Unauthorized installed equip?

[Banjo33]

Hypothetically, let's say during the course of airplane shopping, you discover that an airplane's mechanic has installed an item that wasn't originally installed (it's recorded in the aircraft logs). For instance, this hypothetical item could be a nose gear taxi light (wing lights were original equipment and are still installed).

I assume this kind of installation would require a Form 337 from the FSDO or an STC in the logs in order to be considered legal?

If this is the case, are there any fees associated with making this installation legal (assuming no STC exists)?

Would you consider this a negotiable item (and at what cost) towards purchase?

Hypothetically of course.

 

[Let'sgoflying!]

If it was not a safety concern or involved destroying part of the airplane ie cutting into structural members or something like a flammable interior, I would have little concern.
I would not be willing to pay a lot more for such a mod.
I would be concerned about what my IA would say at annual and look at it how difficult it would be to return the airplane to what he considers acceptable.

 

[bnt83]

Hypothetically, let's say during the course of airplane shopping, you discover that an airplane's mechanic has installed an item that wasn't originally installed (it's recorded in the aircraft logs). For instance, this hypothetical item could be a nose gear taxi light (wing lights were original equipment and are still installed).

I assume this kind of installation would require a Form 337 from the FSDO or an STC in the logs in order to be considered legal?

If this is the case, are there any fees associated with making this installation legal (assuming no STC exists)?

Would you consider this a negotiable item (and at what cost) towards purchase?

Hypothetically of course.

There is so little information given the only appropriate hypothetical answer is it depends.

 

[Banjo33]

In this situation, the current owner wouldn't be expecting this to increase the value of his plane. I don't believe anything structural was altered, merely a light bracket was attached to the nose gear arm, wiring routed to the cockpit in conjunction with the existing harness, and a 3-position switch installed in place of the original switch.

My concerns are: what is the proper way to document this alteration? And, worst case, it's discovered by an inspector or a future IA declares the airplane unairworthy until it's removed or documented properly, what is a ballpark cost to complete this process?

If I saw an installation like this, I wouldn't necessarily want to remove it, but I'd have to be prepared to do so if a situation required it.

 

[Henning]

It depends if it required a Major Modification, if not it needs nothing but a log book entry.

 

[bnt83]

Call an avionics shop and ask them to quote a job with no specifics like make/model airplane, what make/model equipment you want and see what kind of quote you can get.

Still not enough information.

 

[Silvaire]

I don't know when it began but there seems to be a penchant these days for calling just about anything a "major" alteration, apparently without glancing at FAR 43.17 appendix b. Because if it's not in there then it's not a major alteration and you're not supposed to file a 337. Yea mechanics probably do it to cover their ass but they aren't supposed to.

 

[Henning]

I don't know when it began but there seems to be a penchant these days for calling just about anything a "major" alteration, apparently without glancing at FAR 43.17 appendix b. Because if it's not in there then it's not a major alteration and you're not supposed to file a 337. Yea mechanics probably do it to cover their ass but they aren't supposed to.

I wonder what the FAA does with those 337s?

 

[GrampaMark]

Does the TCDS for this make/model/serial # range list a nose gear landing light?

It could be that the light was an option which was added later. The log entry would be sufficient in that case.

Mark

 

[flyingron]

I wonder what the FAA does with those 337s?

They get shoved in a file with your N number on it. If you ask for it you can get a scan of them (if the dweeb at the FAA manages to do it right, I'm missing opposite sides of fronts that they did scan).

 

[Banjo33]

Does the TCDS for this make/model/serial # range list a nose gear landing light?

It could be that the light was an option which was added later. The log entry would be sufficient in that case.

Mark

Good question, I'll have to look into that. In this scenario, we'll just assume that the installed light came from a different make/model of aircraft.

 

[Anticept]

All modifications which involve the installation of parts* which are not based on approved/acceptable data (approved data being PMAs with appropriate sections stating what it can be installed on or replace, TCDS, Type Design, STCs, DER Engineering data, field approvals, etc) or installed during the course of repairs (and such repairs are not major IAW 43 APP A) will end up requiring a 337 due to a field approval as a last resort. This light is no exception.

Now, what does this mean? Well, you can either have the light removed, get the installation inspected and approved, or ignore it and hope nothing turns up.

