Removing a Major Alteration.

Just returned from the annual Inspection Authorization renewal meeting. Not
too boring and some good information and good food. The one thing that got the
most attention was the assertion by one of the FAA inspectors that when you
remove any equipment installed with a Form 337 as a major alteration you must
complete and submit another Form 337 outlining the removal.

Their reasoning is that the 337 is a part of the permanent record of the
aircraft and therefore the record needs to be made complete by showing the
removal of the alteration. In other words the original modification made the
aircraft a properly altered entity and removing the mod again alters its even
though returning it to its original as certificated state. A sort of circle of
life thing I suppose.

Now I have been told by inspectors at other FSDO's I have dealt with that
returning the aircraft to its original as certificated status only needs an
entry in the permanent maintenance records , i.e. logbook, weight and balance
record, equipment list etc.

My FSDO says the other FSDO is wrong. (Big Surprise there!)

What do you say?


John Dupre'

John,
We were taught in A&P school that removing an Major Alteration will
require another 337 unless the original 337 specified that it may be
removed and or re-installed. Ag Ops do this so they can ad and remove
spray equipment at will once the original 337 is approved.
Michelle

JDupre5762 wrote:

Just returned from the annual Inspection Authorization renewal meeting. Not
too boring and some good information and good food. The one thing that got the
most attention was the assertion by one of the FAA inspectors that when you
remove any equipment installed with a Form 337 as a major alteration you must
complete and submit another Form 337 outlining the removal.

Their reasoning is that the 337 is a part of the permanent record of the
aircraft and therefore the record needs to be made complete by showing the
removal of the alteration. In other words the original modification made the
aircraft a properly altered entity and removing the mod again alters its even
though returning it to its original as certificated state. A sort of circle of
life thing I suppose.

Now I have been told by inspectors at other FSDO's I have dealt with that
returning the aircraft to its original as certificated status only needs an
entry in the permanent maintenance records , i.e. logbook, weight and balance
record, equipment list etc.

My FSDO says the other FSDO is wrong. (Big Surprise there!)

What do you say?


John Dupre'





--

Michelle P ATP-ASEL, CP-AMEL, and AMT-A&P

"Elisabeth" a Maule M-7-235B (no two are alike)

Volunteer Pilot, Angel Flight Mid-Atlantic

Volunteer Builder, Habitat for Humanity

JDupre5762 wrote:
Just returned from the annual Inspection Authorization renewal meeting. Not
too boring and some good information and good food. The one thing that got the
most attention was the assertion by one of the FAA inspectors that when you
remove any equipment installed with a Form 337 as a major alteration you must
complete and submit another Form 337 outlining the removal.

Their reasoning is that the 337 is a part of the permanent record of the
aircraft and therefore the record needs to be made complete by showing the
removal of the alteration. In other words the original modification made the
aircraft a properly altered entity and removing the mod again alters its even
though returning it to its original as certificated state. A sort of circle of
life thing I suppose.

Now I have been told by inspectors at other FSDO's I have dealt with that
returning the aircraft to its original as certificated status only needs an
entry in the permanent maintenance records , i.e. logbook, weight and balance
record, equipment list etc.

My FSDO says the other FSDO is wrong. (Big Surprise there!)

What do you say?


John Dupre'

Oh cripes, here goes another 2,340,981,234 article thread...

Actually, it doesn't matter what anyone here says (unless they are a FAA
power-that-be), it only matters what the FAA says.

A more productive thread would be, in a case of conflicting FSDO opinions,
how do you obtain the "One True Answer" that will stand up to scrutiny in a
worst case situation by all that may get involved, i.e. the FAA, the NTSB,
your insurance carrier, and Fred the mechanic?

--
Jim Pennino

Remove -spam-sux to reply.

The purpose of a 337 is to document a change in type design. Once modified,
the aircraft airworthiness is based on the data in the TCDS's -AND- the 337
form. Remove the alteration and the "official" airworthiness status has to be
changed via the 337.....unless, as someone mentioned, the original 337 deals
with converting for use as a camera ship (for example) then converting back as
required.

Here is the definition of airworthiness from the Inspectors handbook:
From 8300.10 chg 17 - The Inspectors Handbook

"(2) Airworthiness:
(3) Since “airworthiness� is not
defined in the FA Act of 1958, as amended, or in the regulations, a clear
understanding of its meaning is essential in conducting a violation
investigation. A review of case law relating to airworthiness reveals two
conditions that must be met for an aircraft to be considered "airworthy.�
These conditions a
(a) The aircraft must conform to its type design (certificate). Conformity to
type design is considered attained when the required and proper components are
installed and they are consistent with the drawings, specifications, and other
data that are part of the type certificate. Conformity would include applicable
supplemental type certificates and field approved alterations.

(b) The aircraft must be in condition for safe operation. This refers to the
condition of the aircraft with relation to wear and deterioration. Such
conditions could be skin corrosion, window delamination/crazing, fluid leaks,
tire wear, etc."

Since adding an antenna requires a 337, according to my local FSDO,
another 337 is needed to remove one?
The other thread about removing old antennas will take on a new twist.

OMG this is going to be ugly.

JohnN3TWN wrote:
The purpose of a 337 is to document a change in type design. Once modified,
the aircraft airworthiness is based on the data in the TCDS's -AND- the 337
form. Remove the alteration and the "official" airworthiness status has to be
changed via the 337.....unless, as someone mentioned, the original 337 deals
with converting for use as a camera ship (for example) then converting back as
required.

Here is the definition of airworthiness from the Inspectors handbook:
From 8300.10 chg 17 - The Inspectors Handbook

"(2) Airworthiness:
(3) Since “airworthiness� is not
defined in the FA Act of 1958, as amended, or in the regulations, a clear
understanding of its meaning is essential in conducting a violation
investigation. A review of case law relating to airworthiness reveals two
conditions that must be met for an aircraft to be considered "airworthy.�
These conditions a
(a) The aircraft must conform to its type design (certificate). Conformity to
type design is considered attained when the required and proper components are
installed and they are consistent with the drawings, specifications, and other
data that are part of the type certificate. Conformity would include applicable
supplemental type certificates and field approved alterations.

(b) The aircraft must be in condition for safe operation. This refers to the
condition of the aircraft with relation to wear and deterioration. Such
conditions could be skin corrosion, window delamination/crazing, fluid leaks,
tire wear, etc."

wrote in message ...

A more productive thread would be, in a case of conflicting FSDO opinions,
how do you obtain the "One True Answer" that will stand up to scrutiny in a
worst case situation by all that may get involved, i.e. the FAA, the NTSB,
your insurance carrier, and Fred the mechanic?

The only way to cover your butt is to get a written opinion from the
FAA General Counsel. As I recall, it's not a quick and easy process,
but it can be done.

John Galban=====N4BQ (PA28-180)