Aircraft modifications 3-9-2013
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  • 1. Federal AviationAdministrationOrlando FSDO2013 IA Renewal Seminar“Aircraft Modifications”Presented by: Tony AlfayaAviation Safety InspectorMarch 9, 2013
  • 2. Federal AviationAdministration2Aircraft ModificationsMarch 9, 2013““Aircraft Modifications / Alterations”Aircraft Modifications / Alterations”Title 14 of theTitle 14 of the Code of Federal RegulationsCode of Federal Regulations (14CFR)(14CFR) ..-- Part 21Part 21 Certification Procedures for Products & PartsCertification Procedures for Products & Parts-- Part 23, 25, 27, 29Part 23, 25, 27, 29 Airworthiness StandardsAirworthiness Standards-- Part 43Part 43 Maintenance, Rebuilding, & AlterationsMaintenance, Rebuilding, & Alterations- Part 91Part 91 General Operating and Flight RulesGeneral Operating and Flight Rules- Part 135Part 135 Operating RequirementsOperating Requirements-- Part 145Part 145 Repair StationsRepair Stations
  • 3. Federal AviationAdministration3Aircraft ModificationsMarch 9, 2013“Case Law”Relating to airworthiness reveals two conditions thatmust be met for an aircraft to be considered “airworthy.”Title 49, United States Code (49 U.S.C.) § 44704(c) and 14CFR § 21.183(a), (b), and (c) state that the following twoconditions necessary for issuance of an airworthinesscertificate:
  • 4. Federal AviationAdministration4Aircraft ModificationsMarch 9, 2013“First Condition”The aircraft must conform to its Type Design….Conformity to the Type Design is considered attainedwhen the aircraft configuration and the engine,propeller, and articles installed are consistent withthe drawings, specifications, and other data thatare part of the Type Certificate (TC).This includes any Supplemental Type Certificate (STC),approved repairs and alterations incorporated intothe aircraft. “Properly Altered Condition”
  • 5. Federal AviationAdministration5Aircraft ModificationsMarch 9, 2013.“Second Condition”The aircraft must be in a condition for safeoperation. This refers to the condition of theaircraft relative to wear and deterioration, forexample, skin corrosion, window delamination/crazing, fluid leaks, and tire wear, etc…...
  • 6. Federal AviationAdministration6Aircraft ModificationsMarch 9, 2013§ 1.1 General DefinitionsMajor Alteration: means an alteration not listed in theaircraft, aircraft engine, or propeller specifications(TC) —(1) That might appreciably affect weight, balance,structural strength, performance, powerplant operation,flight characteristics, or other qualities affectingairworthiness; or(2) That is not done according to accepted practicesor cannot be done by elementary operations.Minor Alteration: means an alteration other than amajor alteration. “Does not require FAA approval.”
  • 7. Federal AviationAdministration7Aircraft ModificationsMarch 9, 2013“Type Design”Type Design includes drawings, specifications,materials, processes, and the airworthinesslimitations of the ICAs required to show compliancewith applicable certification rules for the product.If the alteration or repair is determined to be a majorchange to Type Design, a field approval will not begranted.Type Design changes cannot be field approved andrequire:1. New TC (or)2. Amendment to the TC (or)2. Supplement to the TC (STC)
  • 8. Federal AviationAdministration8Aircraft ModificationsMarch 9, 2013““Part 43 Appendix A-Part 43 Appendix A- Major Alterations”Major Alterations”((11)) Airframe major alterations.Airframe major alterations. Alterations of the parts andAlterations of the parts andof the types, listed in Appendix A, when not listed in theof the types, listed in Appendix A, when not listed in theaircraft specifications issued by the FAA.aircraft specifications issued by the FAA.(2) Powerplant major alterations.Powerplant major alterations. Alterations of aAlterations of apowerplant, listed in Appendix A, when not listed in the enginepowerplant, listed in Appendix A, when not listed in the enginespecifications issued by the FAA.specifications issued by the FAA.(3)(3) Propeller major alterationsPropeller major alterations.. Alterations of a propeller,Alterations of a propeller,listed in Appendix A, when not authorized in the propellerlisted in Appendix A, when not authorized in the propellerspecifications issued by the FAA.specifications issued by the FAA.(4) Appliance major alterations.(4) Appliance major alterations. Alterations of the basicAlterations of the basicdesign not made in accordance with recommendations of thedesign not made in accordance with recommendations of theappliance manufacturer or in accordance with an FAAappliance manufacturer or in accordance with an FAAAirworthiness Directive.Airworthiness Directive.
