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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. Donít 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, itís 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.
    The only true wisdom is in knowing you know nothing.
    Socrates

  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. Thatís a required item for flight or the front door? Secondary structure welded to primary. Iíve discussed things like this with a couple of Feds I work with. It always starts with the answer you want to hear then the ďwell if we were looking for something to violate you overĒ it would probably be a gray area subject like this.

    (b) Major repairsó(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. Iíve 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 canít go wrong!


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

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