On May 21, 2003, seven months after the Federal Aviation Administration (FAA) made the first substantive revision to field approval policy in 20 years, the FAA issued a second revision. This latest revision is Change 16 to Volume 2, Chapter 1, of FAA Order 8300.10, Airworthiness Inspector's Handbook. You can get a copy of the Order and revisions by getting online and pulling up: http://www2.faa.gov/avr/afs/faa/8300/.
It would be an understatement to say that everyone, including the inspectors in FAA local Flight Standards District Offices (FSDO), was happy with the first revision. So, armed with an exemption from the Environmental Protection Agency (EPA), I will attempt to put oil on troubled waters with a two-part article on field approvals. Part 1 will provide a short history of field approvals; in Part 2, I will cover the latest policy that came out in late May of this year. However, before we get too far into the field approval process, I would like to go over a few important facts.
- FAA FSDOs nationwide process approximately 23,000 field approvals a year.
- Of those 23,000 field approvals, approximately 65 percent deal with avionics installations (major alterations).
- FAA airworthiness and avionics inspectors must be trained and authorized by their individual region and office before they can perform field approvals.
- However, once approved, the authority and responsibility to perform a field approval is the FSDO inspector's alone.
- The FSDO inspector must have experience in the areas that the applicant wants to alter or repair before he or she can sign off block 3 of Form 337.
- FAA field approvals are "policy driven," not "regulatory driven." In other words, field approvals are not specifically addressed in FARs.
- Because there is no rule that speaks to field approvals, maintenance personnel do not have a regulatory right to get a field approval.
- Field approvals are listed in the FSDO inspector's work program as Demand Work, not Required Work, so they do not get extra marks on the bark for each field approval they sign off.
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.
I have been told that getting an FAA field approval is a lot like getting an elephant pregnant.
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