Aircraft modifications 3-9-2013

Federal AviationAdministration

Orlando FSDO

2013 IA Renewal Seminar

“Aircraft Modifications”

Presented by: Tony Alfaya

Aviation Safety Inspector

March 9, 2013


2Aircraft ModificationsMarch 9, 2013

““Aircraft Modifications / Alterations”Aircraft Modifications / Alterations”

Title 14 of theTitle 14 of the Code of Federal Regulations Code of Federal Regulations (14CFR)(14CFR) . .

-- Part 21Part 21 Certification Procedures for Products & Parts Certification Procedures for Products & Parts-- Part 23, 25, 27, 29Part 23, 25, 27, 29 Airworthiness Standards Airworthiness Standards -- Part 43 Part 43 Maintenance, Rebuilding, & AlterationsMaintenance, Rebuilding, & Alterations - Part 91 Part 91 General Operating and Flight RulesGeneral Operating and Flight Rules- Part 135 Part 135 Operating RequirementsOperating Requirements-- Part 145 Part 145 Repair StationsRepair Stations



“Case Law”

Relating to airworthiness reveals two conditions that must be met for an aircraft to be considered “airworthy.”

Title 49, United States Code (49 U.S.C.) § 44704(c) and 14 CFR § 21.183(a), (b), and (c) state that the following two conditions necessary for issuance of an airworthiness certificate:



“First Condition”

The aircraft must conform to its Type Design….

Conformity to the Type Design is considered attained when the aircraft configuration and the engine, propeller, and articles installed are consistent

with the drawings, specifications, and other data that are part of the Type Certificate (TC).

This includes any Supplemental Type Certificate (STC), approved repairs and alterations incorporated

into the aircraft. “Properly Altered Condition”



. “Second Condition”

The aircraft must be in a condition for safe operation. This refers to the condition of the aircraft relative to wear and deterioration, for example, skin corrosion, window delamination /crazing, fluid leaks, and tire wear, etc…..

.



§ 1.1 General Definitions

Major Alteration: means an alteration not listed in the aircraft, aircraft engine, or propeller specifications (TC) —

(1) That might appreciably affect weight, balance, structural strength, performance, powerplant operation, flight characteristics, or other qualities affecting airworthiness; or

(2) That is not done according to accepted practices or cannot be done by elementary operations.

Minor Alteration: means an alteration other than a major alteration. “Does not require FAA approval.”



“Type Design”

Type Design includes drawings, specifications, materials, processes, and the airworthiness limitations of the ICAs required to show compliance

with applicable certification rules for the product.

If the alteration or repair is determined to be a major change to Type Design, a field approval will not

be granted.

Type Design changes cannot be field approved and require: 1. New TC (or) 2. Amendment to the TC (or)2. Supplement to the TC (STC)



““Part 43 Appendix A-Part 43 Appendix A- Major Alterations”Major Alterations”

((11) ) Airframe major alterations.Airframe major alterations. Alterations of the parts and Alterations of the parts and of the types, listed in Appendix A, when not listed in the of the types, listed in Appendix A, when not listed in the aircraft specifications issued by the FAA.aircraft specifications issued by the FAA.

(2) Powerplant major alterations. Powerplant major alterations. Alterations of a Alterations of a powerplant, listed in Appendix A, when not listed in the engine powerplant, listed in Appendix A, when not listed in the engine specifications 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 propeller listed in Appendix A, when not authorized in the propeller specifications issued by the FAA.specifications issued by the FAA.

(4) Appliance major alterations.(4) Appliance major alterations. Alterations of the basic Alterations of the basic design not made in accordance with recommendations of the design not made in accordance with recommendations of the appliance manufacturer or in accordance with an FAA appliance manufacturer or in accordance with an FAA Airworthiness Directive.Airworthiness Directive.



““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) of this appendix, this appendix, each personeach person performing a major repair performing a major repair or major alteration or major alteration shallshall——

(1) Execute (1) Execute FAA Form 337 FAA Form 337 at least in at least in duplicateduplicate;;

(2) Give a (2) Give a signed copy of that form to the aircraft signed copy of that form to the aircraft ownerowner; and; and

(3) (3) Forward a copy Forward a copy of that form to the FAA Aircraft of that form to the FAA Aircraft Registration Branch in Oklahoma City, Oklahoma, Registration Branch in Oklahoma City, Oklahoma,

within 48 hourswithin 48 hours after the aircraft, airframe, aircraft after the aircraft, airframe, aircraft engine, engine, propeller, or appliance is approved for return propeller, or appliance is approved for return to service.to service.



Volume 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 one Data may be presented in various forms, but all data will fall into one of of twotwo categories: categories: acceptable acceptable to the FAA, or to the FAA, or approved approved by the FAA.by the FAA.

