FAA Requires 337 for Modification Removal

[belandd]

I just attended an annual training session that included a brief from our local FAA maintenance inspector. he strongly advices that you have a 337 in your record to cover removing any modification.
He was particularly interested in skiis.
You need a 337 to alter the aircraft TC when you install the skiis and you need a 337 to return the aircraft to its original TC status when you remove the skiis.

Of course I don't like it but it does make sense.

[a64pilot]

For many years, it has been my impression that anything that requires a 337 to install, takes a 337 to remove. For instance if your installing a new radio, make the removal entry of the old radio on the 337 that installs the new one.
If you don't then over the years, it appears that your flying around with several radios.

[Hottshot]

Isn't this normally covered in the install of said parts ie; Installed PN# xxx-xxx and removes PN# xxx-xxz

[aero101]

That's my take on it WUP, you remove a comm radio and install a new one. Obviously skis are for snow conditions only, most are installed on an STC, as are Floats, etc, etc, etc.... A logbook entry all that's required per my PMI on these items... Lot's of ski's are also installed per TCDS, or 337's which is simply a modification to the TCDS.

[a64pilot]

That's my take on it WUP, you remove a comm radio and install a new one. Obviously skis are for snow conditions only, most are installed on an STC, as are Floats, etc, etc, etc.... A logbook entry all that's required per my PMI on these items... Lot's of ski's are also installed per TCDS, or 337's which is simply a modification to the TCDS.

Yes, but the argument is that when you remove the skis that were installed with a 337, a removal 337 should be filled out and filed.

You guy's know what a spreader for an AG airplane is? Big funnel looking thing that attaches to the hopper, used for dry application like fertilizer. FAA says it takes a 337 because it is a major modification, it is too, big thing weighs like 100 lbs or so. Problem is I do dry work with my spreader today and wet work tomorrow with my pump and booms etc, and back to dry the day after. So, I'm supposed to fill out and file 50 or 60 337's every season?

[LT4247]

Constant and unrelenting regulation with no common sense mixed in. And folks wonder why less and less people want to fly or own airplanes...

[UP-M5]

no way.

installing an item - like skis - that are not on the TCDS requires a form 337, obviously. whether the item is installed by field approval or STC doesn't matter. the fact that you have have one or the other on your 337 constitutes an approved change to your type design.
basically i have added these skis to the TCDS of this one particular aircraft (so to speak). now a log book entry is required when i install them - the 337 didnt say i installed them, it just provided the APPROVED DATA that said i could install them. if i remove them - log book entry.

we do this every day with wheels to floats to bushwheels to skis and back, cargo pods on and off, and any combination of the bunch. and on part 135 aircraft that are under much scrutiny.

your particular fed was just wrong.
we cant be filling out and submitting 337's every time we make a configuration change.
and what about field approvals. they take time and effort to get - now i have to get these re-field approved every year after i have removed them

[aero101]

UP-M5 couldn't have said it much better.... Field approval is one time type design change and whatever is on the field approval is now considered a type design change to that particular aircraft. You can now go back and forth between type design changes with logbook ONLY - entry so long as you're sticking to an approved type design, IE - FLOATPLANE, LANDPLANE, or SKI PLANE.... I am also a 135 operator, and under constant oversight, logbook entry and return aircraft to service is all that's required.... I know other operators that use lumber racks, external fuel can racks, etc, etc, etc, and that's all that's required of them as well. Not sure about the AG equipment mentioned and the reason why, but kind of suspect the local fed up here was either misunderstood, or was one of the newer inspectors who has come up with a NEW interpretation of FAR's? I will certainly check with my PMI tomorrow for his take. Maybe Oklahoma City is looking for justification for jobs now that the biggest part of the country no longer will do a field approvals?

[YELLOWMAULE]

Constant and unrelenting regulation with no common sense mixed in. And folks wonder why less and less people want to fly or own airplanes...

You bring up a good point. Specifically, look at the Golden Age of Aviation. Look at all of the inovation and progress we made during that one period of what 2, 3 decades? What brought it to a halt? Regulation.
These guys were stuffing huge engines in little planes and tearing up the skies! (GeeBee Racer) There were new engines seemingly every month, new airframes! Yeah, we lost a few people but sometimes that's the price to be paid. They knew it, most of 'em did anyway. We owe a lot to that era, Hell, many of the components we flew with now are directly related and little changed from that era. Look at the cost to the people who want to make a new (better) part? Thanks to folks like Bill & Wup, it can happen but I can only imagine the hoops they have to jump.

