337 challenges

[6843]

So here's the end of the story. I called Desser fearing they would say the tires were too old (they were bought in the summer of 2019) and they couldn't help me. I was wrong. They generously allowed me to return them (with a restocking fee) and credited the refund to a set of 8.00X6 tires and tubes. The cost difference was $110. So rather then try to figure out the 337 problem, I'm getting the bigger tires I wanted without hassle.

Over the years I've heard a few bad stories about Desser but I'm a loyal customer for life now. What great customer service.

[6643]

John, which document are you pulling out that info that you pasted above pertaining to types of approved data?

That material is from the course material I used to use for AV-101- Forms and Records. It is a compendium of information from many sources, including texts, ACs and conversations with our FAA overseers.

I've used a DER several times, and in every instance I took the DER's work to the FSDO and had them sign off in block 3. Maybe belt and suspenders, but certainly acceptable.

I'm not sure what the source of the wording "(Note: This type of data usually requires additional approval)" is, but it is consistent with my personal practice of using the DER work product to obtain a field approval.

I've never had an issue getting a field approval. I feel that every time what I was asking was reasonable, and I had my acceptable data ducks all lined up in a row. One time I was asked to have two full threads showing above a nut. I didn't argue, even though that's not the requirement.

I think unless things have changed there is “Approved” data, and data that may be “Acceptable” to the administrator.

Correct. Approved data can be used to approve a major repair or modification. Acceptable data (e.g. previously approved form 337s dated after 1/1/1956) can be used to support a field approval. The field approval is the approved data.

I believe for instance 43.13 which you would think is the Bible, is only data that May be acceptable, it is NOT approved data.
... or didn’t used to be anyway.

Correct again. It didn't use to be. However, while you were out cruising the Caribbean, new versions of both 43.13-1 and -2 were issued. The approval statements I posted earlier are taken directly from the front of each. When used according to those limitations, either constitutes approved data and can be used as the basis for approval with no additional requirements.

I should point out that I see many folks making this process more onerous than it needs to be, generally by seeking a field approval when one isn't necessary. For example, FAR 43 appendix A lists all work that constitutes a major repair or a major modification. If what you are not doing is not on that list then you do not need to seek FAA approval or file Form 337. Additionally, if what you are doing is described in AC43.13-1 or -2 and meets the limitations I posted earlier, then you already have approved data and do not need to involve the FAA beyond filing the Form 337 to record the repair or modification. Seat belts is another area of confusion. The FAA issued Policy Statement Number ACE-00-23.561-01 on shoulder harness retrofitting, listing the types of retrofits that can be done as minor modifications, requiring only a log book entry.

So, don't poke the sleeping dog if you don't need to!

[6898]

John, Thank You for taking the time to help with this. You and many other members are why this forum is valuable. the other "quick" forms of media today you get a lot of personal opinions and not the facts or the time to dig in where others cant or don't know how? Thanks Again Jeff

[8359]

I believe inspectors being personally liable for FA's is a government wide thing. I work with quite a few government agencies in my day job and they are all very careful about saying anything because a few years ago they were told the same thing, that they are personally liable for any errors.

[8233]

Thanks John. The items I worked with a DER on, he was very specific that no additional field approvals would be required and that the 337 could go straight to OKC. I think that does depend on the nature of the work and the scope of authority of the DER.

I do find it interesting and frustrating how much variation we see depending on the combination of the specific FSDO, PMI and IA involved. If anything, I’ve learned there seems to be more than one way to skin a cat. I’ve heard stories that as the older guys are retiring and the new guys are coming into the FSDOs that things are getting much more difficult to accomplish.

[6643]

I believe inspectors being personally liable for FA's is a government wide thing.

On the other hand, when was the last time you saw a government employee voluntarily admit responsibility for something?

"Any resemblance to actual government employees, living or dead, or actual events, is purely coincidental."

[klyde sessna]

For just a little more on this subject, enjoy a chat with Mr. David Lowe in Kentucky. He has a few real life experiences in this matter to share. Probably some recommendations, too.

[8170]

I got my 8.50s and Grove axles field approved through the SDL FSDO no problem. I have been working with them for a long time and had a good relationship with the PMI. I guess it depends on what time of the year you catch them.

[klyde sessna]

Ok. So some folks say people are field approval and form 337 happy. Lots of times not needed. So..... if the 8.50 tire is approved on the Cleveland wheel, which is STCd for the plane, why do we need an additional approval for the tire?

The TCDS only gives the tire sizes approved for the original Goodyear wheel, correct?

The original certification was done under CAR4a.480:

"CAR 4a.480
Tires. A landing gear wheel may be equipped with any make or type of tire, provided that the tire is a proper fit on the rim of the wheel and provided that the tire rating of the Airplane Tire Committee of the Tire and Rim Association is not exceeded."

So who says we need this extra paperwork at all?

[8233]

For just a little more on this subject, enjoy a chat with Mr. David Lowe in Kentucky. He has a few real life experiences in this matter to share. Probably some recommendations, too.

That's exactly who I was thinking of when I made my comment above. He has some great and not so great stories, especially with the changing of the guard.