Rosen visors install - 337 required. Really?

[Oldguy]

Finally got around to thinking about pulling the old visors off of my J - nothing wrong, just too small for the easterly morning trips with the westerly returns - and wanted to put in the Rosen's, but the paperwork with them shows an STC and suggests getting my mechanic to do a 337 or contacting the local FSDO. Really?

Unfortunately, I am a rule follower, and if I have to do it, I will, but it sounds awfully onerous for an action such as this. Or am I making this out to be too simple? What have others done?

TIA.

[KSMooniac]

Yep. They opted to pursue an STC for those, so you must file a 337 when installing. Kinda silly, but it is what it is.

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[Oldguy]

3 minutes ago, KSMooniac said:

Yep. They opted to pursue an STC for those, so you must file a 337 when installing. Kinda silly, but it is what it is.

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Bummer, but thanks. 

[DonMuncy]

Although I think it is absurd, Rosen and others have gotten STCs for visors. The regulations appear quite clear to me that STCs are for major modifications. (You can look up the definition, but I can not fathom that anyone would believe it would apply to visors.)

If they are a minor modification, as I think, any A&P can install them and make a logbook entry. All you have to do is find an A&P who thinks like I do.

[KSMooniac]

Major/minor mod is murky and a friendly mechanic would indeed call visors a minor mod, but I believe if the STC exists for a product (like the Rosens) then they must be installed under the STC provisions with a 337 for records.



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[Hank]

Just now, KSMooniac said:

Major/minor mod is murky and a friendly mechanic would indeed call visors a minor mod, but I believe if the STC exists for a product (like the Rosens) then they must be installed under the STC provisions with a 337 for records.



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I don't understand how the distinction can be "murky," since Major Modification is defined in the FARs (and no, sun visors aren't major mods, STC or no). 

From what I've seen, much inappropriate-per-FAR 337 use is because A&Ps don't want to make a decision and sign their name, which is part of being an A&P. They wrongly view the 337 as removing responsibility from them. 

[DonMuncy]

20 minutes ago, KSMooniac said:

Major/minor mod is murky and a friendly mechanic would indeed call visors a minor mod, but I believe if the STC exists for a product (like the Rosens) then they must be installed under the STC provisions with a 337 for records.



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I don't know that I necessarily agree, but I don't have any authority otherwise. But before I would pay Rosen prices and comply with an STC, I would contact DonMuncy and try to con him into turning me out a set like his, install them myself and get my A&P to sign them off. (See my gallery for photos.)

[KSMooniac]

I don't understand how the distinction can be "murky," since Major Modification is defined in the FARs (and no, sun visors aren't major mods, STC or no). 
From what I've seen, much inappropriate-per-FAR 337 use is because A&Ps don't want to make a decision and sign their name, which is part of being an A&P. They wrongly view the 337 as removing responsibility from them. 

I'm in your camp on this, really, but sometimes major/minor is murky. For visors it is beyond silly that Rosen pursued an STC, and even more so, that someone in the FAA thought it was a good idea instead of just telling them it was unnecessary. Perhaps Rosen thought it would distinguish their product and make it seem more valuable and thus justify a premium price? But the fact remains that since they are STC'd, the directions must be followed and a 337 filed. Just because a mechanic deems them a minor mod does not erase the STC requirements.

If my plane didn't come with them already, I'd owner-produce my own like Don. Especially since I bought a mill and need stuff to do. Then I'd get them installed as a minor mod.

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[gsxrpilot]

Hmmmmm... got me thinking. When 6XM got sold for scrap and parted out.. I wonder how much they got for the @DonMuncy style visors I'd fabricated and installed? No STC or 337 involved. 

[Guest]

I don’t see the big deal, install them, make a log entry, file the 337 and amend the W&B.  You’re only doing it once.

Clarence

[Marauder]

I don’t see the big deal, install them, make a log entry, file the 337 and amend the W&B.  You’re only doing it once.
Clarence

$450, I ain’t doing them at all. The special ones I have are much more worthy of the CB Club.


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[bradp]

Probably because the giant price inflation for two pieces of plastic and some minimal hardware is justified by the regulatory compliance with obtaining an STC.  It’s another example of why GA isn’t doing so well...

