337 for interior plastic

[Robert M. Gary]

So, I sent off for new interior plastic. The pieces are not PMA'd so
the dealer is telling me I need to do a 337. Reading part 43 I see
preventative maint says..

(9) Refinishing decorative coating of fuselage, balloon baskets,
wings tail^
M
group surfaces (excluding balanced control surfaces), fairings,
cowlings,^M
landing gear, cabin, or cockpit interior when removal or disassembly
of any^M
primary structure or operating system is not required.^M


This makes me think I can replace my cabin vent covers myself. Does
that means I can also sign the 337? Do I need to pay an A&P a minimum 1
hour labor to sign the 337?


-Robert

[Jim Burns]

The dealer is nuts. What part 43 is telling you, is that you do NOT need a
337, in fact the FSDO inspector will deny your 337 because it is not a major
repair or alteration. All you need to do is install it and make a log book
entry under your name and cert #.
Jim

"Robert M. Gary" > wrote in message
oups.com...
> So, I sent off for new interior plastic. The pieces are not PMA'd so
> the dealer is telling me I need to do a 337. Reading part 43 I see
> preventative maint says..
>
> (9) Refinishing decorative coating of fuselage, balloon baskets,
> wings tail^
> M
> group surfaces (excluding balanced control surfaces), fairings,
> cowlings,^M
> landing gear, cabin, or cockpit interior when removal or disassembly
> of any^M
> primary structure or operating system is not required.^M
>
>
> This makes me think I can replace my cabin vent covers myself. Does
> that means I can also sign the 337? Do I need to pay an A&P a minimum 1
> hour labor to sign the 337?
>
>
> -Robert
>

[Jim Burns]

> >All you need to do is install it and make a log book
> >entry under your name and cert #.
>
> Certainly what I would do. However, in addition to name and cert # you
> need to include date, type of "Cert," and reference the maintenance
> manual pages RE: installation of the interior items.

Correct. My omission.
Jim

[George Patterson]

Robert M. Gary wrote:
> So, I sent off for new interior plastic. The pieces are not PMA'd so
> the dealer is telling me I need to do a 337. Reading part 43 I see
> preventative maint says..

Part 43 tells you that replacing these items is preventative maintenance, *not*
a major repair or alteration. No 337 is required.

George Patterson
If a tank is out of ammunition, what you have is a sixty ton portable
radio.

[RST Engineering]

C'mon folks. This clown has been in these ngs for a month now railing on
these plastic parts. He is either trolling or paranoid.

In either case, let him deal with it himself or pay a thousand dollars to
one of my colleagues for a logbook signature.

(BTW, I'm available for the logbook signature if he is {;-) )


Jim

[Robert M. Gary]

Of course when I posted the first time I was asking about needing a 337
because it is not PMA'd. This post was asking if a 337 was necessary if
I could sign it since the work itself seems to fall under preventative
maintenance.

[RST Engineering]

Again, you are a troll or paranoid. Pick one and tell us which it is.

Jim




"Robert M. Gary" > wrote in message
oups.com...
> Of course when I posted the first time I was asking about needing a 337
> because it is not PMA'd. This post was asking if a 337 was necessary if
> I could sign it since the work itself seems to fall under preventative
> maintenance.
>

[Robert M. Gary]

I know what I am, sounds like you need to pick.
I'm asking if there is a reasonable way to replace my vent covers with
full FAA approval. If you aren't interested in aviation, FAA
regulations or the maintenance of aircraft, I suggest you find another
newsgroup to read.Meanwhile, let the rest of us enjoy our aircraft and
do our best to keep the FAA happy.

-Robert

[Darrel Toepfer]

Robert M. Gary wrote:
> I know what I am, sounds like you need to pick.
> I'm asking if there is a reasonable way to replace my vent covers with
> full FAA approval. If you aren't interested in aviation, FAA
> regulations or the maintenance of aircraft, I suggest you find another
> newsgroup to read.Meanwhile, let the rest of us enjoy our aircraft and
> do our best to keep the FAA happy.

