it came with a STC. Does this mean that I need my a&p to sign off on it or can I install it as an owner? Sorry if this is a dumb question.
Click to expand...

Well NOW you do, now that you've gone and told the whole world about it. Sheesh... :nono:

-Rich
 
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flyingron said:
I took the 310 version and put them in as a minor mod to the Navion.
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Does the Navion have a production certificate, and a IPC for all the parts on that certificate?
 
I went to TAP Plastics with a sketch, let them hotwire cut the visor out so that it had a factory edge, put a strip of aluminum on it with holes to match the old visor, a couple of Adel clamps to let it rotate, and for $50, bingo, a 21.303 (b)(2) owner produced part.

Talk about the definition of a MINOR alteration. Sheesh.

Jim
 
Tom-D said:
Well Jim here ya go,

AC 43-18

http://www.faa.gov/documentLibrary/media/Advisory_Circular/AC 43-18 CHG 2.pdf
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Yes, TOm, that is one of the books of my bible. HOWEVER, we all wear several hats. You wear one as the A&P, one as the IA, but you (and I) wear one as the "owner or operator" of an aircraft.

So the question then poses itself, since there are separate rules and interpretations for these categories, which one did I fabricate the visor from? I'll argue that my A&P and IA had NOTHING to do with me as an aircraft owner taking plans to a machinist, taking that part back, making an attach bracket, and then inspecting it to see if it looked like what I drew.

I then took the visor from the owner bench to the A&P bench and asked myself if that visor was similar in form, function, and fit to Mr. Cessna's cardboard covered in vinyl. Other than the fact that it was made from smoke grey polycarbonate of the same approximate thickness, I says, says I, that it sure looks like an airplane part to me.

And it surely looks like a minor modification. Last I looked, that was my call, no?

It is really quite similar to what we sometimes do on a 337 form. You/I do the work and fill out the top half as the A&P, and then you/I inspect the work and fill out the bottom half as the IA. This visor thing is just one step below that.

Jim
 
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Arrow115 said:
I appreciate everyone's responses. I left the Rosens in the plane for my IA to install. Seems silly for something that easy but I would rather play by the rules.

I am looking forward to seeing them installed. They seem to be well made and will be a big improvement over the factory visors.

Thanks again for clarifying my install question.
Click to expand...

I've had them on both my aircraft and love them. Seeing where you're going always seemed really important to me. I hope yo like yours as much as I like mine.
 
Tom-D said:
Does the Navion have a production certificate, and a IPC for all the parts on that certificate?
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I'm not sure how that is relevant to the question, but just like every other type certificated aircraft, the production certification is an approval on the type certificate. No separate production certificate is necessary nor issued.
 
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I purchased Plane Parts replacement visors for my Arrow. Like for like replacement. Problem is that they won't stay in place. They tend to always droop down, but since they are translucent it isn't a big problem. I stayed away from the Rosen because of the cost but it seems this is a pay me now pr pay me pater scenario. I will probably end up with the Rosens in the end.

Oh I did price replacement friction clips from Muncie. They only want $120 each.
 
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