Acceptable DataAcceptable Data is data that you can reasonably expect the FAA to is data that you can reasonably expect the FAA to find acceptable for the purpose it was created. Examples may find acceptable for the purpose it was created. Examples may include the drawings and specifications, maintenance manuals, include the drawings and specifications, maintenance manuals, etc….. that are etc….. 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 a the drawings and specifications, including a listing of the drawings and specifications needed to define the listing of the drawings and specifications needed to define the configuration and design features of a particular article, repair, configuration and design features of a particular article, repair,

or or alteration. alteration.

NON-TSO & NON-PMA Parts NON-TSO & NON-PMA Parts may may notnot be used as approved parts be used as approved parts unless 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



““FAA Approved Data”FAA Approved Data”

The following list, although not all-inclusive, contains sources of Approved Data:

* TCDS, Type Certificate Data Sheet.* AC 43.13-1b/-2b, are approved data, when the AC

chapter, page, and paragraph are listed in 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.



““Field ApprovalsField Approvals” AC 43-210 STANDARDIZED PROCEDURES FOR REQUESTING

FIELD APPROVAL OF DATA, MAJOR ALTERATIONS, AND REPAIRS.

There are 3 types of field approvals:

1. Examination of data only- This is the most common kind of field approval. The applicant submits data that is acceptable to the Administrator, and FAA inspector approves the data by signing block 3 of FAA Form 337.

2. Physical Inspection- The applicant submits a request for approval and the inspector physically inspects the alteration and approves the alteration by signing block 3 of FAA Form 337.

3. DAR- Function Code 50 “Statement of Completeness for Alterations”

Do not cut metal, string wire, or install equipment until the field approval is granted!



“Follow-On Field Approval”

Approval of equipment of the same make and model on an aircraft using data from the initial field approval or a previously approved alteration (STC or TC). The make and model of the aircraft may be different for generic applications such as avionics installations, as long as the aircraft & installation are similar.

Initial Approval- the first field approval, STC, or TC that include the installed equipment on a

similar make and model aircraft.

Similar Aircraft- same certification basis, similar design type, material, and technology.



“Designated Engineering Representative (DER)”

AC 183.29-1, DER Consultant Directory.

DERs are representatives (designees) of the Administrator who may approve or recommend approval to the FAA of data.

DER’s authority is limited to specific functions. If a DER is limited to a specific area, data from more than one DER may be necessary and/or an FAA field approval may be required to complete the alteration.

FAA Form 8110-3 specifying “Recommend for Approval” does not constitute an approval but is usually eligible to support a field approval by the ASI.



“Instructions for Continued Airworthiness (ICA)”8900.1, Volume 4, Chapter 9, Section 1, Para. 4-11898900.1, Volume 4, Chapter 9, Section 1, Para. 4-1189

If the repair or alteration data is approved solely by the DER(s) but If the repair or alteration data is approved solely by the DER(s) but necessitates an necessitates an ICAICA in addition to the maintenance recording in addition to the maintenance recording requirements of part 43, § 43.9, the requirements of part 43, § 43.9, the ICAICA should be should be prepared by prepared by the applicant and recorded in the applicant and recorded in block 8 of FAA Form 337block 8 of FAA Form 337. .

The The ICA Checklist (Figure 4-66) ICA Checklist (Figure 4-66) should beshould be used as a guide for the used as a guide for the applicant who creates the ICA. The applicant who creates the ICA. The ICA developed in accordance ICA developed in accordance with this guidancewith this guidance is acceptable to the Administrator and is acceptable to the Administrator and

therefore therefore is not required to be reviewed by the FAA.is not required to be reviewed by the FAA.

The ICA also may introduce additional maintenance requirements that many times are not accomplished and/or tracked. Especially, when associated with an STC.



“Organization Designation Organization (ODA)”

ODA-approved data is documented by either FAA Form 8100-9, Statement of Compliance with Airworthiness Standards, or FAA Form 8100-11, Organization Designation Authorization Statement of Completion, or both, for products mfg. by ODA holder.

If the data is only documented by FAA Form 8100-9, the form should note which aspects are covered by the data, and might be included in the data package to support a field approval request.

If the data is also documented by FAA Form 8100-11, and the approval addresses all aspects of the repair or alteration, then a field approval is not necessary.



“Aircraft Flight Manual Supplements (AFMS)”

ASIs have a limited Authority to review & approve AFMS. The requirements for AFMS are determined at the time of initial approval (STC) & are normally listed on the STC Cover Page. Many STC cover pages also call out the required Pilot’s Operating Handbook.

An AFMS approval may be necessary from the ACO when an ASI is not specifically authorized to review and approve as described by Information for Operators (InFO) 08047. The ASI should confirm through the applicant that the configuration of the equipment and systems, as installed, are

described or properly characterized.



“Operational Flight Check vs. Flight Testing”

Any repair or alteration that has been determined to be major or that may substantially affect the aircraft’s operation may require an operational flight check in accordance with § 91.407 (a) and (b). Following

successful completion, the results are recorded in the aircraft records.

An alteration that requires a flight test to show compliance with the regulations I.A.W. requirements of § 21.191(b) “21.35” must be coordinated with the appropriate ACO or authorized flight test DER. The MIDO or authorized DAR must issue an experimental A/W certificate for the purpose of showing compliance I.A.W. the FAA Order 8130.2, Airworthiness Certification of Aircraft and Related Products.