Robert, advice given here is worth exactly what you pay for it...

Information from reading between the lines of what Jim Weir types...

Priceless...

[Ron Natalie]

Gene Kearns wrote:

> Certainly what I would do. However, in addition to name and cert # you
> need to include date, type of "Cert," and reference the maintenance
> manual pages RE: installation of the interior items.

Well specifically, it requires a description of the work. There's
no requirement to reference maintenance manual pages.

22 Nov. 2005, Ronald Natalie, Replaced decorative interior plastics
with kit from PlanePlastics, Inc. SIGNATURE NNN-NN-NNNN Private
Pilot.

[Ron Natalie]

Robert M. Gary wrote:
> Of course when I posted the first time I was asking about needing a 337
> because it is not PMA'd. This post was asking if a 337 was necessary if
> I could sign it since the work itself seems to fall under preventative
> maintenance.
>
The need for a 337 and the fact that these lack a PMA (or other
authority) and hence may be unapproved parts are unrelated items.

[OtisWinslow]

Robert,

The only flag I see is the fact that it's not an approved part and could
be interpretted as not meeting the type certificate.

Now having said that, I've replaced/repaired/repainted interior plastic
parts on several planes I've owned and didn't even make a log entry.
Shame on me.

For the ones you're not replacing go buy some S.E.M. paint for
flexible surfaces. Works great. Available at auto body stores.

OW


"Robert M. Gary" > wrote in message
oups.com...
> So, I sent off for new interior plastic. The pieces are not PMA'd so
> the dealer is telling me I need to do a 337. Reading part 43 I see
> preventative maint says..
>
> (9) Refinishing decorative coating of fuselage, balloon baskets,
> wings tail^
> M
> group surfaces (excluding balanced control surfaces), fairings,
> cowlings,^M
> landing gear, cabin, or cockpit interior when removal or disassembly
> of any^M
> primary structure or operating system is not required.^M
>
>
> This makes me think I can replace my cabin vent covers myself. Does
> that means I can also sign the 337? Do I need to pay an A&P a minimum 1
> hour labor to sign the 337?
>
>
> -Robert
>

[RST Engineering]

Sorry. I forgot my full sig line:

Jim Weir
Commercial Airplane/Glider Instrument CFI Airplane/Glider
A&P IA
Owner C-120 N2014V, C-170 N4190V, C-172 N3618S, C-182 N73CQ


"Robert M. Gary" > wrote in message
ps.com...
>I know what I am, sounds like you need to pick.
> I'm asking if there is a reasonable way to replace my vent covers with
> full FAA approval. If you aren't interested in aviation, FAA
> regulations or the maintenance of aircraft, I suggest you find another
> newsgroup to read.Meanwhile, let the rest of us enjoy our aircraft and
> do our best to keep the FAA happy.
>
> -Robert
>

[Robert M. Gary]

Thanks Ron! 337's have always confused me. Its never been clear to me
when I need one, when they must be signed by the FAA etc.

[Robert M. Gary]

Otis,
But as an A&P (not sure if you are or not, I'll assume you are for the
discussion) aren't you allowed to self-certify that a part is
substantially similar to the original, and therefore just install it? I
know that my A&P has made brackets for me and says that is how he is
able to replace them with OEM without a 337.

-Robert

[Michael]

Robert

Jim Weir tends at times to be a little less that patient, at other
times tends to disseminate information that is less than correct, and
at times tends to operate in the margins of legality, but his
credentials here are not in question. And you are being just a little
bit paranoid.

A Form 337 is an FAA record of major repair or alteration. The ONLY
time one is required is when you perform a major repair or alteration.
A major alteration requires approved data, and must be signed by an IA.
The sticking point is what constitutes approved data. An STC is
approved data. So is an FAA field approval (which you won't get), or a
DER's report. Everything else is iffy. I've had 337's bounced back
because an FAA-approved (complete with serial number, revision date,
and revision history) installation manual for a TSO'd component was
judged not to be approved data. Two years prior, the exact same manual
was considered by the same FSDO to be approved data and the 337 was
accepted.

