Oldguy Posted July 6, 2018 Report Share Posted July 6, 2018 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 returnsĀ - 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. Quote Link to comment Share on other sites More sharing options...
KSMooniac Posted July 6, 2018 Report Share Posted July 6, 2018 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.Sent from my LG-US996 using Tapatalk 1 Quote Link to comment Share on other sites More sharing options...
Oldguy Posted July 6, 2018 Author Report Share Posted July 6, 2018 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. Sent from my LG-US996 using Tapatalk Bummer, but thanks.Ā Quote Link to comment Share on other sites More sharing options...
DonMuncy Posted July 6, 2018 Report Share Posted July 6, 2018 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. 2 Quote Link to comment Share on other sites More sharing options...
KSMooniac Posted July 6, 2018 Report Share Posted July 6, 2018 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. Sent from my LG-US996 using Tapatalk Quote Link to comment Share on other sites More sharing options...
Hank Posted July 6, 2018 Report Share Posted July 6, 2018 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. Sent from my LG-US996 using Tapatalk Ā 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).Ā From what I've seen, much inappropriate-per-FARĀ 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.Ā 1 Quote Link to comment Share on other sites More sharing options...
DonMuncy Posted July 6, 2018 Report Share Posted July 6, 2018 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. Sent from my LG-US996 using Tapatalk Ā 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.) 3 Quote Link to comment Share on other sites More sharing options...
KSMooniac Posted July 6, 2018 Report Share Posted July 6, 2018 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).Ā From what I've seen, much inappropriate-per-FARĀ 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.Ā 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.Sent from my LG-US996 using Tapatalk Quote Link to comment Share on other sites More sharing options...
gsxrpilot Posted July 7, 2018 Report Share Posted July 7, 2018 Hmmmmm... got me thinking. When 6XM got sold for scrap and parted out.. I wonder how much they got for the @DonMuncyĀ style visors I'd fabricatedĀ and installed? No STC or 337 involved.Ā Quote Link to comment Share on other sites More sharing options...
Guest Posted July 7, 2018 Report Share Posted July 7, 2018 I donāt see the big deal, install them, make a log entry, file the 337 and amend the W&B. Ā Youāre only doing it once. Clarence Quote Link to comment Share on other sites More sharing options...
Marauder Posted July 7, 2018 Report Share Posted July 7, 2018 I donāt see the big deal, install them, make a log entry, file the 337 and amend the W&B. Ā Youāre only doing it once. Clarence $450, I aināt doing them at all. The special ones I have are much more worthy of the CB Club. Sent from my iPad using Tapatalk Pro Quote Link to comment Share on other sites More sharing options...
bradp Posted July 7, 2018 Report Share Posted July 7, 2018 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. Ā Itās another example of why GA isnāt doing so well... 2 Quote Link to comment Share on other sites More sharing options...
Guest Posted July 7, 2018 Report Share Posted July 7, 2018 Iām not referring to the price of Rosen Visors,Ā which is high.Ā Iām referring to the need for filing a 337. Ā On my Comanche I took the original shade material off and added a new blade called āDim Itā available at Spruce. ClarenceĀ Quote Link to comment Share on other sites More sharing options...
bradp Posted July 7, 2018 Report Share Posted July 7, 2018 But yes clarance I agree - after having filled only a couple of 337s out for the G5 STCsĀ itās a painless process.Ā 1 Quote Link to comment Share on other sites More sharing options...
steingar Posted July 7, 2018 Report Share Posted July 7, 2018 I had Rosen sun visors on two of my airplanes, and Iād 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. Canāt put a price on that. The STC wasnāt that big a deal, an hour of my mechanics time wasnāt what Iād call expensive. If I was that heāll bound to install them Iām certain I could get an A&P to sign it off. Quote Link to comment Share on other sites More sharing options...
RobertGary1 Posted July 7, 2018 Report Share Posted July 7, 2018 Also means your friendly local a&p canāt sign it off. Must be an IA.Ā -Robert Quote Link to comment Share on other sites More sharing options...
N201MKTurbo Posted July 7, 2018 Report Share Posted July 7, 2018 6 hours ago, RobertGary1 said: Also means your friendly local a&p canāt sign it off. Must be an IA.Ā -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. Quote Link to comment Share on other sites More sharing options...
RobertGary1 Posted July 7, 2018 Report Share Posted July 7, 2018 (edited) 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 (nonĀ IA) sign theĀ 337 for theĀ stc?? The point is that making it an stc adds complexityĀ Ā -Robert Edited July 7, 2018 by RobertGary1 Quote Link to comment Share on other sites More sharing options...
N201MKTurbo Posted July 8, 2018 Report Share Posted July 8, 2018 Show me the regulation that requires it. I havenāt 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 couldĀ sign the 337. He is an IA and the head of the localĀ A&P school. I looked Long and hard and couldnāt 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. Quote Link to comment Share on other sites More sharing options...
N201MKTurbo Posted July 8, 2018 Report Share Posted July 8, 2018 2 hours ago, RobertGary1 said: The a&p (nonĀ IA) sign theĀ 337 for theĀ stc?? The point is that making it an stc adds complexityĀ Ā -Robert But it really doesnāt. The form is easy to fill out and doesnāt cost anything. Quote Link to comment Share on other sites More sharing options...
bradp Posted July 8, 2018 Report Share Posted July 8, 2018 Hereās another permutation - if the A&P determines it doesnāt 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? Ā 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 doesnāt exist on an AML. Ā Quote Link to comment Share on other sites More sharing options...
N231BN Posted July 8, 2018 Report Share Posted July 8, 2018 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. Quote Link to comment Share on other sites More sharing options...
N201MKTurbo Posted July 8, 2018 Report Share Posted July 8, 2018 (edited) 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 Quote Link to comment Share on other sites More sharing options...
N231BN Posted July 8, 2018 Report Share Posted July 8, 2018 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." Quote Link to comment Share on other sites More sharing options...
N201MKTurbo Posted July 8, 2018 Report Share Posted July 8, 2018 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." Ā 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. Quote Link to comment Share on other sites More sharing options...
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