  • 9. Federal AviationAdministration9Aircraft ModificationsMarch 9, 2013““Part 43 (Appen. B) Recording of Major Alterations”Part 43 (Appen. B) Recording of Major Alterations”(a) Except as provided in paragraphs (b), (c), and (d) of(a) Except as provided in paragraphs (b), (c), and (d) ofthis appendix,this appendix, each personeach person performing a major repairperforming a major repairor major alterationor major alteration shallshall——(1) Execute(1) Execute FAA Form 337FAA Form 337 at least inat least in duplicateduplicate;;(2) Give a(2) Give a signed copy of that form to the aircraftsigned copy of that form to the aircraftownerowner; and; and(3)(3) Forward a copyForward a copy of that form to the FAA Aircraftof that form to the FAA AircraftRegistration Branch in Oklahoma City, Oklahoma,Registration Branch in Oklahoma City, Oklahoma,within 48 hourswithin 48 hours after the aircraft, airframe, aircraftafter the aircraft, airframe, aircraft engine,engine,propeller, or appliance is approved for returnpropeller, or appliance is approved for return to service.to service.
  • 10. Federal AviationAdministration10Aircraft ModificationsMarch 9, 2013Volume 4, Chapter 9, Section 1Volume 4, Chapter 9, Section 1““Perform Field Approval of Major Repairs and Major Alterations”Perform Field Approval of Major Repairs and Major Alterations”Data may be presented in various forms, but all data will fall into oneData may be presented in various forms, but all data will fall into oneofof twotwo categories:categories: acceptableacceptable to the FAA, orto the FAA, or approvedapproved by the FAA.by the FAA.Acceptable DataAcceptable Data is data that you can reasonably expect the FAA tois data that you can reasonably expect the FAA tofind acceptable for the purpose it was created. Examples mayfind acceptable for the purpose it was created. Examples mayinclude the drawings and specifications, maintenance manuals,include the drawings and specifications, maintenance manuals,etc….. that areetc….. that are necessary to define the repair or alteration.necessary to define the repair or alteration.Approved Technical DataApproved Technical Data the drawings and specifications, including athe drawings and specifications, including alisting of the drawings and specifications needed to define thelisting of the drawings and specifications needed to define theconfiguration and design features of a particular article, repair, orconfiguration and design features of a particular article, repair, oralteration.alteration.NON-TSO & NON-PMA PartsNON-TSO & NON-PMA Parts maymay notnot be used as approved partsbe used as approved partsunless they have been FAA approved via an STC or TC.unless they have been FAA approved via an STC or TC.FAA Order 8900.1 “FSIMS”FAA Order 8900.1 “FSIMS” http://fsims.faa.govhttp://fsims.faa.gov
  • 11. Federal AviationAdministration11Aircraft ModificationsMarch 9, 2013““FAA Approved Data”FAA Approved Data”The following list, although not all-inclusive, containssources of Approved Data:* TCDS, Type Certificate Data Sheet.* AC 43.13-1b/-2b, are approved data, when the ACchapter, page, and paragraph are listedin block 8 of FAA form 337.* A/Ds, Airworthiness Directives.* DER, Designated Engineering Representative.* FAA Approved SB or SL, Service Bulletin/Letter.* STC, Supplemental Type Certificate.* AML/STC, STC with an Approved Model List.* ODA, Organization Designation Authorization.* Field Approval, FAA Approval of Acceptable Data.
  • 12. Federal AviationAdministration12Aircraft ModificationsMarch 9, 2013““Field ApprovalsField Approvals”AC 43-210 STANDARDIZED PROCEDURES FOR REQUESTINGFIELD APPROVAL OF DATA, MAJOR ALTERATIONS, ANDREPAIRS.There are 3 types of field approvals:1. Examination of data only- This is the most common kind of fieldapproval. The applicant submits data that is acceptable to theAdministrator, and FAA inspector approves the data by signingblock 3 of FAA Form 337.2. Physical Inspection- The applicant submits a request forapproval and the inspector physically inspects the alteration andapproves the alteration by signing block 3 of FAA Form 337.3. DAR- Function Code 50 “Statement of Completeness forAlterations”Do not cut metal, string wire, or install equipment until the fieldapproval is granted!
  • 13. Federal AviationAdministration13Aircraft ModificationsMarch 9, 2013“Follow-On Field Approval”Approval of equipment of the same make andmodel on an aircraft using data from the initialfield approval or a previously approved alteration(STC or TC). The make and model of theaircraft may be different for genericapplications such as avionics installations, aslong as the aircraft & installation are similar.Initial Approval- the first field approval, STC, or TCthat include the installed equipment on asimilar make and model aircraft.Similar Aircraft- same certification basis, similardesign type, material, and technology.
  • 14. Federal AviationAdministration14Aircraft ModificationsMarch 9, 2013“Designated Engineering Representative(DER)”AC 183.29-1, DER Consultant Directory.DERs are representatives (designees) of theAdministrator who may approve or recommendapproval to the FAA of data.DER’s authority is limited to specific functions. If aDER is limited to a specific area, data frommore than one DER may be necessary and/oran FAA field approval may be required to completethe alteration.FAA Form 8110-3 specifying “Recommend forApproval” does not constitute an approval but is usuallyeligible to support a field approval by the ASI.
