Tri-Pacer wrote:



Really ???? What FSDO do you work under?


Here's some discussion of this subject from the Beech Owners email list.



BB, I believe it has *always* been at the IA's discretion to make
major alterations.

The rub is that major alterations require approved data. The IA
signature on a Form 337 means that the IA has inspected the
alteration and found that it conforms with the approved data
referenced in the Form 337. The IA has no authority to approve the
data -- only an FAA employee or DER can do that.

I suspect what's going on here is that FSDO folks are getting out of
the data approval business, and that all alterations for which
approved data does not already exist (e.g., STC) will require hiring
a DER to approve the data. Essentially, approval of data will become
something you pay for instead of getting free. (Nothing's free, but
you know what I mean.)

IMHO the loss of the FSDO proofreading function for Form 337s is no
loss at all. Hopefully IA's are smart enough to figure out how to
fill out a Form 337 properly without help from the FAA. (Somehow, I
don't think safety is improved materially when a FSDO inspector kicks
back a Form 337 for a sun visor installation because it doesn't have
Instructions for Continuing Airworthiness in the proper 18-item format.)

Maybe having to hire a DER for what amounts to a field approval is
not such a bad idea. The DER will charge a fee for his services, but
at least it won't be a guaranteed "no" (which is pretty much what
most FSDOs have been doing on field approval requests in recent years).

In my view, the more maintenance- and certification-related functions
that can be transferred from FAA to the private sector (designees,
etc.), the better. They'll cost money, but at least they'll get done.

(No, I'm not in favor of privatizing ATC. g)

At 06:39 PM 1/7/2007, Bob wrote:

Since the FSDO has been eliminated, could it then be construed as
at the signatory IA's discretion to make major alterations?

BB:


----- Original Message ----- From: "carmine" carminefp at comcast.net
To: "Beech-Owners at Beechcraft. Org" beech-owners at beechcraft.org
Sent: Sunday, January 07, 2007 5:48 PM
Subject: B: 337


Attended an IA seminar this weekend here in the Seattle area and the
FSDO people made it very clear that 337's go toOklahoma and not to
them. They will accept those 337's that have a cover letter asking
if it's correct and acceptable. They said that Oklahoma will not be
critiquing them at all. Mentioned in the past they found errors in
25 to 50 percent of those submitted locally in any given year.



Cy, where did you get that impression? The change to Part 43
Appendix B which calls for Form 337s to be sent directly to OKC
instead of to the local FSDO makes no distinction between 337s for
major repairs and major alterations. All 337s are to be sent
directly to OKC after signed off by the inspecting IA.

As always, the IA may only sign the 337 if it references approved
data. If the data is not approved per STC or something similar,
approval of the data must be secured (from the FAA or a DER) *before*
the IA signs the 337.

Once the IA signs the 337, it now gets submitted directly to
OKC. The FAA recently unveiled a new system whereby 337s may be
filled out online and submitted electronically to OKC, which sounds
to me like a huge improvement (at least in terms of 337s getting lost
in the system and never showing up in the aircraft records at OKC).

At 08:08 PM 1/7/2007, cgalley wrote:
I believe these 337s are only for repairs not alterations.
----- Original Message -----
From: "Bob" parair at ca.rr.com
To: beech-owners at beechcraft.org
Sent: Sunday, January 07, 2007 8:39 PM
Subject: B: 337



Since the FSDO has been eliminated, could it then be construed as at the
signatory IA's discretion to make major alterations?




Cy, an IA has always been able to approve a major alteration. He has
never been able to approve the data for a major alteration -- only an
FAA employee or DER can do that. Approval of data by the FAA or a
DER must be done BEFORE the IA signs off the 337, not after. I think
we have a terminology problem here. A major repair or major
alteration requires two approvals -- approval of the data and
approval of the work. An IA has never been permitted to do the
former, and has always been permitted to do the latter. There is no
change in that regard. The only purpose for the FSDO to look at a
Form 337 *after* the IA signs it (approving the work) is for
proofreading purposes, not approval purposes. Under the new rule,
FSDOs are getting out of the proofreading business. --Mike

At 08:35 PM 1/7/2007, cgalley wrote:
But the IA can't approve an alteration. Maybe the person that said
you have
to "buy" an alteration thru a DER or DAR is right.