337 for interior plastic

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.

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

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

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.

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

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

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

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

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.

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