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Thread: SB 819 Fuselage Door Frame Corrosion

  1. #91
    Curt Ammons cammons3's Avatar
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    Default Re: SB 819 Fuselage Door Frame Corrosion

    Thanks for the inputs, folks. As mentioned, I did query our local FSDO. Once we got on the same page, here was his response:

    There is no 337 required for welding. Welding is a process of fabrication. A 337 is required for alterations and repairs to the product itself. The welding must be done iaw industry standards. Don’t get wrapped up in the reinstallation of a channel. As long as the weld does not compromise the tubing structure, and it is done correctly, you have not done a major repair to anything. I believe people are over-thinking this issue and making it way too difficult. There is no interruption needed for this specific issue, it’s very clear...
    If you do not agree with this, make a written request to the FAA. I would send it certified return receipt.

    Federal Aviation Administration
    Office of the Chief General Counsel
    800 Independence Ave, SW
    Washington DC 20591
    Curt
    N7606K/N4405H

  2. #92
    Clayton Harper's Avatar
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    Default Re: SB 819 Fuselage Door Frame Corrosion

    Curt, It appears to me that this author, like a lot of A&Ps, is unaware of the Appendix to FAR Part 43. Do your own test. Ask a few mechanic what is in the Part 43 Appendix.

  3. #93
    Rick-CAS's Avatar
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    Default Re: SB 819 Fuselage Door Frame Corrosion

    I think Clayton has this one. Appendix A discusses manufacturing, fabricating, and welding as major repairs. SB 819 is FAA approved data to remove, inspect, fabricate, and install. So a gray area as to just comply with the SB as a logbook entry. I would say put it on a 337 referring the SB and send it in just to cover yourself. I know Appendix A says primary structure but how do you defend what holds the windshield in. That’s a required item for flight or the front door? Secondary structure welded to primary. I’ve discussed things like this with a couple of Feds I work with. It always starts with the answer you want to hear then the “well if we were looking for something to violate you over” it would probably be a gray area subject like this.

    (b) Major repairs—(1) Airframe major repairs. Repairs to the following parts of an airframe and repairs of the following types, involving the strengthening, reinforcing, splicing, and manufacturing of primary structural members or their replacement, when replacement is by fabrication such as riveting or welding, are airframe major repairs.

  4. #94

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    Default Re: SB 819 Fuselage Door Frame Corrosion

    I would like to discourage sending in 337's "just to be safe". I think the industry does itself a dis-service doing that and it is actually contrary to FAA policy. FAA says you should not submit a 337 for a minor. Back in the day A&P's installed radios all the time with just a logbook entry. Then somehow we started sending in 337's on them in the late 80's early 90's, then it became expected to submit even though the regs never changed. (When did Principal Avionics Inspectors become an FAA position?) Now the industry is trying to take back the authority to install radios without 337's. My method is to document my decision to declare the minor and put it in the logbook. If the FAA inspector disagrees at a later date, then we have a disagreement and find a resolution. No fraud or coverup needed. Another thing I hear from fellow IA's is "Well Ok City didn't kick back my 337, so it must be approved". Ok City only has Inspectors look at (very) random 337's to check content. Almost all 337's are only looked at by document specialists to scan into the files. They look to see if the Owner/N-number/serial is consistent with their records, but do not examine the content of the 337. It would only be looked at by an FAA Inspector if at a later date there was a problem and they went back and examined the form. The IA is the approver! My $.02

  5. #95

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    Default SB 819 Fuselage Door Frame Corrosion

    Quote Originally Posted by blueshortwing View Post
    I would like to discourage sending in 337's "just to be safe". I think the industry does itself a dis-service doing that and it is actually contrary to FAA policy. FAA says you should not submit a 337 for a minor. Back in the day A&P's installed radios all the time with just a logbook entry. Then somehow we started sending in 337's on them in the late 80's early 90's, then it became expected to submit even though the regs never changed. (When did Principal Avionics Inspectors become an FAA position?) Now the industry is trying to take back the authority to install radios without 337's. My method is to document my decision to declare the minor and put it in the logbook. If the FAA inspector disagrees at a later date, then we have a disagreement and find a resolution. No fraud or coverup needed. Another thing I hear from fellow IA's is "Well Ok City didn't kick back my 337, so it must be approved". Ok City only has Inspectors look at (very) random 337's to check content. Almost all 337's are only looked at by document specialists to scan into the files. They look to see if the Owner/N-number/serial is consistent with their records, but do not examine the content of the 337. It would only be looked at by an FAA Inspector if at a later date there was a problem and they went back and examined the form. The IA is the approver! My $.02
    Actually fileing a 337 for a minor repair or minor alteration is a violation of 43.9. I’ve never seen a letter of investigation or violation for it, but it is still a violation. Just as blueshortwing says, document your decision process for it being a minor in the log book entry using the decision tree FAA gives. You can’t go wrong!


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    Last edited by dgapilot; 04-13-2018 at 07:49 AM.

  6. #96
    dhillier's Avatar
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    Default PA16 SB819 Help

    Help!

    Recently I started the rebuild on N5240H. I cut the sheet metal off for SB819 to reveal a fair few bits of corrosion. The tubes have all been blasted, primed and are ready for repairing. When in the USA last month I collected the SB819 kit for a PA16 from Univair.

    Using drawing 11858, Pipers SB819 instructions and various photos as reference, I am still very much stuck.

    I can’t figure out how many of the parts fit onto the fuselage. They appear very oversized in both length and width. Problems include

    How do the 3 parts that make up the right hand entry door rear frame fit together?
    How do the 4 parts that make up the front of the left hand rear passenger door fit together?
    Where do parts:
    16-22
    16-23
    16-20
    16-21B
    22-07B
    16-21T
    fit on the frame?

    Does anyone have any photos or advice that may be useful please?

    Regards

    Dean

  7. #97
    Administrator Steve Pierce's Avatar
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    Default Re: PA16 SB819 Help

    They sell the channels for the PA20 and 22. When I have done the SB on PA16 fuselages I have had to trim those down. I have a shear and brake and ended up making my own, less time than cutting Univair's down. The bottom of the door also tapers on the later models and doesn't on the 15, 16 and 17.

    Merged your thread with an older one on the subject. I have some drawings and I believe some pictures I will post.

  8. #98
    dhillier's Avatar
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    Default Re: PA16 SB819 Help

    Thanks - if you have some pictures that would be great.

    for example on the rear door. Which way do the curved portions face and how do the 3 pieces join together?
    E30A4E1C-32E0-4188-A589-902D7DB89DBD.jpeg475A7EE0-4D29-4701-81A8-7BF7ACBA780E.jpeg

  9. #99
    Administrator Steve Pierce's Avatar
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    Default Re: SB 819 Fuselage Door Frame Corrosion

    Univair has a drawing or brochure showing all the part numbers laid out like the go on the fuselage. I don't have any pictures and I haven't found the brochure yet but I do remember having to cut those channels down a lot so the next one I made my own.

  10. #100

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    Default Re: PA16 SB819 Help

    Quote Originally Posted by dhillier View Post
    Thanks - if you have some pictures that would be great.

    for example on the rear door. Which way do the curved portions face and how do the 3 pieces join together?
    E30A4E1C-32E0-4188-A589-902D7DB89DBD.jpeg475A7EE0-4D29-4701-81A8-7BF7ACBA780E.jpeg
    Dean, hope you are hanging that tube, looks like an awful lot of pitting!


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