  • 15. Federal AviationAdministration15Aircraft ModificationsMarch 9, 2013“Instructions for Continued Airworthiness (ICA)”8900.1, Volume 4, Chapter 9, Section 1, Para. 4-11898900.1, Volume 4, Chapter 9, Section 1, Para. 4-1189If the repair or alteration data is approved solely by the DER(s) butIf the repair or alteration data is approved solely by the DER(s) butnecessitates annecessitates an ICAICA in addition to the maintenance recordingin addition to the maintenance recordingrequirements of part 43, § 43.9, therequirements of part 43, § 43.9, the ICAICA should beshould be prepared byprepared bythe applicant and recorded inthe applicant and recorded in block 8 of FAA Form 337block 8 of FAA Form 337..TheThe ICA Checklist (Figure 4-66)ICA Checklist (Figure 4-66) should beshould be used as a guide for theused as a guide for theapplicant who creates the ICA. Theapplicant who creates the ICA. The ICA developed in accordanceICA developed in accordancewith this guidancewith this guidance is acceptable to the Administrator andis acceptable to the Administrator andthereforetherefore is not required to be reviewed by the FAA.is not required to be reviewed by the FAA.The ICA also may introduce additional maintenancerequirements that many times are not accomplished and/or tracked.Especially, when associated with an STC.
  • 16. Federal AviationAdministration16Aircraft ModificationsMarch 9, 2013“Organization Designation Organization (ODA)”ODA-approved data is documented by either FAAForm 8100-9, Statement of Compliance withAirworthiness Standards, or FAA Form 8100-11,Organization Designation Authorization Statement ofCompletion, or both, for products mfg. by ODA holder.If the data is only documented by FAA Form 8100-9, theform should note which aspects are covered by thedata, and might be included in the data package tosupport a field approval request.If the data is also documented by FAA Form 8100-11, andthe approval addresses all aspects of the repair oralteration, then a field approval is not necessary.
  • 17. Federal AviationAdministration17Aircraft ModificationsMarch 9, 2013“Aircraft Flight Manual Supplements (AFMS)”ASIs have a limited Authority to review & approve AFMS.The requirements for AFMS are determined at the time of initialapproval (STC) & are normally listed on the STC Cover Page.Many STC cover pages also call out the required Pilot’sOperating Handbook.An AFMS approval may be necessary from the ACO whenan ASI is not specifically authorized to review and approve asdescribed by Information for Operators (InFO) 08047.The ASI should confirm through the applicant that theconfiguration of the equipment and systems, as installed, aredescribed or properly characterized.
  • 18. Federal AviationAdministration18Aircraft ModificationsMarch 9, 2013“Operational Flight Check vs. Flight Testing”Any repair or alteration that has been determined to bemajor or that may substantially affect the aircraft’soperation may require an operational flight check inaccordance with § 91.407 (a) and (b). Followingsuccessful completion, the results are recorded in theaircraft records.An alteration that requires a flight test to showcompliance with the regulations I.A.W. requirements of §21.191(b) “21.35” must be coordinated with theappropriate ACO or authorized flight test DER. TheMIDO or authorized DAR must issue an experimental A/Wcertificate for the purpose of showing complianceI.A.W. the FAA Order 8130.2, Airworthiness Certification ofAircraft and Related Products.
  • 19. Federal AviationAdministration19Aircraft ModificationsMarch 9, 2013“Eligibility Considerations for Field Approval”“Field Approval Job Aid”1. Items with the letters “STC” require an STC andcannot be field approved or approved by DER.2. Items with the letters “EVL” may be field approved,depending on the scope & complexity of thealteration. They will not automatically qualify for afield approval. They must be evaluated.3. Items with the letters “ENG” may be field approved,but require either supporting DER or ODA approvedengineering data or concurrence from the ACO forissuance of field approval.
  • 20. Federal AviationAdministration20Aircraft ModificationsMarch 9, 2013“Damage Tolerance/Fatigue Evaluation of Structure”AC 25.571-1C Damage Tolerance and FatigueEvaluation of StructureDamage tolerance means that the structure has been evaluated toensure that should serious fatigue, corrosion, or accidentaldamage occur within the operational life of the airplane, theremaining structure can withstand reasonable loads withoutfailure or excessive structural deformation until the damage isdetected.Data approval requires a person who has comprehensive knowledgeof the specific design philosophy, loading spectrum, andfracture mechanics techniques used in that particular design. Dueto these qualifications of the specialist, responsibility for theassessment may be restricted to staff members of the airframemanufacturer, certain DERs, the FAA, or certain SFAR 36engineering staff.
