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.


Answer: If your major alteration just sits there, be it part of the structure, or if it is something like a radio package where there is nothing to rig, replace, remove, reinstall, or whatever, do this: note on the Form 337 that no additional instructions for continued airworthiness are required for this installation. This will tell the technician to inspect the installation in accordance with the aircraft manufacturer's instructions or in accordance with Appendix D of Part 43, or any other applicable inspection requirement.

Question: How in depth must these instructions be? Should I hire a tech writer to write the instructions?

Answer: The average field approval for major alterations are pretty standard fare. FAA inspectors are limited by FAA Order 8300.10 on just what they can field approve. So just write the instructions so that they are clear, complete, and concise to maintain the entire alteration, so that even this Washington DC bureaucrat can understand them. I would recommend that since most technicians are process-oriented folks and tend to do things in steps, write the instructions using bullets or steps. Please do not try to impress the FAA inspector by writing the history of rubber on the back side of a Form 337 if all the technician needs to know is how to change a tundra tire.

Question: Does this new policy include a major alteration performed under an STC?

Answer: No, this policy applies only to a major alteration performed under a field approval. For major alterations for aircraft, engine, or propeller installed using STC data, these alterations already are required to have instructions for continued airworthiness by section 21.50(b).

Question: Hey, Bureaucrat! I checked the book. Section 21.50(b) does not talk to appliances such as radios, GPS, interiors, and the like, so an STC for a radar installation in a corporate jet might not have any instructions for continued airworthiness. What do you want us to do?

Answer: You are right. Section 21.50(b) does not speak out loud to appliances. However, Part 43 section 43.13 (a) still requires the technician to use acceptable data to maintain appliances. To ensure future compliance with section 43.13(a), when the STC does not have instructions for continued airworthiness (ICAW) for an appliance, I suggest you contact the local FAA office, and they in turn will contact the appropriate FAA's Aircraft Evaluation Group (AEG.) These are the folks who approved ICAW for STC installations, and they should be able to help you out.

I told you what writing policy does for me, but what would this additional red tape do for the technician on the hangar floor? Well, it should save the technician time, money, and a visit from the log book police. For example, let's suppose that today you installed a TSO Imperial Star VCR model 7000 in the cabin of a Falcon 50, and you complied, with some reluctance, with this new policy. A year from now the VCR you installed was just about demolished by the company's CEO who tried to put two video tapes in the machine at one time. Wouldn't it be nice if a technician, a year from now, could go to the major alteration's Form 337 for the TSO VCR, installation and find instructions for continued airworthiness. And maybe those instructions read something like this:

Instructions for Continued Airworthiness for TSO VCR Imperial Sta, model 7000.

1. TSO VCR model 7000 is a on-condition unit and no additional maintenance is required other than to check for security and operation at normal inspection intervals.

2. If the VCR is inoperative, remove unit, secure cables and wiring, turn off applicable switches and circuit breakers and placard them inoperative, revise equipment list and weight and balance as applicable prior to flight, and make a log book entry unit was removed (refer to section 91.213 of the FAR or the aircraft's MEL)

3. The VCR can be repaired only at a factory authorized repair center or an appropriately rated FAA Part 145 Repair Station.

4. Once the VCR is repaired, reinstalled the unit in the aircraft in accordance with the original Form 337 approved data. Perform an operational check of the unit, and approve it for return to service with a log book entry required by section 43.9.

Question: When the FAA inspector "field approves" the acceptable data for a major alteration and turns it into "approved data" when Block 3 of the Form 337 is signed, does that also mean that the inspector also "approved" the instructions for continued airworthiness?

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