[Guest]

I’m not referring to the price of Rosen Visors, which is high.  I’m referring to the need for filing a 337.  On my Comanche I took the original shade material off and added a new blade called “Dim It” available at Spruce.

Clarence 

[bradp]

But yes clarance I agree - after having filled only a couple of 337s out for the G5 STCs it’s a painless process. 

[steingar]

I had Rosen sun visors on two of my airplanes, and I’d have them on the Mooney if Rosen still made them for mine. They were awesome, stayed where they were put and allowed me to see. Can’t put a price on that. The STC wasn’t that big a deal, an hour of my mechanics time wasn’t what I’d call expensive. If I was that he’ll bound to install them I’m certain I could get an A&P to sign it off.

[RobertGary1]

Also means your friendly local a&p can’t sign it off. Must be an IA. 

-Robert

[N201MKTurbo]

6 hours ago, RobertGary1 said:

Also means your friendly local a&p can’t sign it off. Must be an IA. 

-Robert

Not necessarily true. Just check the other box and have your A&P sign it off. There are plenty of things an A&P can return to service.

[RobertGary1]

1 hour ago, N201MKTurbo said:

Not necessarily true. Just check the other box and have your A&P sign it off. There are plenty of things an A&P can return to service.

The a&p (non IA) sign the 337 for the stc??

The point is that making it an stc adds complexity 

 

-Robert

Edited July 7, 2018 by RobertGary1

[N201MKTurbo]

Show me the regulation that requires it.

I haven’t been able to find it.

I had this conversation with the head of the avionics shop who sold me all my avionics reciently. I asked him if he would sign off the 337 after I was done. He said I could sign the 337. He is an IA and the head of the local A&P school. I looked Long and hard and couldn’t find any regulation that said an IA as to return an aircraft to service after installing an STCed modification.

I would be very interested if you know different.

[N201MKTurbo]

2 hours ago, RobertGary1 said:

The a&p (non IA) sign the 337 for the stc??

The point is that making it an stc adds complexity 

 

-Robert

But it really doesn’t. The form is easy to fill out and doesn’t cost anything.

[bradp]

Here’s another permutation - if the A&P determines it doesn’t appreciably/ significantly change any of the items in the major mod list can he just install the STCd item and sign it off as a minor mod?  There are a lot of examples where a minor Mod would be a better fit than a 337major or follow on STC when a plane doesn’t exist on an AML.  

[N231BN]

I wish it were true but an STC is a major alteration and there is no option for an A&P to complete block 7 of the 337. I agree with the above comments that a STC should not have been granted for the visors.

On the other hand, Whelen Orion lights have a STC but it appears mechanics are installing them as a minor alteration. I would do the same for the visors. If you are going to fill out a 337 you had better find the right person to fill out block 7.

[N201MKTurbo]

18 minutes ago, N231BN said:

I wish it were true but an STC is a major alteration and there is no option for an A&P to complete block 7 of the 337. I agree with the above comments that a STC should not have been granted for the visors.

On the other hand, Whelen Orion lights have a STC but it appears mechanics are installing them as a minor alteration. I would do the same for the visors. If you are going to fill out a 337 you had better find the right person to fill out block 7.

What about the big block that says "other"?

Edited July 8, 2018 by N201MKTurbo

[N231BN]

Sorry, an A&P certificate is not "other"...

check 65.85 "(a) Except as provided in paragraph ( of this section, a certificated mechanic with an airframe rating may approve and return to service an airframe, or any related part or appliance, after he has performed, supervised, or inspected its maintenance or alteration (excluding major repairs and major alterations). In addition, he may perform the 100-hour inspection required by part 91 of this chapter on an airframe, or any related part or appliance, and approve and return it to service."

[N201MKTurbo]

27 minutes ago, N231BN said:

Sorry, an A&P certificate is not "other"...

check 65.85 "(a) Except as provided in paragraph ( of this section, a certificated mechanic with an airframe rating may approve and return to service an airframe, or any related part or appliance, after he has performed, supervised, or inspected its maintenance or alteration (excluding major repairs and major alterations). In addition, he may perform the 100-hour inspection required by part 91 of this chapter on an airframe, or any related part or appliance, and approve and return it to service."


 

Well, there it is. I will have to talk to my people about this some more.

FWIW. I found an AC that has a defined procedure for getting STC reclassified as a minor alteration. It seems like getting an IA to sign it off would be easier.