*Parts are things that are NOT:
hardware (bolts, nuts, clamps, etc)
hosing & tubing
wiring and connectors
other components which are only required to meet a spec
All of the above must also avoid being in contravention to manufacturer mx instructions, or it will require the 337 and approved supporting data.

 

[Witmo]

All modifications which involve the installation of parts* which are not based on approved data (approved data being PMAs with appropriate sections stating what it can be installed on or replace, TCDS, STCs, DER Engineering data, field approvals, etc) require a 337. This light is no exception.

Now, what does this mean? Well, you can either have the light removed, get the installation inspected and approved, or ignore it and hope nothing turns up.

*Parts being things that are NOT:
hardware
hosing
wiring
other components which are only required to meet spec
All of the above must also avoid being in contravention to manufacturer mx instructions, or it will require the 337 and approved supporting data.

You are mistaken. The installing mechanic makes the determination whether installing something constitutes a major alteration or a minor one. If it doesn't alter the weight and balance or significantly change the electrical or some other system, he doesn't need "approved" data if he decides it's a minor alteration. A major alteration or repair needs approved data or if none is available, acceptable data, used as a basis for a field approval via 337. Minor alterations are a log book entry alone and don't require any data, approved or otherwise.

The light in question may very well be a major alteration requiring a 337. It depends on the particular part and installation.

 

[weirdjim]

All modifications which involve the installation of parts* which are not based on approved data (approved data being PMAs with appropriate sections stating what it can be installed on or replace, TCDS, STCs, DER Engineering data, field approvals, etc) or installed during the course of repairs (and such repairs are not major IAW 43 APP A) require a 337. This light is no exception.

Corey ... Brian, Silvaire, and I differ on occasion about things maintenance and mechanical, but when we are mostly on the same side, a wise callow mechanic might take their new license and put it back into their pocket until the ink is dry.

Jim

 

[Norman]

Jim,

I'm a retired IA. I didn't want to burst Corey's bubble. Early in my career I once sent one to the FSDO and got a phone call asking why I thought it was necessary to submit a 337. It was wastebasket material.

 

[Tom-D]

I wonder what the FAA does with those 337s?

They enter it in the aircraft history records.
The GS3 does not know what a major alteration is. it's just a sheet of paper to her.

 

[Tom-D]

All modifications which involve the installation of parts* which are not based on approved data (approved data being PMAs with appropriate sections stating what it can be installed on or replace,

Gotta reference for that?


IMHO it is not a major until it meets the requirements of FAR 43-A for the system it is contained in.

 

[Tom-D]

Jim,

I'm a retired IA. I didn't want to burst Corey's bubble. Early in my career I once sent one to the FSDO and got a phone call asking why I thought it was necessary to submit a 337. It was wastebasket material.

When we sent them to FSDO, they could do that. those days are lost and gone for ever.

 

[Tom-D]

Hypothetically, let's say during the course of airplane shopping, you discover that an airplane's mechanic has installed an item that wasn't originally installed (it's recorded in the aircraft logs). For instance, this hypothetical item could be a nose gear taxi light (wing lights were original equipment and are still installed).

I assume this kind of installation would require a Form 337 from the FSDO or an STC in the logs in order to be considered legal?

If this is the case, are there any fees associated with making this installation legal (assuming no STC exists)?

Would you consider this a negotiable item (and at what cost) towards purchase?

Hypothetically of course.

Don't we have our A&P-IA inspect the aircraft for things like this on a pre-buy?

Or is this the reason the first annual is so expensive?

 

[bnt83]

You simply cannot determine what the op is asking based on the information given.

Most everything alteration wise hinges on the tcds for the airplane. For example,

We can change the seat foam out of a 1960 172 with essentially no engineering data whatsoever and its totally legit. Try that on a new aircraft with very specific dynamic crash rated seats and its not.

 

[Anticept]

...

...

...

...

I read back on my first post in this thread and it's a discombobulated mess. I typed it up on my phone while in the middle of a break from a job and edited it half a dozen times. When posting on PoA, if you aren't writing a 110% accurate novel, your stuff gets picked apart. I kept splicing, rewriting, and trying to figure out how to catch every little case to head you guys off, and my evil plans were ruined .

