In Part 2 of my tome on field approvals, we will cover current field approval policy found in Change 16 to FAA Order 8300.10. You can pull up Change 16 on our web site at: http://www2.faa.gov/avr/afs/faa/8300/.
In order for the rest of the article to make sense, we have to first agree that a repair is a procedure or a process whose intent is to restore the aircraft or one of its parts back to the original design or properly altered condition. An alteration is a change to the original design or properly altered condition.
Is or isn't?
Before running to the FSDO for a field approval, your first question should be whether the repair or alteration staring you in the face is either major or minor. Making this is or isn't determination is not as easy as it sounds. If we look in 14 CFR part 1, the definitions of major repair and major alterations are strikingly similar. If we consolidate and paraphrase the two 14 CFR definitions of a major repair and a major alteration into one, it would look like this:
1. If a repair or alteration is improperly done, it might affect weight and balance, structural strength, performance, powerplant operations, flight characteristics, or other qualities affecting airworthiness.
2. That is not done according to accepted practices or cannot be done by elementary operations.
If you take that definition at face value, any repair or alteration that you do on an aircraft would be major because everything you touch on an aircraft affects something else. Even as a mechanic working at North Philadelphia airport 25 pounds ago, I always believed that the lawyers who wrote the part 1 definitions for major repairs and alterations should have worked a little harder to narrow the definitions down to a level of understanding we did not need a second legal opinion for.
So where do you go next to figure out major or minor? Try Part 43, appendix A. It lists major repairs and major alterations by powerplant, airframe, and appliances. But you may have a problem with the appendix A list. The problem is the lists in the appendix are not all that inclusive, so your repair or alteration may not be identified as major on the list. So if you roll craps, then try the manufacturer and see if it can tell you if what you want to do is major or minor. But it has been my experience that most manufacturers are less than helpful in the major repair or major alteration department because lawyers have made cowards of us all. In an act of final desperation, you can call your FAA inspector and ask your major or minor question.
Let's say you tried all of the above and still no luck. As a last gap measure I have a possible solution for you. Ask yourself three questions. If the answers to any of those questions are no, then the repair or alteration you want to perform is major. While not perfect, the three-part question enables you to focus on the decision in front of you. The question begins with: If the repair or alteration you performed totally fails, can the aircraft:
1. Continue to fly?
3. Keep passengers, crew, and people on the ground unharmed?
I have been told that getting an FAA field approval is a lot like getting an elephant pregnant.
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