Draft Order 8300.X Repair and Alteration Data available for comment

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n14ky
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Draft Order 8300.X Repair and Alteration Data available for comment

There is a new draft Order 8300.X on Major Repair and Alteration Data open for comment here http://www.faa.gov/aircraft/draft_docs/orders/

This draft is set to replace the contents of 8900.1 Vol 4 Chap 9 sect 1 on Field Approvals. I strongly suggest that all read and make comments as appropriate.

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bob.pasch
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Sorry for the delay in responding but I [yawn] fell asleep several times while reading the NPRM. As far as I can see, it still doesn't affect us worker bees as it is guidance, not regulatory. (Don't go there Dave!) We're still using AC43-210 as a template and compliance with the AC, objectivity notwithstanding, keeps us in the communicative ball park to accomplish the task. So the question you should ask yourself re: 8300xxx is "what changes for me?"

My personal answer is nothing but you should decide for yourself. As I see it, the regulations are clear. There are three levels of changes to type certificated products: a major change in type design, which requires an application for an STC; a major alteration, which requires approved data; and, a minor alteration. If you can't agree or if your inspector doesn’t recognize the differences supported by the regulations, then start up the FAA chain of command until you reach a supervisor who recognizes the regulations.

Don't be afraid to disagree, ask why! It's not a question designed to challenge their authority. It allows you find out what they know that you hadn't considered or what they hadn't considered that you have. Then... communicate!

On a positive note, their proposed guidance includes a chart, Figure 3-1 in the NPRM that is remarkably similar to Ric Peri's guidance, architecture for a field approva [I don't recall the exact title], developed circa 2004 for exactly this reason. Hmmm, not bad... only 10 years!

n14ky
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Bob,
First off, it isn't an NPRM, it is a request for comment on Policy. There are actually some good things in the proposed policy, first off, if approved they would have to notify you in writing with the reason for not approving a Field Approval request. I've had some in the past that weren't approved with no reason given, or the reason was we're too busy. That won't fly with this new policy.

While as part of the user community, our guidance is supposed to be Advisory Circulars, we all know that FAA employees are bound by their Orders. If in the preperation of a Field Approval we know what thier guidance is, and develop out request along the lines of what they are looking for, it is a much smooter ride. In this case, we have the ability to comment on their policy and if we make it easier for us to comply with policy, we should take advantage of it.

As a DAR, there are a number of items within the order I disagree with. Also as a designee, I am also bound by the policy of an order, so the contents of the final version will have a direct impact on how I perform the functions of a designee. Keep in mind that designees can now do field approvals, and like with almost every other FAA function, they will be handing off more and more field approvals to designees.

Recently FAA came up with the Major Repair and Alteration Job Aid. This document is used by FAA inspectors to determine if a given alteration can be done as a field approval, if it will need the assistance of the ACO and or DER, or if it will have to go the STC process. This document is the most important part of the entire process as it defines what can be done as a Field Approval. This document is a combined AFS and AIR document, and all mechanics that do field approvals should keep a close eye on any changes. A couple years ago it was changed (used to be in 8900.1 Vol 4 Chap 9) to make wheel and brake changes an STC project. Fortunatly with the more recent change it is now back to being eligable as a Field Approval. Little things like that make ourr job a real headache, so being able to make comment on these policy documents are a real blessing. We shouldn't let the opportunity pass us by even if the comment is "good job".

Just as a point of reference, my comments on this proposed policy were 4 pages in length.

bob.pasch
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You know what Dave? You're right! It isn't an NPRM. Now let's cut to the chase. You say there's a lot of good things in there, I say it's another ambivolent attempt at convoluted logic intended to purposely keep the water muddy! A modified Peter Principle, if you will, for reasons of job security.

Face it, we all [for the most part] know what needs to happen to get the job done on both "sides" because, as A&Ps, we're REQUIRED to read, write and comprehend the English language. So I read the MMs and follow the ACs and what happens? Enter the modifief Peter Principle. Their "side" sez: "Nope, sorry Bubba, no can do. OUR GUIDANCE sez you gotta do it this way".

A debate ensues, regulations defeat guidance... again [or you could say common sense prevails] and everyone's happy. Everyone but your customer, whose been aggrivated for no reason; your boss, whose worried about negative relations cuz he's a businessman, not a mechanic and the lower totem pole tech whose worried about FAA reprisal. And why did this happen? Guidance!

Now you infer it's helpful yet you say"...our guidance is supposed to be Advisory Circulars, we all know that FAA employees are bound by their Orders." How is that helpful pal? But wait, it gets worse! Your reasoning is "...we have the ability to comment on THEIR policy and if we make it easier for us to comply with policy, we should take advantage of it."

WE aren't BOUND by THEIR policy! Like 7UP, never have never will. And as if that wasn't enough enter the Major Repair and Alteration Job Aid. As you see it, it's an aid. As I see it, it's an aid designed to determine how to interpret the guidance that MANDATES them to maintain ambiguity.

So if you really want to fix a perceived problem, change the regulations or change the Advisory Circular Dave. KISS it Dave, don't exacerbate an already abstruse situation with more oxymoronic instructions.

I'll sum it up with this example. A man goes to buy a suit from the worlds best suit salesman. The first suit he tries on is way too big. His pants won't even stay up. The salesman says that it looks good on him and "to keep your pants from falling down just hold your arm against the waist of your pants.

"But look at the cuffs; these pants are way too long" the man says.
"Not at all" says the salesman, "Just adjust the length of the pants and hold your knees together."

The man then complains: "but this jacket is way too big." The suit salesman assures him it looks good, "all you have to do is adjust the lapels like this... and hold your other arm here across your chest to keep it looking nice.

The guy looks in mirror and agrees to buy the suit. As he's walking down the street (with his knees together, one arm holding the waist of his pants, the other pressing against his chest to keep the jacket looking nice), a elderly couple see the man walk buy and the wife says "Oh, look at the poor retarded, disabled man." And the husband replies: "Yeah but his suit sure fits great, doesn't it?"

So what'll it be Dave? A 44 regular or a 58 extra tall?

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