Anyways, that's supposed to be specifically talking about parts, hence why I starred the word "parts" and tried to elaborate. I did not mean to speak about methods and practices for installation, but only about the parts that are consumed during the work. I still stand by my statement, there needs to be some sort of approval or accepted procedure that says "this part can be installed on this plane" (for TCed products), or you'll end up 337ing it with a field approval.

I know that in days past, the FAA was more lenient with regards to GA aircraft and parts. But, thanks to all the unapproved parts and people losing their lives to them, they've really cracked down.

Anyways, not everything has to have an approval, as mentioned, but instead can be proven to be airworthy by other means. I believe I had covered that pretty well with my little exemption list. But, to take it a step further, Advisory circular 20-62E section 4b states 5 cases for acceptable parts (or, to put it simply, the exempted stuff that does not require all the fancy FAA stamped approval paperwork) being installed on TCed products.

1. Standard parts (such as nuts and bolts) conforming to an established industry or U.S. specification. -- self explanatory, but they do further define this in this same document should someone want to really get picky
2. Parts produced by an owner or operator for maintaining or altering their own product and which are shown to conform to FAA-approved data. -- aka a manufacturer of something which is type certificated. The word "Product" is defined as such in the document.
3. Parts for which inspections and tests have been accomplished by appropriately certificated persons authorized to determine conformity to FAA-approved design. -- This is to address vintage aircraft, where parts no longer exist and the data describing the parts is difficult or impossible to locate or obtain. This allows Designated Engineering Representatives and Aviation Safety Inspectors to approve/field approve replacement parts.
4. Parts fabricated by an appropriately rated certificate holder with a quality system and consumed in the repair or alteration of a product or article in accordance with part 43. -- This is the important one that many of us use. A mechanic can produce a part for installation by fabrication on an aircraft. However, we must pay attention to the "in accordance with part 43" part, which basically is a big broad stroke saying it can't just be any part, it has to be airworthy by still meeting "the original or properly altered condition". AC 43-18 further expands on what fabrication means and entails. Included in 43-18 for the purpose of fabrication is a very interesting note: raw materials, like sheet metal, are NOT considered parts
5. A commercial part as defined in § 21.1. -- definition from the reg: "Commercial part means an article that is listed on an FAA-approved Commercial Parts List included in a design approval holder's Instructions for Continued Airworthiness required by §21.50;"

Anyways, I do outright admit the ink on my certificate is indeed still a little "wet." I appreciate feedback and correction. However, especially in response to the way weirdjim worded his statement, don't play the "kid" card. I don't appreciate being spoken down to (no one does). Please be helpful instead of condescending. I do keep my ears open and still recognize I have a lot to learn, but I won't learn anything if people just say crap like that.

In closing, I will also say, I've never been taught any exemptions to the above (and asked in school about it, and got the information that I posted here). However, I am not able to find a reference that DIRECTLY states what I said, so there could be an exception that I'm not aware of. Still, there's a lot of documents, including the suspected unapproved parts AC, that really drives the point home about establishing a part as airworthy. However, I have not seen anything that says a mechanic can establish just any part as being airworthy; there's a lot of references to ASIs, DERs, PMAs, TCs, etc if it's going to be a part that is not fabricated. As said above, when fabricating, you are then providing the "approval" (using term loosely here) that the part can be installed on that aircraft.

 

[weirdjim]

I read back on my first post in this thread and it's a discombobulated mess.

As another poster said, none of us wanted to pop your bubble, but as a current college teacher, what I teach in the classroom as "the party line" and what I do at my business in the real world sometimes bear scant resemblance to one another. Academic freedom allows me to point that out at every occasion, but sometimes that message doesn't get across.

I'll say it again. What your teachers had to say to keep the FAA off their tails and what happens in the real world sometimes differ by a bit more than an RCH. They probably didn't teach you that acronym either; see what I mean?

I'm 72. I can legitimately call nearly everybody on this group "kid" and get away with it.

Jim

 

[Tom-D]

I read back on my first post in this thread and it's a discombobulated mess. I typed it up on my phone while in the middle of a break from a job and edited it half a dozen times. When posting on PoA, if you aren't writing a 110% accurate novel, your stuff gets picked apart. I kept splicing, rewriting, and trying to figure out how to catch every little case to head you guys off, and my evil plans were ruined .