(Soap Box) Bring back Personal Responsibilty!

[Kirk]

Your Fed is kind of right, but UP M5 is more right I think. Each 337 issue is going to be different.

If a 337 based mod included structural changes etc. Documentation would have to show how the structure was modified to restore it to Type Certificate spec.

But removing a NAVCOM or skis etc is not further modifying the aircraft and would not require one. (As I read the FARs at least).

A good read of the definition of "major modification" shows that the A&P doing the work makes the determination of whether it is major or minor. Now he will certainly be second guessed by FAA, but really reading the "major" definition leads me to believe a lot of mods are done under 337 un-necessarily, just to cover a shops butt. Can't blame them, I'd worry too.

Kirk

[a64pilot]

The argument against log book entries is the aircraft's record in Oak city does not reflect the current configuration of the aircraft. You have a 337 that say's you put a color TV in it, and a log book entry that say's TV removed. The Feds want their record corrected if the TV is removed.
A lot of the problem is that the older ones are retiring, and taking common sense with them. Most of the newer ones seem to have come from the 121 side of the FAA, and are now trying to regulate 91 like 121. Or at least it seems that way.
Don't shoot the messenger, this is another example of over thinking / over regulation. There are many, many FAR's that you can't meet the letter of the law, they were written as to try to remove all of the "wiggle room", but because they are written they way they are, they cannot be implemented in all cases.
Sometimes you just have to say, yes sir, three bags full, they go away and you do the best you can.

[aero101]

I just got off the phone with one of our local FAA inspectors and he says this issue has come up before and it's nothing to worry about, BUT if you want to meet the letter of the law on an item that will be going on / off such as skis, that you specify in the 337 that this is a seasonal installation, give instructions on both the installation (which we normally do on field approval) and then give instructions on the removal (which we normally don't do) and specify that the removal and installation of this item requires a logbook entry only (as is done on some STC's). He was also agreeable if my concern was great enough, to signing off on field approval revisions covering this. I was also told that IF I were ever to get a young inspector that wanted to argue the point, that I should request a hearing as the current way we handle this is the way we've been doing it for 30 plus years, many inspectors have reveiwed my books, so what's changed? Hope this helps to clarify?

[a64pilot]

Your right, if you get it on the 337 that the TV can come and go with just a log book entry, then in my opinion, that's the way it is. Good point, haven't tried that, maybe it will work.
I use TV because skis are logical, make sense as a temporary installation, it's other things like camera mounts, external tracking antennas, etc. etc. that seem to be problematic.

[belandd]

I like the idea of putting both the installation and the removal on one 337. If not that then fill out a 337 for installation (on seasonal item) and one for removal.
You should be able to insert the current one into your records and not have to make out a new one every time.

Like every one else, I have been operating with log book entry for years.

[Andy Young]

Reviving an old thread here. Recently installed Bushwheels and was doing a little digging to figure out what the current interpretation/industry standard is for paperwork on these things. I haven't had a chance to talk to someone at the Anchorage FSDO (left a message) but I spoke to the Airworthiness Inspector at the Denver FSDO, since the plane is based there half the year.

Here's what he said:
Since the tire installation is covered by an STC, all that is LEGALLY required is a logbook entry that references the STC; no 337 is required. He did say that a 337 is highly recommended, so that if the question of legal installation ever comes up (during a ramp check, after an accident, if aircraft records are lost or destoyed, etc.) the FAA has a record of the install/configuration of the aircraft. In the case of seasonal equipment (such as Bushwheels, floats, skis) he said they do recommend (as mentioned in earlier posts) making a statement at the bottom of the 337 something to the effect of "This is a seasonal installation. It is anticipated that this aircraft will be swapped between bushwheels and stock-sized tires seasonally or as required for operating conditions."

I have to say, given this interpretation, I'm tempted to just not bother with the 337. I don't really care all that much that the FAA is up to speed on my current configuration, as long as they can't bust me for it. I'll be interested to hear what the local (Anchorage) FSDO has to say on the matter.