Field Approval Changes

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n14ky
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Field Approval Changes

Anyone looked at the guidance for Field Approvals lately? Change 159 to FSIMS Order 8900.1 dated 6/10/2011 re-wrote almost the entire Volume 4 Chapter 9 dealing with Field Approvals. They took away a lot of stuff that we used to be able to do with Field Approvals like wheel and brake changes. I've emailed a couple of the alphabet groups and have calls into folks I know at AFS-300 to find out whet we need to do to review this and make it right. It just doesn't make sense to reduce what can be done by field approval and require STCs for things when Aircraft Cert is understaffed already. The last STC I got took over 6 months. Just tell your customer he's going to have to let his airplane sit for 6 month while you get the paperword sorted out!

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bob.pasch
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You present it just the way you always have! Their GUIDANCE changed not our regs...

n14ky
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Bob,
That's always been one of the problems with Field Approvals, there is no regulatory basis for them, it's always just been policy. The policy changed, and talking to Bob Stackslager (AFS-350) it's going to change more. Figure 4-68 in VOl 4 Chapter 9 actually belongs to Aircraft Cert, not Flight Standards. We, as mechanics need to start having more of a dialog with the folks in Aircraft Cert so they understand the need for Field Approvals for the continued airworthiness and safety of the GA fleet.

Thanks,
David

bob.pasch
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Maybe Dave but I prefer to have an open dialogue with my PMI who signs my field approvals. I think that's much more important! In my opinion, it seems that when most people move to AFS, they forget where they came from! They leave their experience, intelligence and common sense behind...

n14ky
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I agree, kkep the dialog with your PMA, but the actual decision is now with Aircraft Cert, not Flight Standards, for all those things identified as STC in Figure 4-68. IItem #2 states

"With the complexity of broad applications concerning field approval evaluations, inspectors occasionally encounter a situation in which the guidance material requires application for an STC but the Aircraft Certification Office (ACO) may deem it unnecessary. In those circumstances, ACOs should consider re-classification to ENG. In these instances, justification from the ACO must be coordinated with AIR-100 and the appropriate product directorate and provided in writing to the approving inspector so it can be referenced on Form 337."

The other thing to consider is that Flight Standards is starting to shift "Field Approvals" from the inspectors to designees. Order 8100.17 was just released on 8/31 establishing a new Function Code 51 for DARs to issue Field Approvals. So now it will be a game of coordinating between the DAR, his advisor, your PMI, and AIrcraft Cert. Seems the FAA just wants to make it harder to keep the GA fleet flying.

David

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