Anyways, that's supposed to be specifically talking about parts, hence why I starred the word "parts" and tried to elaborate. I did not mean to speak about methods and practices for installation, but only about the parts that are consumed during the work. I still stand by my statement, there needs to be some sort of approval or accepted procedure that says "this part can be installed on this plane" (for TCed products), or you'll end up 337ing it with a field approval.

I know that in days past, the FAA was more lenient with regards to GA aircraft and parts. But, thanks to all the unapproved parts and people losing their lives to them, they've really cracked down.

Anyways, not everything has to have an approval, as mentioned, but instead can be proven to be airworthy by other means. I believe I had covered that pretty well with my little exemption list. But, to take it a step further, Advisory circular 20-62E section 4b states 5 cases for acceptable parts (or, to put it simply, the exempted stuff that does not require all the fancy FAA stamped approval paperwork) being installed on TCed products.

1. Standard parts (such as nuts and bolts) conforming to an established industry or U.S. specification. -- self explanatory, but they do further define this in this same document should someone want to really get picky
2. Parts produced by an owner or operator for maintaining or altering their own product and which are shown to conform to FAA-approved data. -- aka a manufacturer of something which is type certificated. The word "Product" is defined as such in the document.
3. Parts for which inspections and tests have been accomplished by appropriately certificated persons authorized to determine conformity to FAA-approved design. -- This is to address vintage aircraft, where parts no longer exist and the data describing the parts is difficult or impossible to locate or obtain. This allows Designated Engineering Representatives and Aviation Safety Inspectors to approve/field approve replacement parts.
4. Parts fabricated by an appropriately rated certificate holder with a quality system and consumed in the repair or alteration of a product or article in accordance with part 43. -- This is the important one that many of us use. A mechanic can produce a part for installation by fabrication on an aircraft. However, we must pay attention to the "in accordance with part 43" part, which basically is a big broad stroke saying it can't just be any part, it has to be airworthy by still meeting "the original or properly altered condition". AC 43-18 further expands on what fabrication means and entails. Included in 43-18 for the purpose of fabrication is a very interesting note: raw materials, like sheet metal, are NOT considered parts
5. A commercial part as defined in § 21.1. -- definition from the reg: "Commercial part means an article that is listed on an FAA-approved Commercial Parts List included in a design approval holder's Instructions for Continued Airworthiness required by §21.50;"

Anyways, I do outright admit the ink on my certificate is indeed still a little "wet." I appreciate feedback and correction. However, especially in response to the way weirdjim worded his statement, don't play the "kid" card. I don't appreciate being spoken down to (no one does). Please be helpful instead of condescending. I do keep my ears open and still recognize I have a lot to learn, but I won't learn anything if people just say crap like that.

In closing, I will also say, I've never been taught any exemptions to the above (and asked in school about it, and got the information that I posted here). However, I am not able to find a reference that DIRECTLY states what I said, so there could be an exception that I'm not aware of. Still, there's a lot of documents, including the suspected unapproved parts AC, that really drives the point home about establishing a part as airworthy. However, I have not seen anything that says a mechanic can establish just any part as being airworthy; there's a lot of references to ASIs, DERs, PMAs, TCs, etc if it's going to be a part that is not fabricated. As said above, when fabricating, you are then providing the "approval" (using term loosely here) that the part can be installed on that aircraft.

Now that you have an Advisory Circular as a reference, try reading the FAR ---- FAR 43-A. that is what tells us what a major alteration is.

This light may or may not be a major alteration, one must see the engineering data to make a decision.

 

[bflynn]

I dunno - I think the problem with hypothetical questions is that you wind up getting hypothetical answers.

 

[Silvaire]

...In closing, I will also say, I've never been taught any exemptions to the above (and asked in school about it, and got the information that I posted here). However, I am not able to find a reference that DIRECTLY states what I said, so there could be an exception that I'm not aware of. Still, there's a lot of documents, including the suspected unapproved parts AC, that really drives the point home about establishing a part as airworthy...

As a newly licensed mechanic you are acting conservatively and that's wise. You're also reading the vast amount of material that is available to you. What you don't want to do however is read yourself into a box and you certainly don't want to ever develop the idea that you are some sort of policeman - because you're not.