What I am trying to say, ever so gently, is that there is no such thing
as a cost-effective clear-cut answer when it comes to altering an
aircraft. If you insist on getting a clear-cut, black-and-white, no
shades of gray kind of answer, you will be going down the road of
needing a DER to generate approved data for your major alteration
requiring a 337. That's not reasonable, but that's the CYA answer
you're going to get. It's the CYA answer the dealer gave you. He
didn't want to jump through the hoops of getting an STC or PMA, but if
he even suggests that you install his plastic without approved data,
all it takes is some fed to decide it's major and he's looking at a rap
for selling unapproved parts.

Another way to look at this (the way you're trying to do it) is that
you are installing a decorative or preservative coating which is not
prohibited and not contrary to good aviation practice. That's
preventive maintenance, and requires nothing more than a logbook entry
made by you. So who makes the determination that what you are doing is
preventive maintenance rather than an alteration? Well, you do. And
your determination stands until some fed (or overly officious IA doing
your annual) decides otherwise. Of course you could call your FSDO and
ask for an official determination (in writing). The determination you
will probably get (since it's the safest one for the fed to issue) is
that unless you show otherwise, you should hire a DER and get an STC.
The fed is not likely to stick his neck out and say it's minor - that
exposes him to risk, and there's nothing in it for him.

This is not a good way to do things, but it's what we are stuck with.

One of the reasons I maintain a certain amount of anonymity on the net
(even though anyone with half a brain and minimal skills in using
Google can figure out - but not legally prove - exactly who I am) is so
I can give out advice that could get my A&P revoked. Here's my advice.
Put in the plastic. Don't sign a damn thing. It was always there.

Or you can make the logbook entry. It will probably be OK - but it can
be used to violate you.

Michael

[OtisWinslow]

I'm not an A&P .. nor do I play one on tv. Didn't stay at Holiday Inn
Express either. Just
an owner. I didn't say what I did was technically legal.


"Robert M. Gary" > wrote in message
oups.com...
> Otis,
> But as an A&P (not sure if you are or not, I'll assume you are for the
> discussion) aren't you allowed to self-certify that a part is
> substantially similar to the original, and therefore just install it? I
> know that my A&P has made brackets for me and says that is how he is
> able to replace them with OEM without a 337.
>
> -Robert
>

[Scott Skylane]

Michael wrote:

/snip/

Michael,

With all due respect, I'll paraphrase you're post as such:

F**k the FAA, put the s**t in, and fly on! Believe me, no one will
care, the airplane will fly just fine, and the paranoid types might as
well just hide under the nearest rock, anyway.

Happy Flying!
Scott Skylane
N92054

[Robert M. Gary]

I'm not sure paranoid has anything to do with it. The question was if
there was any reasonable to do with with FAA blessing. Wanting FAA
blessing, if possible, is not paranoid in my book. If anything, its
helped me gain a better understanding of regulations with regard to
non-TSO'd parts.

[Mike Spera]

> I'm not sure paranoid has anything to do with it. The question was if
> there was any reasonable to do with with FAA blessing. Wanting FAA
> blessing, if possible, is not paranoid in my book. If anything, its
> helped me gain a better understanding of regulations with regard to
> non-TSO'd parts.
>

This news group has value to some of us as a forum to share experiences
relating to the rather inexact science of airplane ownership. Given an
airplane's unique ability to delight, thrill, bankrupt and/or seriously
kill you, the discussions are at times rather unique.

In terms of a cosmetic parts swap like interior plastic, there is plenty
of "gray" area in the rules to spawn a diverse response to many
questions. Unlike questions about strictly procedural tasks, like "how
do you change wheel bearings in a Bugsmasher 2000", this plastics
discussion is less about safety and more about FAA legalities.

