Is 337 form required?
Frank Beale
If an airplane is purchased with no radios installed, is it still considered
to be a major modification and require a 337 form for each radio installed,
if the radios and equipment are installed in the rack designed to hold them
from the factory?
For example, a Cessna 150 purchased with all radios removed and no
transponder, just empty rack without trays and wanting to install nav/gps,
intercom, transponder with encoder. Does a 337 and field approval need to be
done for any or all or is a log book endorsement all that is needed?
I have heard that the rules for this have change in the last year and
wondered if anyone else had heard the same. It was suggested I post the
question in this group as there are a lot of knowledgeable people here.
Thanks,
Frank
Ron Natalie
"Frank Beale" <fr...@bealenet.com> wrote in message news:1FMo9.6579$G5.5114@fe01...
> For example, a Cessna 150 purchased with all radios removed and no
> transponder, just empty rack without trays and wanting to install nav/gps,
> intercom, transponder with encoder. Does a 337 and field approval need to be
> done for any or all or is a log book endorsement all that is needed?
My opinion is that if you don't have to make structural changes to the panel
then it's not a major modification and neither a 337 nor field approval is required
Did the owner file a 337 and get a field approval when he yanked all the radios
out?
> I have heard that the rules for this have change in the last year
Not to my knowledge. This rule has NEVER changed. Various field offices
interpetations change with the wind however.
Frank Beale
realizing that it should have been done. My IA says that he submitted the
337s on the new radios and received a letter back stating that no 337s were
needed as long as they were installed in the rack designed for the radios. I
wonder if he is confused with radios that are installed in existing trays. I
have not seen the letter, he seemed somewhat surprised as well so that is
why I was wondering if this was something new. He updated the W/B when he
made the log book entries.
I guess I should call the local FSDO and ask, but I really do not want to
stir up a lot of mess if I don't need to.
Frank
"Ron Natalie" <r...@sensor.com> wrote in message
news:LkZo9.18720$J4.1392@fe03...
Mike Ferrer
transponder and an IFR certified GPS in a Dakota. Block 8 on my 337 is three
pages long and took two trips to the FSDO to get it written the way they
wanted (each FSDO has their own preference for wording). The 337 was
absolutely, positively required (in their eyes) and the FSDO inspector is
coming out tomorrow to field inspect.
Generally speaking, you need a 337 for any major alteration and "new" radio
installations fall into that class. If you are sliding in a replacement
radio into an existing tray (e.g., MX170B to replace a KX170B), only a
logbook entry is required. No 337 is required for removal of radios but it
does require a logbook entry and updates to the equipment list and W&B by an
A&P.
As always, there are some exceptions to these rules. One that comes to mind
is reinstalling radios that were previously installed and approved with a
337 but later removed. Another loophole (sometimes) is installing radios
listed by the airplane manufacturer as standard or optional equipment for
that model aircraft.
Mike
an A&P
"Frank Beale" <fr...@bealenet.com> wrote in message
news:ry4p9.7032$G5.1335@fe01...
Jim Weir
Jim
An A&P IA
->Generally speaking, you need a 337 for any major alteration and "new" radio
->installations fall into that class.
->Mike
->an A&P
Jim Weir (A&P/IA, CFI, & other good alphabet soup)
VP Eng RST Pres. Cyberchapter EAA Tech. Counselor
http://www.rst-engr.com j...@rst-engr.com
Apis Gliders
<mvfe...@starband.net> writes:
>Generally speaking, you need a 337 for any major alteration and "new" radio
>installations fall into that class.
Where does it say that?
Generally speaking does not mean much. Where are the criteria in print.
I side with Jim Weir. Too many inspectors ask for them when they are not
required.
Robert Mudd
A&P I/A
John Kunkel
"Mike Ferrer" <mvfe...@starband.net> wrote in message
news:LT5p9.2123$rM7.67...@twister2.starband.net...
> >
> Generally speaking, you need a 337 for any major alteration and "new"
radio
> installations fall into that class.
Some years back someone posted a copy of a letter sent to Repair Stations
and IA's from the Milwaukee FSDO addressing the flood of 337's that they
were receiving for radio installations.
The letter clearly stated that basic radio installations are not considered
major alterations and need only a logbook entry. It was signed by the
supervisor of the Airworthiness Management Unit.
Of course, your FSDO may vary.
John
Jim Weir
logbook at the show (which is in the Milwaukee FSDO district), and fly home.
Simple, eh?
{;-)
Jim
"John Kunkel" <kunk...@shorts.attbi.com>
shared these priceless pearls of wisdom:
->Some years back someone posted a copy of a letter sent to Repair Stations
->and IA's from the Milwaukee FSDO addressing the flood of 337's that they
->were receiving for radio installations.
->The letter clearly stated that basic radio installations are not considered
->major alterations and need only a logbook entry. It was signed by the
->supervisor of the Airworthiness Management Unit.