Let's go back to something more fundamental:

§65.81 General privileges and limitations.
(a) A certificated mechanic may perform or supervise the maintenance, preventive maintenance or alteration of an aircraft or appliance, or a part thereof, for which he is rated (but excluding major repairs to, and major alterations of, propellers, and any repair to, or alteration of, instruments), and may perform additional duties in accordance with §§65.85, 65.87, and 65.95. However, he may not supervise the maintenance, preventive maintenance, or alteration of, or approve and return to service, any aircraft or appliance, or part thereof, for which he is rated unless he has satisfactorily performed the work concerned at an earlier date. If he has not so performed that work at an earlier date, he may show his ability to do it by performing it to the satisfaction of the Administrator or under the direct supervision of a certificated and appropriately rated mechanic, or a certificated repairman, who has had previous experience in the specific operation concerned.

(b) A certificated mechanic may not exercise the privileges of his certificate and rating unless he understands the current instructions of the manufacturer, and the maintenance manuals, for the specific operation concerned.

The OP's hypothetical case of a landing light that wasn't there when the aircraft rolled off the factory floor is a good example for this discussion. To further simplify the discussion let's just all hypothetically agree that this is not a major alteration and so, as I said earlier, a 337 is not to be filed. What makes this landing light either legal or not legal is the presence or absence of a signed logbook entry by a licensed A&P mechanic.

As an A&P you are required to be capable of reading and writing English. You also are designated as capable of being able to understand and interpret the various regulations manuals and advisories associated with your trade. Unfortunately, in this hypothetical case, someone somewhere along the line is going to start playing policeman and attempt to invalidate the previous mechanics work. This could come in the form of refusing to sign off an annual or, in the case of an FAA official, incorrectly claiming that the aircraft is unairworthy.

You are right about one thing though, it is getting worse and it's not because people are dropping out of the sky with "unapproved" landing lights strapped to their gear leg, it's because everyone seems to have developed this inexplicable fear of their own shadow and are focused on nothing else 24/7 other than trying to cover their own ass.

It's truly sad - don't become one of them, have some faith in yourself and come to the understanding that AC 43-13-2B - Acceptable Methods, Techniques, and Practices - Aircraft Alterations is there for a reason

 

[dtuuri]

All modifications which involve the installation of parts* which are not based on approved data (approved data being PMAs with appropriate sections stating what it can be installed on or replace, TCDS, STCs, DER Engineering data, field approvals, etc) or installed during the course of repairs (and such repairs are not major IAW 43 APP A) require a 337. This light is no exception.

Now, what does this mean? Well, you can either have the light removed, get the installation inspected and approved, or ignore it and hope nothing turns up.

*Parts are things that are NOT:
hardware (bolts, nuts, clamps, etc)
hosing & tubing
wiring and connectors
other components which are only required to meet a spec
All of the above must also avoid being in contravention to manufacturer mx instructions, or it will require the 337 and approved supporting data.

Nailed it, just the way I remember from 1972 when I got my license. Don't see why you need to apologize for a thing. A landing gear alteration is major by definition (assuming it isn't in the specs); what if the light hangs the gear on extension?

dtuuri

 

[Tom-D]

A landing gear alteration is major by definition (assuming it isn't in the specs)

dtuuri

Show us how the landing gear was modified.

 

[dtuuri]

Show us how the landing gear was modified.

It sounds like it's attached with a light of some kind, motorcycle perhaps?

Hypothetically, let's say during the course of airplane shopping, you discover that an airplane's mechanic has installed an item that wasn't originally installed (it's recorded in the aircraft logs). For instance, this hypothetical item could be a nose gear taxi light (wing lights were original equipment and are still installed).

dtuuri

 

[flyingron]

If it doesn't alter the weight and balance or significantly change the electrical or some other system,

That's not the definition of major modification at all. The definition is in part 43. It's only the weight and balance LIMITS changing that automatically makes something a major modification (e.g., gross weight increases, envelope restrictions). Just because you add something that increases/decreases the empty weight doesn't necessary make it a major modification.

Further, just because you change a major system doesn't make it a major modification, provided the change is in compliance with the aircraft specifications (i.e., in conformance with the type certificate). I could replace the 185 HP E-185 engine on a Navion with a 285HP IO-520 one with only a logbook entry.

he doesn't need "approved" data if he decides it's a minor alteration.

