FAA Form 337 Question

[NotarPilot]

I'll bet I'll stir up a hornet's nest with this but here goes...

 

I had a meeting today with a couple FAA Maintenance Inspectors, at my hangar, so they could inspect my Mooney before installing some LED exterior lighting (Nav, strobes, pos, beacon).  I had completed and submitted three 337 forms for the work about two weeks ago.  They said my 337s looked good and I just needed to have the IA sign the forms so they could approve it and I could start the work with replacing the lights.  They specifically recommended NOT to do the installation until the work is approved otherwise my plane would be grounded until the work is approved.

 

After the meeting I went over to my IA's hangar who says he will only sign it AFTER the work is completed and once he signs it I am legal to go fly.  He said the FAA does not need to approve the 337 form.  I did a search online and I believe he's correct.  Nothing says the FAA has to approve the work.  You just have to submit the 337 form to the FAA to let them know what you did.  No where on the form is there a "Approval" box for the FAA to check, just the IA.  I think it all rides on the IA's shoulders once it's approved.  Is this accurate?

[N601RX]

If its a field approval on a 337 the FAA has to approve it.   If its a STC or other manufacture approved mod on a 337 then the FAA does not have to approve it because they have already approved it.  The key is that you have to have approved data if your IA considers it a major change.

[NotarPilot]

What if there's no STC but only a TSO?

[JaredDavis]

I don't have an answer.

 

The Orion 600 instruction sheet has this step:

 

11. Update aircraft records, complete Form 337 and obtain FAA field
approval for installation, as required.

 

Love the "as required" dump back on the installer.

 

What beacon part did you use?

[danb35]

N601RX has it right--if it's a major alteration or a major repair (the only reason you'd fill out a 337 in the first place), you must have "approved data" to support it.  If you don't have an STC or other source of approved data, you'll need a field approval, which is the only time it needs to go to the FSDO for approval (that's what makes it "approved data").

 

ETA: The determination of whether the installation qualifies as a major or minor alteration is largely at the discretion of your installing A&P/IA (IA is not needed for a minor alteration).  It's my personal opinion that a lot of unnecessary 337s are completed for things that just aren't major alterations.

[NotarPilot]

Thanks for the info.  That makes sense.  I'm installing the 7108055 Beacon.

[N601RX]

Many mechanics don't consider replacing one TSO part with another part with the same TSO to be a major change

[1964-M20E]

MY $0.02 repalcing the lights it is not a major change but that is me.

[takair]

IF it is a field approval, then the FAA would approve the data listed on the back via block 3. IF you have approved data, you would list it on the back and the IA can send it in to Oklahoma City with his signature without block 3. Regarding the IA signature, he should NOT sign it until the work is complete and he is satisfied that it matches the approved data. As others said, this may not even be a major alteration, but that is often left tot he judgement of the individual mechanic.

[Marauder]

MY $0.02 repalcing the lights it is not a major change but that is me.

Sorry if I laugh John... On PoA there is a 14+ page thread on the legality of changing a light bulb. I thought I had seen it all until that thread.

[1964-M20E]

Sorry if I laugh John... On PoA there is a 14+ page thread on the legality of changing a light bulb. I thought I had seen it all until that thread.

 

All is good this is just my opinion for what it is worth.

 

The regulations allow the owner to change the light lens and reflector for the recognition lights and the wing tip lights and change wiring for the landing light.  Well the new LED lights are the light lens and reflector all in one.   No mechanic, no IA, no 337 and no FAA just your signature in the log book saying you replaced the light lens and reflector.  

 

I’m sure others will disagree with me. 

 

Secondly I could be mistaken but only the recognition light is required during daylight other lights are only required for night time operations and I rarely fly at night.

Third how many times have you seen the flashing beacon or rotating beacon on a plane in VMC before you have seen the plane itself?  I do fly with all my lights on whenever I fly.  Other than the landing light I have never noticed the light before the plane at least during the daytime.

[Cruiser]

John,

I think the regulations deal with replacing the old parts with the same part number new parts.

When you take out the old part and put in the same exact part it is a replacement.

When you take out the old part and put in something different it is a modification.