FAA STC applicability in TCCAs eyes

[Howitzer]

I'm looking at importing an aircraft from the US. From what i've gathered in SI No. 513-003 it would qualify under a Level I review. Am i reading it correctly in that TCCA would allow the FAA STC be applied as there is a formal understanding of FAA certification? Basically, will they say "oh, this is FAA approved, here's a letter of acceptance"?

One more question regarding the 337 Form. I understand that this is what is used for a Field Approval from the local FSDO, and that TCCA does not recognize this kind of approval. How do you get around something like that? Do you apply for an STC that is serial number based or is it up to the discretion of the DAR?

Forgive me if i've mis-interpreted something, after all, i'm only a pilot!

Thanks for the help.

[CID]

If it's a small airplane in the normal, utility or aerobatic category AND its state of design is the USA, FAA STCs are automatically accepted without review. That applies even after import.

If an airplane is being imported from the USA, regardless if state of design or category, all field approvals and what are known as 8110-10 approvals are accepted without review. Not the case once imported.

[sportingrifle]

CID.....I could be wrong here but our local TC types are only accepting 337's if Box 3 is signed by an FAA employee.(FAA FSDO ASI) If only signed by an IA, they are not accepting them. Is this your understanding?

I was also under the impression that TC could at their discretion (codespeak for "we don't like what you are trying to do) "familiarise" themselves with an STC which seems to be bureaucraticeese for starting at square 1 and doing almost everything to re-invent the wheel.

I am right in the middle of obtaining an STC and would love to hear your thoughts on this. There seems to be a considerable regional interpretation of the rules that themselves have much grey areas written into them. If we truly are one big happy ICAO happy family, I would love to see all 337's and STC's accepted with out question but despite Toronto having frozen over, hell probably won't!
Cheers Sportingrifle

[Heliian]

If we truly are one big happy ICAO happy family,

haha, that would require the u.s. coming in line with the rest of the world. never gonna happen.

The problem with 337's is that some are done for repairs which would otherwise be not approved and the only way to get around it is to remove it from the a/c and make the repair/installation conform to the regs.

My advice to you is to get in touch with an AME here in canada with type experience.

[CID]

Any paperwork you present for consideration must be executed properly. That goes for STCs, field approvals and 8110-3 approvals. Something that confuses the process is making reference to the 337 form without qualifying it.

The FAA 337 form is used to record major repairs and alterations. There are various FAA policies that allow use of the form for a few purposes other than originally intended for. One is the "Field Approval". The Field Approval is not defined by any FAR. It is a method intended to approve major alterations using other than the STC process which IS defined by FARs. Field Approvals are not intended to be used on more than one serial number.

Field Approvals must be documented on the 337 form and Block 3 MUST be signed by the responsible FSDO. If there is no signature, it's not a Field Approval.

But that doesn't mean it can't be accepted. If there is an accompanying 8110-3 form, which is used by a DER to make statements of compliance, then you have an 8110-3 approval which is not a "Field Approval". It is also a policy driven method to avoid an STC but like field approvals, they are not intended to be applied to more than one serial number. The difference is that 8110-3 approvals are used when the modification requires compliance findings that are not covered under the various accepted standard practices and advisory circulars. For example, if you make a hole in a pressurized airplane, a Field Approval is not an option since you will need a DER to sign an 8110-3 against the FAR standards related to structural strength of pressure vessels.

The policy actually prohibits FSDOs from signing Block 3 of a 337 form if an 8110-3 form is referenced.

With respect to "repairs" (and you may want to look at the definition in the 100 series of CARS) they are mutually accepted without review between the FAA and TCCA. Of course, as long as the paperwork is properly executed.

Keep in mind that all the above is still in the context of an import. Outside of an import, Field Approvals and 8100-3 approvals are not permitted, nor are FAA repair stations permitted to issue them on non US registered aircraft.

[sportingrifle]

Hi CID......

Thanks for the reply, this makes sense now.

BTW, You could set yourself up a nice consulting business explainging this stuff to the rest of us and helping us navigate around it!

[Colonel Sanders]

Field Approvals are not intended to be used on more than one serial number

Reality Gap Time: they sure are

I know of many different Field Approvals that have been
installed on hundreds of different aircraft (same type).