That's not exactly a true statement. Just because something doesn't rise to the level of a major modification doesn't mean that there's not some compliance that needs to be met, depending on what the part is or what you are doing.

A major alteration or repair needs approved data or if none is available, acceptable data, used as a basis for a field approval via 337.

Every major alteration or repair takes a 337. Major alterations are required to either be supported by an STC or other data acceptable to the administrator (which would be the basis a field approval, but frankly, those are getting harder to come by).

Minor alterations are a log book entry alone and don't require any data, approved or otherwise.

Again that's not true.

 

[bnt83]

That's not the definition of major modification at all. The definition is in part 43. It's only the weight and balance LIMITS changing that automatically makes something a major modification (e.g., gross weight increases, envelope restrictions). Just because you add something that increases/decreases the empty weight doesn't necessary make it a major modification.

Further, just because you change a major system doesn't make it a major modification, provided the change is in compliance with the aircraft specifications (i.e., in conformance with the type certificate). I could replace the 185 HP E-185 engine on a Navion with a 285HP IO-520 one with only a logbook entry.

That's not exactly a true statement. Just because something doesn't rise to the level of a major modification doesn't mean that there's not some compliance that needs to be met, depending on what the part is or what you are doing.

Every major alteration or repair takes a 337. Major alterations are required to either be supported by an STC or other data acceptable to the administrator (which would be the basis a field approval, but frankly, those are getting harder to come by).

Again that's not true.

Appendix B to Part 43—Recording of Major Repairs and Major Alterations

(a) Except as provided in paragraphs (b), (c), and (d) of this appendix, each person performing a major repair or major alteration shall—
(1) Execute FAA Form 337 at least in duplicate;
(2) Give a signed copy of that form to the aircraft owner; and
(3) Forward a copy of that form to the FAA Aircraft Registration Branch in Oklahoma City, Oklahoma, within 48 hours after the aircraft, airframe, aircraft engine, propeller, or appliance is approved for return to service.
(b) For major repairs made in accordance with a manual or specifications acceptable to the Administrator, a certificated repair station may, in place of the requirements of paragraph (a)—
(1) Use the customer's work order upon which the repair is recorded;
(2) Give the aircraft owner a signed copy of the work order and retain a duplicate copy for at least two years from the date of approval for return to service of the aircraft, airframe, aircraft engine, propeller, or appliance;
(3) Give the aircraft owner a maintenance release signed by an authorized representative of the repair station and incorporating the following information:

 

[Silvaire]

It's because of this false stigma that you can't do anything to alter a type certificated aircraft from the state it was in when it rolled off the production floor that STC's exist for simple things like installing Rosin sun visors. Rosin went to the trouble of getting the STC so that all of the clowns out there who believe you can't so much as hang a post-it note on the instrument panel without violating some regulation would have to just STFU.

It's darn silly some of the stuff I hear.

So in this little exercise there is a landing light on the gear and there is a logbook entry signed by a licensed A&P mechanic. Who is going to now claim that the landing light is illegal and under what authority and what reference?

Interestingly enough the OP demonstrates the true interest of the typical aircraft owner. He wants to know if he can use that landing light to get five hundred bucks knocked off the purchase price.

 

[dtuuri]

It's because of this false stigma that you can't do anything to alter a type certificated aircraft from the state it was in when it rolled off the production floor that STC's exist for simple things like installing Rosin sun visors. Rosin went to the trouble of getting the STC so that all of the clowns out there who believe you can't so much as hang a post-it note on the instrument panel without violating some regulation would have to just STFU.

It's darn silly some of the stuff I hear.

So in this little exercise there is a landing light on the gear and there is a logbook entry signed by a licensed A&P mechanic. Who is going to now claim that the landing light is illegal and under what authority and what reference?

Interestingly enough the OP demonstrates the true interest of the typical aircraft owner. He wants to know if he can use that landing light to get five hundred bucks knocked off the purchase price.