David Pincus
Here's the post from 1995:
From: Rod Farlee (r...@sadtler.com)
Subject: FAA Form 337, Major vs Minor Alterations
Newsgroups: rec.aviation.homebuilt
Date: 1995/08/21
U.S. Department of Transportation
Federal Aviation Administration
Flight Standards District Office
4915 South Howell Avenue
Milwaukee, WI 53207
DATE: June 5, 1995
SUBJECT: Major Alterations
TO: Certified Repair Stations and Inspection
Authorization (IA's)
This office is frequently confronted with questions regarding
what constitutes a major alteration, especially when
installation or removal of avionics and other similar
equipment is involved. The following information is provided
to help mechanics and repair stations understand this
sometimes complicated matter. The regulatory definitions of
major alterations are found in Federal Aviation Regulations
(FAR) 1 and 43, Appendix A (a). These regulations are often
interpreted too conservatively resulting in minor alterations
being treated as major alterations.
Simple alterations that do not affect the structural
integrity of the aircraft, alterations that are made by the
same method as the aircraft manufacturer has used or
installation of equipment listed by the aircraft manufacturer
as "Optional Equipment" may be considered minor alterations.
A simple equipment installation that is made in an aircraft
with units mounted on factory provided racks may be
considered as minor alterations. The certificated person
installing the equipment is responsible to use the
information provided by the equipment manufacturer, and that
information in Advisory Circular (AC) 43.13-1 and 43.13-2
regarding wire size, circuit protection, wire support,
antenna installation, etc. They are also responsible to
record the alteration in the aircraft records in accordance
with FAR 43.9 (logbook entry) and update the weight and
balance and equipment list.
We do not wish to imply that field approvals of equipment
installation is never required. Examples of installations
that would require field approval are:
* Alterations that involve the construction of a radio rack
or shelf.
* An installation made in an instrument panel that is a
structural part of the aircraft and requiring an opening
to be cut in areas other than that specified by the
aircraft manufacturer.
* Special FAA policy sometimes requires field approval on
installation of new types of equipment such as the current
requirement for GPS.
If you have any questions regarding this memo, or are in
doubt as to whether a 337 is required, please do no
hesitate to contact this office.
Sincerely,
Thomas L. Lind
Supervisor, Airworthiness
Certificate Management Unit
Mike Ferrer
> Generally speaking does not mean much. Where are the criteria in print.
> I side with Jim Weir. Too many inspectors ask for them when they are not
> required.
>
> Robert Mudd
> A&P I/A
Garmin, for one, says it in paragraph 1.1 of their Installation Manuals for
the GMA-340 audio panel and the GTX-327 transponder. I quote the 340
manual,
"This manual provides the installation and operating instructions for the
GARMIN GMA 340, GMA 340H and GMA 340 Dual ADF Audio Panel. Reference to GMA
340 throughout this manual refers to all versions of the unit. Information
pertaining to the maintenance of the unit can be found in the GMA 340
Maintenance Manual, P/N 190-00149-02. After installation of the GMA 340, FAA
Form 337 must be completed by an appropriately certificated agency to return
the aircraft to service."
Mike
Mike Ferrer
Without a doubt, some FSDOs are more relaxed than others. That is why I
said, "Generally speaking..." If your FSDO doesn't require 337s, you're a
lucky dog....
"Jim Weir" <j...@rst-engr.com> wrote in message
news:5v7aqu0gkemn84acn...@4ax.com...
Jim Weir
Garmin can say anything they damned well please. They are not the one making
the rules or making the determination.
Jim
"Mike Ferrer" <mvfe...@starband.net>
shared these priceless pearls of wisdom:
->> Where does it say that?
->> Generally speaking does not mean much. Where are the criteria in print.
->> I side with Jim Weir. Too many inspectors ask for them when they are not
->> required.
->>
->> Robert Mudd
->> A&P I/A
->
->Garmin, for one, says it in paragraph 1.1 of their Installation Manuals for
->the GMA-340 audio panel and the GTX-327 transponder. I quote the 340
->manual
Russell Kent
> So fly your A&P to Oshkosh next year, have him/her sign off your radio in your
> logbook at the show (which is in the Milwaukee FSDO district), and fly home.
> Simple, eh?
>
> {;-)
Hey wait a minute! How am I supposed to fly the plane when the paperwork isn't
done for the radio(s)? That means I either need a ferry permit (to fly with the
radios installed without the paperwork) or have the radios *installed* while on
the group in the Milwaukee FSDO and then the logbook entry made.
And the last time I checked, I thought Jim Weir had the necessary alphabet soup
after his name to make the logbook entries. Maybe we can just arrange for Jim to
"oversee" the installation at Oshkosh and sign off there so we can avoid hauling
our A&P all the way to Oshkosh. He works on your plane; you think he's nuts
enough to ride in it??! <vbg>
Russell Kent
Joe Norris
Omar Filipovic wrote:
>
> Does any of this actually apply to experimentals, especially those where the
> original builder is making the modifications?
An FAA Form 337 is not used for repairs or alterations on an
experimental airplane, regardless of whether it's the original builder
or another person doing the work. The procedure for approving a major
change to an experimental aircraft is covered in that particular
aircraft's operating limitations document. These "OpLims" are a part of
the airworthiness certificate, and as such must be carried in the
aircraft at all times.
If you are making a change to your experimental aircraft, familiarize
yourself with the requirements for approving a major change as outlined
in the OpLims.
Joe Norris
