Gone With The Wind?
The field approval process
The process has essentially remained the same . . . some areas required more attention to detail than others and that is going to require more time and effort to complete.
The epic book and movie story by Margaret Mitchell described how the Civil War spelled the end of an era. Some say it seems appropriate to cite when discussing what we all know as the field approval process. Rhett Butler and Scarlet O'Hara saw the end coming in the movie and acted accordingly. Tara was abandoned.
We all suspected it was coming sooner or later. You should have noticed that maintenance inspectors for the last several years have been more and more reluctant to approve field work involving a 337 form. It seems it has been common to refer the matter to the Aircraft Certification Office (ACO) for approval. Many were told to hire a Designated Airworthiness Representative (DAR) or Designated Engineering Representative (DER) so that they might assist in providing approved data. There was some difference in how the process was treated at the various FSDO's around the country. The procedure cried out for organization and revision. Well we got it!
At a current IA seminar an inspector stated that the field approval was going to be so complex now it will be almost impossible for the average tech in the field to complete. He said that for all practical purposes it is gone. After reviewing the new requirements this may or may not be true . . . but, it will be more complex and require more paperwork. The process has essentially remained the same. It's just that some areas require more attention to detail than others and that is going to require more time and effort to complete.
HBAW 02-03 (ASI Handbook Bulletin)
Last October the FAA published Handbook Bulletin 02-03 that addressed the procedures for inspectors to follow when performing field approval functions. The directive was designed to tie together all the different interpretations of the field approval process that have been existing for some time. This was supposed to be the final word on the issue. This instruction to ASI's has since been reduced to an "Order" making it mandatory guidance for the field inspectors to follow on the subject (8300.10 CHG 15). The title reads "Perform Field Approval of Major Repairs and Major Alterations." So, at least in theory and on paper, the field approval still exists.
Needless to say, the instructions seem to have taken a lot of discretion from the IA's and repair facilities and placed more emphasis on using the bureaucracy. Alaska technicians and operators, who have been allowed significant leeway on the subject in the past, will likewise be pressed to follow the procedures. Some say things will come to a boil in Alaska! We'll see.
Since the bulletin has now become an "Order" neither an IA, repair station, or field inspector can independently approve a repair or alteration without further input. Additional steps have been added to the process that make it sound a little more complex.
Many operators feel that in the FAA's zeal to help organize the field approval process the exact opposite seems to have occurred. Only time will tell.
The Aircraft Certification Division has recently stated . . .
"We have noted, over time, some inconsistency and lack of standardization in the way Flight Standards District Offices issued field approvals. In some instances, inspectors issued field approvals when the product should have received an STC. This order . . . will ensure that we will better identify alteration projects that need to be referred to the ACO as a potential STC project."
(Order 8110.46, 9-30-02).
The Question: To field approve or to STC? By Joe Hertzler R ecently I was studying the field approvals of FAA Form 337s, what I consider to be the hottest issue between the FAA and...
I have been told that getting an FAA field approval is a lot like getting an elephant pregnant.
On May 21, 2003, seven months after the Federal Aviation Administration (FAA) made the first substantive revision to field approval policy in 20 years
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.