You don't know any of that. Is it really a landing light or a clearance item from Autozone? Does the OP want $500 bucks off or wants to know how much it'll cost him to make it right if it isn't. You haven't inspected it, so you can't say it's airworthy and if you have and it isn't you're saying you have no authority to refuse to sign it off for an annual because you aren't a policeman. But worst of all, you called us "clowns" for pointing out that it's a landing gear alteration and therefore meets the definition of a major alteration unless there are specs for the installation.

What about automotive bucket seats in Comanches? The Comanche Flyer used to be full of "how to's" on what others have stuck in their planes. If an A&P signed it off once, is it good enough for you now? Anybody who doesn't is a "clown"? Lighten up ol' buddy.

Btw, what I learned back in the early 1970s was just as you say is a modern "stigma"--ANYTHING you do to a certified plane alters it. Even adding an ashtray. You can only restore it to original if you have no approved documentation to do more. That's how I recall it anyway, so this isn't a new concept IMO.

dtuuri

 

[Silvaire]

...But worst of all, you called us "clowns" for pointing out that it's a landing gear alteration and therefore meets the definition of a major alteration unless there are specs for the installation....

First of all my "clown" quote:

...so that all of the clowns out there who believe you can't so much as hang a post-it note on the instrument panel without violating some regulation...

If your "us" falls into that category then you're a clown and not because I called you one, just because you are.

Secondly a landing light is a landing light, not a landing gear. If you wanted to replace the torque link with something from Home Depot now your talking about altering the landing gear. Clamping a GoPro to a wing strut does not "alter" the wings and installing an AirGizmo panel dock for your Garmin 496 does not "alter" the fuselage.

What on earth happened to common sense? When did it cease to exist?

 

[Norman]

I could replace the 185 HP E-185 engine on a Navion with a 285HP IO-520 one with only a logbook entry.

Think so? My former employer shoe-horned a TSIO 520 into a Navion. It had to go into the experimental category in order to do that. A few years later he was able to return it to the normal category. It meant a substantial amount of paperwork.

As an aside, he knows as much or more than most feds about the regs.

 

[Witmo]

Think so? My former employer shoe-horned a TSIO 520 into a Navion. It had to go into the experimental category in order to do that. A few years later he was able to return it to the normal category. It meant a substantial amount of paperwork.

As an aside, he knows as much or more than most feds about the regs.

It all depends on what engines are listed on the TCDS. An unlisted engine would require a substantial amount of paperwork and hassles.

 

[Tom-D]

It sounds like it's attached with a light of some kind, motorcycle perhaps?


dtuuri

You are just like the rest of us, you don't know squat about the installation. so you are making it up as you go.

 

[bnt83]

Too many folks, even aircraft mechanics, don't know the difference between the following terms:

#1 Major Alteration

#2 Minor Alteration

#3 FAA Approved Data (the most abused and inappropriately used term ever)

#4 FAA Acceptable Data

Thousands of airplanes have aftermarket equipment (with an aerospace pedigree) such as shoulder harnesses, installed using only FAA acceptable data and signed off by a single log entry as a minor alteration.

I've seen many FAA Approvals on an FAA form that only stated that the data listed is in compliance some very generic rule from the TCDS such as this one:

§23.1301 Function and installation.

Each item of installed equipment must—
(a) Be of a kind and design appropriate to its intended function.
(b) Be labeled as to its identification, function, or operating limitations, or any applicable combination of these factors; and
(c) Be installed according to limitations specified for that equipment.

Those approvals make my eyes roll a bit...

 

[flyingron]

Think so?

I absolutely know so. The IO-520-B or IO-520-BA on the existing basket mount provided you have a B model or later, or you've installed the fuselage stiffeners per the Navion manufacturer drawings is permitted on any Navion. It's just a log book entry as it is in compliance with the aircraft specifications. Every optional change on the Navion type certificate is eligible on serial number 2 and up (serial number 1 doesn't exist).

My former employer shoe-horned a TSIO 520 into a Navion.

A TSIO-520 is not an IO-520. The IO-520 is on the type certificate specifications, the TSIO-520 is not.

As an aside, he knows as much or more than most feds about the regs.

And having been on the board of directors of the American Navion Society for a while, we've beat on both the FAA and the bastards who now hold the Navion type certificate as to just what is or is not legal.

 

[weirdjim]

the FAA and the bastards

Don't repeat yourself in the same sentence, Ron


Jim

 

[Anticept]

Hi all!