For those who give advice like "just do it", remember, the jury is
forever "out" whenever you yourself do such a thing. At any time, some
A&P or FAA inspector on the ramp may tap YOU on the shoulder and say "I
don't think so" to the very operation you are recommending to others.
Yes, the likelihood of someone KNOWING about some of this stuff may be
quite slim. But, we have all read the horror stories of what happens
when someone is forced to get a "new" mechanic ("hey, nice interior
plastic, where's the paperwork?????"). Remember Jay's wing tip strobe
"adventure".

To those considering taking the advice they receive here, remember that
it is always YOUR safety and YOUR responsibility if something goes
wrong. Many who post here do so with a certain zeal that might give the
newbie the impression of authority or experience. That may be absolutely
true or false. An A&P mechanic may say something that is completely
untrue, and the non-credentialed airplane owner may say something that
is spot on. Truth is in the eye of the beholder and can be quite
fleeting. Again, it is up to the reader to decide. Look for patterns of
rational responses. Consider throwing out the top and bottom 10% of
responses ("screw the Feds, just do it" and "YOU ARE GONNA DIE
MAN!!!!!!!").

Like the weather reports, you may run into serious trouble either
completely believing someone, or completely disbelieving them. In the
airplane world, if it sounds simple, cheap, or quick, it is likely to
prove to be an unwise path.

Good Luck,
Mike

[[email protected]]

On 19-Nov-2005, Mike Spera > wrote:

> For those who give advice like "just do it", remember, the jury is
> forever "out" whenever you yourself do such a thing. At any time, some
> A&P or FAA inspector on the ramp may tap YOU on the shoulder and say "I
> don't think so" to the very operation you are recommending to others.
> Yes, the likelihood of someone KNOWING about some of this stuff may be
> quite slim. But, we have all read the horror stories of what happens
> when someone is forced to get a "new" mechanic ("hey, nice interior
> plastic, where's the paperwork?????"). Remember Jay's wing tip strobe
> "adventure".


I think that some common sense is in order here. Remember, the intent of
the regs with respect to maintenance is flight safety, not creating a
"gotcha" situation. The fact is, application of the rules regarding
preventative maintenance (which can be performed by the pilot/owner) leave
quite a bit of room for interpretation. Patch a hole in seat upholstery?
Sure, no problem. Completely recover the seat? It seems like that would be
allowed as "replacing seat parts" but you have to use parts "approved for
the aircraft" whatever that is. On the other hand, one could argue that
recovering a seat is "repairing upholstery" which is allowed without mention
of using approved parts.

My take on repair, painting, or even replacement of simple interior plastic
pieces is that this falls under the category of "repair" of "decorative
furnishings" even if the components in question are involved in cabin
ventilation. My thinking is that such maintenance is far less likely to
impinge upon safety than, say, performing an oil change, which is certainly
allowed.

I would hazard a guess that if some anal retentive FAA examiner wanted to,
he/she could find at least one maintenance violation in just about any
privately owned airplane that is more than a few years old. Here's an
example from our Arrow: It came from the factory equipped with cloth
curtains that could be used by rear seat passengers to shade the sun. They
really don't work very well and are generally a pain in the butt, so we
simply removed them. Now, since they comprise maybe a total of two ounces
of the "official" empty weight and are part of the airplane as certified,
and since there is no mention in the POH that they can be removed if
desired, strictly speaking they have to be there for legal flight. My guess
is that if we ever get a ramp check we will be given a pass on this one.

--
-Elliott Drucker

[Robert M. Gary]

The company making the plastic vent is the same company who is making
the headliners. They hold a PMA for the headliner, so I assume they are
familiar with the FAA requirements for plastic interior stuff.

[Mike Spera]

>>I would hazard a guess that if some anal retentive FAA examiner wanted to,
>>he/she could find at least one maintenance violation in just about any
>>privately owned airplane that is more than a few years old.
>
>
> every airplane, even one just off the line. jet or piston.
>

I agree completely. But, rather than use that as permission, I had a
slightly different take on it. In reality, the bigger chance of "gotcha"
is during an annual with a new wrench rather than a ramp check. The
mechanic's ticket depends on them avoiding Insurance company violations,
FAA scrutiny, and unpleasant events like crashes. They will be LOOKING
for unsafe stuff. Now, whether they also get picky about regulatory
minutia depends on the wrench and their mood that day.