  • 21. Federal AviationAdministration21Aircraft ModificationsMarch 9, 2013§ 23/25.1301 Function and installationEach item of installed equipment must—(a) Be of a kind and design appropriate to its intendedfunction.(b) Be labeled as to its identification, function, oroperating limitations, or any applicablecombination of these factors; and(c) Be installed according to limitations specified forthat equipment.
  • 22. Federal AviationAdministration22Aircraft ModificationsMarch 9, 2013§ 23/25.1309 Equipment, systems, and installations.The requirements of this section, except as identified inparagraphs (a) through (d), are applicable, in addition to specificdesign requirements of part 23, to any equipment or systemas installed in the airplane. This section is a regulation ofgeneral requirements and does not supersede anyrequirements contained in another section of part 23.(a) The airplane equipment and systems must be designed andinstalled so that:(1) Those required for type certification or by operating rulesperform as intended under the airplane operating andenvironmental conditions, including the indirect effects oflightning strikes.(2) Any equipment and system does not adversely affect thesafety of the airplane or its occupants, or the properfunctioning of those covered by paragraph (a)(1) of this section.
  • 23. Federal AviationAdministration23Aircraft ModificationsMarch 9, 2013§ 23/25.1309 “Continued”(c) The airplane systems and associated components consideredseparately and in relation to other systems, must be designedand installed so that:(1) Each catastrophic failure condition is extremely improbableand does not result from a single failure;(2) Each hazardous failure condition is extremely remote; and(3) Each major failure condition is remote.(d) Information concerning an unsafe system operating conditionmust be provided in a timely manner to the crew to enable themto take appropriate corrective action. An appropriate alert mustbe provided if immediate pilot awareness and immediate orsubsequent corrective action is required. Systems and controls,including indications and annunciations, must be designed tominimize crew errors which could create additional hazards.
  • 24. Federal AviationAdministration24Aircraft ModificationsMarch 9, 2013§ 23/25.1431 Electronic Equipment(a) In showing compliance with §23.1309(a), (b), and (c) withrespect to radio and electronic equipment and theirinstallations, critical environmental conditions must beconsidered.(b) Radio and electronic equipment, controls, and wiring must beinstalled so that operation of any unit or system of unitswill not adversely affect the simultaneous operation ofany other radio or electronic unit, or system of units,required by this chapter.(c) For those airplanes required to have more than oneflightcrew member, or whose operation will require morethan one flightcrew member, the cockpit must be evaluatedto determine if the flightcrew members, when seated attheir duty station, can converse without difficultyunder the actual cockpit noise conditions when the airplaneis being operated.
  • 25. Federal AviationAdministration25Aircraft ModificationsMarch 9, 2013§ 23/25.1431 “Continued”(C) “Continued” If the airplane design includes provision for theuse of communication headsets, the evaluation mustalso consider conditions where headsets are beingused. If the evaluation shows conditions under which itwill be difficult to converse, an intercommunicationsystem must be provided.(d) If installed communication equipment includes transmitter“off-on” switching, that switching means must bedesigned to return from the “transmit” to the “off”position when it is released and ensure that the transmitterwill return to the off (non transmitting) state.(e) If provisions for the use of communication headsets areprovided, it must be demonstrated that the flightcrewmembers will receive all aural warnings under the actualcockpit noise conditions when the airplane is beingoperated when any headset is being used.
  • 26. Federal AviationAdministration26Aircraft ModificationsMarch 9, 2013§ 23/25.1308 High-intensity Radiated Fields(HIRF) Protection(d) Before December 1, 2012, an electrical or electronic systemthat performs a function whose failure would prevent thecontinued safe flight and landing of an airplane may bedesigned and installed without meeting the provisions ofparagraph (a) provided—(1) The system has previously been shown to comply withspecial conditions for HIRF, prescribed under §21.16, issuedbefore December 1, 2007;(2) The HIRF immunity characteristics of the system have notchanged since compliance with the special conditions wasdemonstrated; and(3) The data used to demonstrate compliance with the specialconditions is provided.
  • 27. Federal AviationAdministration27Aircraft ModificationsMarch 9, 2013“Burn Certifications”Flammability tests, require an FAA-approved testplan, including the conformity of test specimenswitnessed by an FAA or FAA-designee inspector.FAA-designee inspector must verify that the article orproduct being tested conforms to approved data orprocesses or material specifications.Wire added to the airplane must have self-extinguishing insulation equal to or better than thatoriginally approved under the airplane TC, unless itis inside an enclosure which is sufficiently airtightthat internal combustion cannot be sustained.
  • 28. Federal AviationAdministrationOrlando FSDO2013 IA Renewal Seminar“Aircraft Modifications”QUESTIONS?tony.alfaya@faa.gov407-812-7740