The inevitable Harrumphing aside (wait for it), obviously
the modifications are safe, otherwise aluminum would be
raining from the sky.

[SeptRepair]

Reality Gap Time: they sure are

I know of many different Field Approvals that have been
installed on hundreds of different aircraft (same type).

The inevitable Harrumphing aside (wait for it), obviously
the modifications are safe, otherwise aluminum would be
raining from the sky.

CID is correct. The INTENT is to be used on one serial number. That's why it is refereed to as a "one of approval". Once the approval has been granted it can and has been used as acceptable data for use on other aircraft of similar type. http://www.faa.gov/aircraft/air_cert/de ... prov_proc/

[Colonel Sanders]

You guys talk like politicians.

[CID]

The FAA has been clamping down lately on repair stations that abuse the field approval and 8110-3 approvals. There are two kinds of people in this world. People who follow the rules and people who feel rules were made to be broken.

So yes, multiple field approvals exist for the same alterations issued by the same repair stations. Do they meet the rules and intent? No.

[sportingrifle]

CID....

I play in the antique airplane sandbox. It is common to use a 337 signed in box 3 by the FAA as substantiating data for the same mod on a different airplane of the same type. In fact among type clubs, Form 337's are sometimes traded like hockey cards. The reasoning is that since the FAA have already approved the mod, then it is data that is "acceptable to the administrator." I read two regs at odds with each other. Form 337's are not to be used repeatedly, but on the other hand, data approved by the FAA is deemed to be acceptable data. Not trying to break the rules but they are very confusing and at the end of the day, we are just trying to keep the old stuff safer and more reliable without re-inventing the wheel. Any wisdom?

Cheers Sportingrifle.

[Colonel Sanders]

Aircraft manufacturers do the same thing with new aircraft.

[CID]

I'm not sure what you mean by that last comment Colonel Sanders.

Anyway, with respect to "trading" field approvals like "hockey cards", in what context? Let's start with the term "acceptable". In Canada, "acceptable" data is appropriate for modifications that are not categorized as "major". There is no limit to the number of aircraft that an installer applies that data to.

Also in Canada, outside of an importation, all field approvals must be assessed and are not accepted by Transport Canada without that review. If the modification is deemed to be "major" then a corresponding TCCA STC must be issued and the process may include additional compliance investigation.

So, if operators in Canada are taking data on field approvals and applying it to Canadian registered aircraft without evaluation and acceptance by Transport Canada, it's not only in contradiction to the CARs, you no longer have an airworthy aircraft. At least not as defined by the CARs.

I am certainly not saying that the practice of applying the same data to various aircraft using the field approval system isn't common. It is. Hence the crackdown by the FAA. Ask around. There are plenty of repair stations that are doing a great deal of backtracking at great expense because of it.

A couple of other facts to consider. An FAA repair station can not legally apply a field approval to a foreign registered aircraft. Not can an FAA DER support an 8110-3 approval on a foreign registered aircraft. A few have learned that the hard way when they went to submit a record of the paperwork to the FAA.

There are exceptions in that some DERs down there interpret the policy as being allowed to prepare an 8110-3 against a foreign registered aircraft as long as they don't submit it to the FAA and make that declaration on the 8110-3 form. Something like "Approval of the data listed herein is subject to approval by the responsible airworthiness authority. This for is not on file at the FAA."

That pretty much means, your airplane has no C of A until you get an TCCA STC.

[Colonel Sanders]

Aircraft manufacturers do the same thing with new aircraft

[CID]

Umm...what "thing"?

[sportingrifle]

CID....

No, sorry for the confusion. I wasn't referring to Canadian aircraft. But if somebody obtains a 337 approval to upgrade the generator on their N registered Smith Fliver to an alternator, they will often give other Smith Fliver owners a copy of the approved 337 form so they can do the same. This is what I cheekily described as "trading like hockey cards." These other owners then submit the original as previously approved acceptable data. Is this practice being discouraged?

Thanks for any thoughts you may have.

Sportingrifle

[CID]

Sportingrifle, yep that works as long as block 3 is signed by a FSDO. If it's not and there are 8110-3 forms then it's not allowed. Again, I'm not saying it doesn't happen....