So, I figure that the fewer things that are stretching the limits of the
rules (including non safety issues), the better the chance you have of
emerging with your annual signed off unscathed.

Yes, it seems intuitive that the rules were made to promote safety. But
the "pencil whip" rules have no less effect in the eyes of some IAs and
FAA folks. If you are unfortunate enough to get one of these on a bad
day, the outcome is the same (bad for you).

I think we all agree that breaking the rules that keep us safe is
something to be avoided. What is the difference between safety and
seemingly cosmetic rules designed to trip you up? THAT is the big question.

Good Luck,
Mike

[RST Engineering]

Google on HED231 or go to www.trumeter.net. Last I was in contact with
them, they had a retail outlet in Florida, but the mechanisms themselves are
made in Thailand and exported by a UK company.

Jim





"Gene Kearns" > wrote in message
...
> On Thu, 17 Nov 2005 08:46:35 -0800, "RST Engineering"
> > wrote:
>
>>Sorry. I forgot my full sig line:
>>
>>Jim Weir
>>Commercial Airplane/Glider Instrument CFI Airplane/Glider
>>A&P IA
>>Owner C-120 N2014V, C-170 N4190V, C-172 N3618S, C-182 N73CQ
>>
>
> Ok, then, let's check your memory......
>
> you wrote an article a few years back about building a digital (I
> think) clock. One of the guys I work with wants to build one for his
> RV-4..... but Radio Shack no longer carries the "clock board." Is
> there still an affordable board that can be substituted in this
> application? I forgot and left the article and specs at work, but I
> can get them if necessary.....
> --
>
> Homepage
> http://myworkshop.idleplay.net/
>
> |
> ____________________|____________________
> \ | | /
> `.#####.'
> /`#_#'\
> O' O `O

[RST Engineering]

<bigger reality>
Expect changes in 14CFR Part 43 that will allow many more "field
repairs/modifications" without going through the major DER/337/fieldapproval
bushwa that we are going through at the present time.

</bigger reality>

Jim


>
> <reality>
> Expect changes in 14 CFR Part 43 that will put major restrictions on
> "Preventive Maintenance" unless you have been formally trained in
> same.
> </reality>

[Michael]

> Remember, the intent of
> the regs with respect to maintenance is flight safety, not creating a
> "gotcha" situation.

As an A&P, I believe this is absolutely not true. The regs actually
make it more difficult to do proper and safe maintenance, and easier to
do a shoddy but approved job. The intent of the regs is exactly to
create a "gotcha" situation so as to empower an FAA inspector to ground
any aircraft at will. The sooner you understand that, the easier it
will be to figure out what does and doesn't make sense.

> I would hazard a guess that if some anal retentive FAA examiner wanted to,
> he/she could find at least one maintenance violation in just about any
> privately owned airplane that is more than a few years old.

Any airplane that is out of warranty - period. Only reason for the
warranty exception is that the factory might fight him on it if the
factory is responsible for the repair, and there's some money and clout
there. They can bring in people to overrule him. You can't.

I've seen it happen. I've seen airplanes grounded for illegible
(supposedly) TSO tags on seatbelts and placards curled up at the
corner, and the pilots written up for flying those supposedly
unairworthy airplanes. The rules are the way they are so feds can do
that. Safety doesn't enter into it.

Michael

[Michael]

> In reality, the bigger chance of "gotcha"
> is during an annual with a new wrench rather than a ramp check.

Correct. Practically the only chance, in fact, unless you decide to
take your airplane to the FSDO. And there is a solution. Don't allow
random mechanics (those that don't come without a personal
recommendation) to annual your airplane. Ever.

What happened with Jay Honeck's strobes is a perfect example of how bad
an idea that is. He had a Form 337, all signed and legal. It wasn't
good enough. Nothing ever is, if you get the wrong mechanic.

Michael