Red Tape

My father was a big man, straight from the old sod. He was a lot smarter than I and a card-carrying survivor of the depression years.

Son of a gun, almost by mistake, during the rule-making process I went and identified a regulatory policy pot-hole. The existing policy was unfair to the FAA inspector who signed Block 3 of FAA Form 337 because when that inspector signs off block 3, he or she ceases being a judge and becomes a partner in the field approval process, and the inspector's career can be short-lived if he or she signs off a less-than-complete field approval. The policy was also unfair to the technician who is required to perform maintenance and inspections on both new and old installed equipment to a published standard in order to sign off that equipment as airworthy. If the technician signs off the inspection or maintenance on the equipment installed under a field approval without out using some sort of acceptable data, he or she is in violation of FAR 43 section 43.13 performance rules.

The bureaucratic fix

Since I am blessed with a smaller than average neural network, I tend to lean toward simplistic solutions rather than creating huge policy quagmires. My bureaucratic fix addresses major alterations approved under a field approval process only. I did not elect to include major repairs in this new policy because the vast majority of major repairs do not require additional instructions for continued airworthiness. Ninety-nine percent of major repair always returns the damaged area or product back to its original type design, and existing maintenance instructions should already be in place.

The new policy addresses all type certificated aircraft, engines, propellers, and appliances so the major alteration can be maintained in accordance with section 43.13 (a). The instructions for continued airworthiness for the new equipment must be identified either on Block 8 of the FAA Form 337 or permanently attached to it. I wanted the Instructions for continued airworthiness on the Form 337 for three reasons.

1. The technician requesting the field approval must develop the instructions for continued airworthiness or provide the new equipment manufacturer's instructions to satisfy the new policy.

2. Since the instructions for continued airworthiness are on the Form 337, it would give the FAA inspector an opportunity to review the maintenance instructions and make common-sense changes if necessary, before the field approval was signed.

3. Since section 91.417 (a)(vi) Maintenance Records requires that FAA Form 337 to be kept forever with the aircraft, a technician working on the same aircraft years from now could go to the original documentation for that major alteration, and that Form 337 would tell him how to maintain that piece of new equipment.

In addition, the Flight Standards Information Bulletin requires the technician in accordance with section 43.9 to record in the aircraft's log book or maintenance record the major alteration. I recommend that the log book entry identify the FAA form 337 by owner and date where the instructions for continued airworthiness, so they can be quickly found by a technician a year from now.

Questions from the field

As with any new policy that is developed in FAA headquarters there is a certain length of time in which everybody has to get use to the new way of doing business. In order to lower the compliance threshold of pain associated with change, I will try to answer some questions I think might be generated from the field offices and industry concerning my latest literary tome.

Question: Hey, Headquarters! How about some ideas on what the these instructions for continued airworthiness should cover?

Answer: The Instructions for Continued Airworthiness should cover the total system that is installed, be it a single piece of equipment, or 40 or more that are installed. The recommended periods in which they should be cleaned, inspected, adjusted, tested, and lubricated; the degree of inspections; the applicable wear tolerances; and the kind of work recommended to be performed at each inspection interval should be identified. If the maintenance to be performed is pretty complicated, for example, a D check of a nuclear powered port-a-potty installed on a Porterfield, the Form 337 can refer to published instructions from the equipment manufacturer instead of putting all of the instructions on the back of the Form 337.

Question: Yo! A question from Philly. I install a new instrument panel, radio shelves, etc., to install a standard TSO radio package. This is comic book simple structural stuff that does not create a fuss, generate any dust, or rust, works real fine, and lasts a long time. It just sits there attached to the airplane. Do I really need to write up 48 pages of Instructions for Continued Airworthiness to satisfy the FAA?

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