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Joined: Feb 2004
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Royson,

You do bring up some good points and they are valid to a point. None of us should have to worry that the FAA is watching us; that if any mistake is made, they will come down on the owner like a ton of bricks and impress their boss that the aircraft owner was kept in line on his watch. Many FAA employees are reasonable, some are strictly by the book. It all depends on the luck of the draw. Some FAA employees own their own aircraft: restore classics or build kit planes. They are truely interested in aviation. Others could care less about aviation and are strictly bureacratic in their thinking (very 2 dimensional).

I will have to say that I am in an unfortunate position. Since I work for the FAA myself as an aircraft certification engineer, I could be held to a higher standard. If I bought and operated an airplane with known 337 issues, I risk being disciplined in some way.

Also, please understand that the reason for filling out a 337 is to keep track of a major repair or alteration that does not follow the manufacturers own methods of maintenance. Major repairs affect the primary structure, how the airplane handles, etc. and as such, the 337 ensures that an FAA designee has approved the fix and that the information is part of the permanent records. God forbid if the repair was not done properly, an IA did not look at it, and the airplane suffers an inflight failure of the primary structure. That is all I am thinking about. A good FAA inspector should not violate an aircraft just because of paperwork, but because safety could not be assured (at least that is the theory). Also, an IA is properly trained to do this kind of work (usually not the owner) or he/she could not become an IA (again, theory as there are some unqualified IA's and A&P's out there).

It all boils down to buyer beware. Do you want an airplane that has some missing 337's for the major repair work done and be exposed to a possible violation? Chances are, it won't be discovered - but it only has to happen once to spoil your day. By the way, if there are missing 337's and an FAA inspector discovers it, then the last A&P who did the annual could be held responsible.

Above all, my safety and the safety of my passengers depends on a good airplane in proper condition and with good maintenance and, as necessary, good repair. I want to enjoy flying without being concerned about the integrity of the machine.

That is my view of things.

Steve

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Right on. Clearly if there is any question about the structural integrity the plane shouldn't be flown regardless of whether the FAA knows about it. Of course the question is, how do we know if there's a structural problem? The official answer would be that an IA has inspected the repair, and filled out the correct paperwork to indicate that it was done to FAR standards.

The missing piece of the puzzle is: If the paperwork was never filed, what can be done after the fact? (Especially years later). Could it be resolved by an IA filling out new paperwork? My understanding is that the 337 must be filed within a limited time after the repair is accomplished (I don't recall the exact period, 30,60, 90 days?)

So in a case like this, is the airplane legally unairworthy? If so, it's easy to understand why the owners since the repair have adopted "don't ask, don't tell"

Is there any solution to this, other than a current IA signing off the repairs (both unlikely, and perhaps unethical, since he/she would have to pretend the repairs were recently accomplished.) Or is the only redress having the repairs done over, and new paperwork filed?

One reason that I'm taking a special interest in this is that we commonly hear from owners who discover STC or 337 paperwork that is in their logbooks was never filed with the FAA. It takes a degree of diligence to discover this in the first place. These are rarely major items like wing repairs. For example, a recent issue was a digital OAT gauge, properly installed, but the paperwork was never filed with the FSDO. If the owner followed the letter of the law, her airplane would be grounded pending approval, which might take months, or never come. She could either remove the OAT gauge to return the airplane to airworthy status, or do nothing, and continue to fly, the obvious path of least resistance.

It's an interesting dilemma.

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Royson,

I would fly with the OAT gage on my airplane too, even if the paperwork is not right. Many FSDO inspectors wouldn't make a fuss over it and it is just a gage. Major repairs on a wing (which is primary structure) is a different story. If the paperwork is not right on this (no 337), the FSDO inspector would take a dim view and maybe ground the airplane until the problem were rectified. Maybe that is why the airplane has been for sale since July. A nice airplane still, but I am going to move on - I did send a message to the owner that he should rectify the problem (though I am still interested) two days ago. Normaly, he responds in a few hours, but he has not responded this time.

It is hard to find a low time 150 in the Chicago area. I am not willing to go to a distan state (like California, Floriday or Colorado) to find a plane; it just is not worth it. I will look in Wisconsin, Michigan and Indiana (Ohio is a stretch).

Thanks for your message!

Steve

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Quote
I actually work for the FAA myself as an Aerospace Engineer in Aircraft Certification..... As a condition of sale, I would stipulate that the owner hire an A&P (hies brother is one) to write the 337's (of course that A&P assumes responsibility). Otherwise, no sale.

What are your thoughts? Am I being reasonable, or too paranoid?

Forget it, if the owner, his A&P or IA knows you work for the FAA, they won't touch it with a ten foot pole. Too much chance they would wind up getting violated for something along the way.

You have problems with this airplane due to its repairs, and you want someone to tell you its OK by doing paperwork on it. The price is way too high and you need to just walk away and look elsewhere.

Rule #1 in aircraft sales, never sell an airplane to: A) a doctor, B) a lawyer, or C) an FAA employee.

Sorry, couldn't resist!!!!

Charles


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First, I am an expert on nothing.
Second, I have more than a passing interest in the subject of missing 337's.
I have talked briefly with Charles about this in the past and I'm sure he can, if he wishes, clarify the subject.
FAR Part 43, Appendix B says in part:
(b) For major repairs made in accordance with a manual or specifications acceptable to the Administrator, a certificated repair station may, in place of the requirements of paragraph (a)-(requirement for 337)-
(1) Use the customer's work order upon which the repair is recorded;
(2) Give the aircraft owner a signed copy of the work order and retain a duplicate copy for at least two years from the date of approval for return to service of the aircraft, airframe, aircraft engine, propeller, or appliance;

Of course it is necessary to examine the regulations in effect at the time of the repair. From this reading it appears that a certificated repair station does not need to file a 337 and they only need to keep records for two years. Now if a past owner chooses not to include the work order in the records passed on when the plane is sold, the only record may be a return to service or annual from a certified repair station.
It sucks but I would guess that it is not an uncommon situation and is only now coming to light with computerized records available from the NTSB and FAA regarding accidents or incidences and our access to the 337's filed with the FAA.

Harry

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I should have included the link to the quoted far:
http://www.airweb.faa.gov/Regulator...0E4308B78D8852566AB006BC9DC?OpenDocument

harry

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I'm no expert, either! Quoteing the regs is one thing; how your local FSDO interprets them is often quite another! Still, the regs do seem to offer hope of an out for long lost paperwork.

Assuming you are in dispute with the local FSDO over interpretation of the regs, to whom do you appeal? The administrator?


Wire Paladin, San Francisco
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