So I've been spending the past few days researching and making calls. Here's what I've been told by AFS 300 tech ops, 2 different people at our local FSDO, and a repair station chief of maintenance in KS city, and in addition, asked for sources.

As it stands, 43 app A HAS ABSOLUTELY NOTHING TO DO WITH PARTS AND THEIR APPROVALS WHATSOEVER, FULL STOP. As I said earlier, it only covers methods and practices. Even in the case of minor alterations, the parts MUST STILL HAVE AN APPROVAL (or meet one of the acceptable cases below).

Now, I did read back over and see a potential point of confusion through all of this: if I'm pulling new wire, or adding cockpit lighting (maybe adding a new light socket), these are minor alterations, as long as the PARTS I AM USING have approvals/acceptable data: like if I have a piper warrior, and I buy another light socket from their parts catalog, then I don't see why this can't be done on just a log entry. It's a piper part that is already installed in the airplane, and I don't see why we can't put another one in there somewhere as long as we don't cross into the major alteration category, like, for whatever reason, riveting it to a spar .


Now, back to parts: it is 21.8 and 21.9 that I was told to examine:

14 CFR 21.8


If an article is required to be approved under this chapter, it may be approved—
(a) Under a PMA;
(b) Under a TSO;
(c) In conjunction with type certification procedures for a product; or
(d) In any other manner approved by the FAA.

14 CFR 21.9



(a) If a person knows, or should know, that a replacement or modification article is reasonably likely to be installed on a type-certificated product, the person may not produce that article unless it is—
(1) Produced under a type certificate;
(2) Produced under an FAA production approval;
(3) A standard part (such as a nut or bolt) manufactured in compliance with a government or established industry specification;
(4) A commercial part as defined in §21.1 of this part;
(5) Produced by an owner or operator for maintaining or altering that owner or operator's product; or
(6) Fabricated by an appropriately rated certificate holder with a quality system, and consumed in the repair or alteration of a product or article in accordance with part 43 of this chapter.
(b) Except as provided in paragraphs (a)(1) through (a)(2) of this section, a person who produces a replacement or modification article for sale may not represent that part as suitable for installation on a type-certificated product.

Therefore, by regulation, you cannot install a part, no matter how minor, no matter what kind of work, and no matter what you intend to do, without the part having an approval/acceptance of some kind (disclaimer: or exemption in rare cases ).


Now, again, lets say you don't fit into any of these categories above. There's two options left: the SUPPLEMENTAL TYPE CERTIFICATE, and the FIELD APPROVAL. Both of these are AUTOMATIC 337s. Therefore, I STILL stand by my claim. Without any other approval, you need a field approval, and thus a 337. In the case of a field approval, this is because the 337 itself becomes the basis of approval.


Now, I will cede the point: people will give me the most conservative answers. That's why I asked for sources to cite. I'm still open to people pointing out where this stuff isn't the case for TCed products, but this time, I would like to be the one to ask for sources, and not just "because I'm an IA that has been doing this for years" (there's enough IAs out there that have been doing it wrong for a long time and got their certificates pulled once they were caught). I feel I've provided enough information and cited sources and advisory circulars for my argument, and I'd rather take the word of three FAA tech ops over random people on the internet .

Thousands of airplanes have aftermarket equipment (with an aerospace pedigree) such as shoulder harnesses, installed using only FAA acceptable data and signed off by a single log entry as a minor alteration.

Seat belts and harnesses are covered by TSO, and thus becomes a standard part that meets a government spec. That's your "approval" (since you pointed out the word approval is misused, I'm using the term loosely to try and avoid another giant debate).

It also depends on WHICH TSO. I don't remember their exact numbers, but one TSO for seatbelts and seating was pretty basic, while the other had a lot of implications about crash test worthiness and testing when changes are made. I suspect the latter is more for airlines, but that's purely speculation on my part.

Now I saw something about Rosin sunvisors. I doubt there's any issue with these sunvisors going into a plane. Still, that's how it is. If it doesn't have a spec to meet, or PMA replacement part, you can't do it. It's bull, it's a super simple mod (why not just "clip on" a tinted piece of acrylic then and forget the whole STC process) and the regs are a pain in the ass sometimes, but that's how it is.