There seems to be a perceived mystery, or perhaps just naivety, concerning the use of the electronic version of the FAA Form 337. I would like to clear the air on some of the misconceptions around the subject.
For those interested in embracing it, this technology actually works and is another tool intended to improve data quality, increase the processing speed, and lessen the cost of delays for schedule commitments and travel to gain approvals.
In almost every public forum the question is asked, “Is the FAA going to make the e337 mandatory?” My official response is I don’t know! However, I don’t think so in the near future because there are issues that need to be resolved.
I work for FAA Headquarters in the General Aviation Maintenance Branch, AFS-350, and was assigned the project upon conception. Being a “nuts and bolts” type, I really wasn’t comfortable overseeing the business aspects of a complex IT project. However, management saw it differently since I’d spent 30 years in the industry as an IA, accumulating a pretty healthy dose of knowledge about the form and how it should work. Thus, my decision was made for me ... or should I say I didn’t have a decision to make.
The concept was presented to AFS-1 by the Alaska Region as a means of supporting folks in remote areas.
Jim Ballough, AFS-1, saw the potential and ordered the development of a national application. This means anyone with Internet service could use the system. I found it amazing how the rusty old doors of bureaucracy would open with support from the top. Almost instantly the core team was formed and supported by IT, finance, aircraft registry, inspectors, individuals from the business sector, and many others.
In those early years requirement documents were written, finance procured, contractors selected, and processes initiated following all the protocol of any government project. In all, the system moved forward from conception to implementation in just short of two years — light speed by any standard. Of course there were short-term requirements and long-term goals to be accomplished with respect to schedule timetables and fiscal monies available. Nonetheless, the dedication and commitment of the team to make it happen and make it right was an inspiring experience.
We were well into the project before I realized that in the same time period the IT folks had been working on a method for incorporating all (or at least other) FAA forms for interactive online processing. The 337 happened to come along and was selected to be the prototype to do that.
My philosophy was to use the KISS (keep it simple, stupid) principle. I only had two basic requirements: it had to do what we said it would do, and it had to be as user friendly as protocol would allow.
Doing business differently
Several things happened during the development that differed from the way we had been doing business. One of the most significant was the decision by AFS-1 that inspectors would no longer perform 337 reviews before sending them to registry. This proved to be a highly controversial decision that generated a lot of uncomfortable comments from the field.
The bottom line was that there was no regulatory basis for the review. Along with that decision came the order to provide a different way for inspectors to oversee their certificate holders. We knew that would cause some re-design of the system workflow as well as a rule change and guidance to inspectors and industry.
Current information is essential so it was decided that the main web page (eformservice.faa.gov) would be the primary place of information. This includes training, tutorials, help information, setup procedures, and contact numbers for assistance.
The new 337
The Form 337 had not been revised since 1986 and there were upgrades to regulatory references necessary. The form went through some minor changes updating reference information as well as reversing block 4 and 5 to flow better and code out the potential for as many of the typical errors as possible, which often resulted in the form submission being returned by the registry. What does that mean?
Well, simply this: Blocks 1 and 2 auto-fill by a search feature from the registry database ensuring accuracy of information and a registration number (N), serial number (S/N) validation of the aircraft on file with registry. The number must be entered manually to ensure the proper aircraft has been identified.
Block 3 includes selection of canned inspector statements and includes the current “statement of completion” by designees. Blocks 4 and 5 were reversed so that checking the type block first eliminates the possibility of multi-line entries. Blocks 6 and 7 include a box for certificated organizations which allows for the rare occasions that an air carrier might use the form, as well as providing the space for any future purposes.
Some have asked, “Why can’t I electronically sign Blocks 6 and 7 at the same time instead of submitting it to myself?” Look at it this way: the computer doesn’t necessarily know how many different certificates you have. If you logged in as the authorized individual performing the work (A&P mechanic), it doesn’t know if you hold an IA for return to service until you log in as such. It’s the same as a mechanic performing the work and switching hats to perform the inspection function as an IA.
Block 8 auto-fills the registration number and date from the information on the front page, making it easier to match a description of work accomplished with the proper aircraft. Without a lot of cost in development, Block 8 cannot validate applicability and/or conformity of the work to the aircraft — but obtaining approved data applicable to the aircraft being worked on is the submitter’s responsibility.
OK, how do we use it?
First, I strongly recommend everyone review the information on the web page. If you need help or don’t understand, a dedicated help desk is available 24/7.
Secondly, you need to obtain two things before you can use the system. You must have an FAA account and a digital signature certificate.
The FAA account is free of charge and its purpose is so the system can validate that you are who you say you are when filling information on the work that you are authorized to perform.
The digital certificate is obtained from a third-party contractor at a minimal cost. Why does it cost anything, you ask? The FAA is in the safety business, not the digital certificate business.
That’s it. Know enough to be dangerous. Set up an account with the FAA. Obtain a digital signature (digital certificate) and you’re off and running. And please, don’t hesitate to ask for help. There is a lot of it available and that’s what it’s there for.
Bob Stockslager works in the General Aviation Maintenance Branch, FAA, AFS-350.