“Eligibility Considerations for Field Approval”

“Field Approval Job Aid”

1. Items with the letters “STC” require an STC and cannot be field approved or approved by DER.

2. Items with the letters “EVL” may be field approved, depending on the scope & complexity of the

alteration. They will not automatically qualify for a field approval. They must be evaluated.

3. Items with the letters “ENG” may be field approved, but require either supporting DER or ODA approved engineering data or concurrence from the ACO for issuance of field approval.



“Damage Tolerance/Fatigue Evaluation of Structure”

AC 25.571-1C Damage Tolerance and Fatigue Evaluation of Structure

Damage tolerance means that the structure has been evaluated to ensure that should serious fatigue, corrosion, or accidental damage occur within the operational life of the airplane, the remaining structure can withstand reasonable loads without failure or excessive structural deformation until the damage is detected.

Data approval requires a person who has comprehensive knowledge of the specific design philosophy, loading spectrum, and

fracture mechanics techniques used in that particular design. Due to these qualifications of the specialist, responsibility for the assessment may be restricted to staff members of the airframe manufacturer, certain DERs, the FAA, or certain SFAR 36 engineering staff.



§ 23/25.1301 Function and installation

Each item of installed equipment must—

(a) Be of a kind and design appropriate to its intended function.

(b) Be labeled as to its identification, function, or operating limitations, or any applicable combination of these factors; and

(c) Be installed according to limitations specified for that equipment.



§ 23/25.1309 Equipment, systems, and installations. The requirements of this section, except as identified in

paragraphs (a) through (d), are applicable, in addition to specific design requirements of part 23, to any equipment or

system as installed in the airplane. This section is a regulation of general requirements and does not supersede any requirements contained in another section of part 23.

(a) The airplane equipment and systems must be designed and installed so that:

(1) Those required for type certification or by operating rules perform as intended under the airplane operating and

environmental conditions, including the indirect effects of lightning strikes.

(2) Any equipment and system does not adversely affect the safety of the airplane or its occupants, or the proper functioning of those covered by paragraph (a)(1) of this section.



§ 23/25.1309 “Continued”

(c) The airplane systems and associated components considered separately and in relation to other systems, must be designed and installed so that:

(1) Each catastrophic failure condition is extremely improbable and 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 condition must be provided in a timely manner to the crew to enable them to take appropriate corrective action. An appropriate alert must be provided if immediate pilot awareness and immediate or subsequent corrective action is required. Systems and controls, including indications and annunciations, must be designed to minimize crew errors which could create additional hazards.



§ 23/25.1431 Electronic Equipment

(a) In showing compliance with §23.1309(a), (b), and (c) with respect to radio and electronic equipment and their installations, critical environmental conditions must be considered.

(b) Radio and electronic equipment, controls, and wiring must be installed so that operation of any unit or system of

units will not adversely affect the simultaneous operation of any other radio or electronic unit, or system of units,

required by this chapter.

(c) For those airplanes required to have more than one flightcrew member, or whose operation will require more than one flightcrew member, the cockpit must be evaluated to determine if the flightcrew members, when seated at their duty station, can converse without difficulty under the actual cockpit noise conditions when the airplane is being operated.



§ 23/25.1431 “Continued”(C) “Continued” If the airplane design includes provision for the

use of communication headsets, the evaluation must also consider conditions where headsets are being

used. If the evaluation shows conditions under which it will be difficult to converse, an intercommunication system must be provided.

(d) If installed communication equipment includes transmitter “off-on” switching, that switching means must be designed to return from the “transmit” to the “off” position when it is released and ensure that the transmitter will return to the off (non transmitting) state.

(e) If provisions for the use of communication headsets are provided, it must be demonstrated that the flightcrew members will receive all aural warnings under the actual cockpit noise conditions when the airplane is being operated when any headset is being used.



§ 23/25.1308 High-intensity Radiated Fields (HIRF) Protection

(d) Before December 1, 2012, an electrical or electronic system that performs a function whose failure would prevent the continued safe flight and landing of an airplane may be designed and installed without meeting the provisions of paragraph (a) provided—

(1) The system has previously been shown to comply with special conditions for HIRF, prescribed under §21.16, issued before December 1, 2007;

(2) The HIRF immunity characteristics of the system have not changed since compliance with the special conditions was demonstrated; and

(3) The data used to demonstrate compliance with the special conditions is provided.



“Burn Certifications”

Flammability tests, require an FAA-approved test plan, including the conformity of test specimens witnessed by an FAA or FAA-designee inspector.

FAA-designee inspector must verify that the article or product being tested conforms to approved data or processes or material specifications.

Wire added to the airplane must have self-extinguishing insulation equal to or better than that originally approved under the airplane TC, unless it is inside an enclosure which is sufficiently airtight that internal combustion cannot be sustained.


Orlando FSDO

2013 IA Renewal Seminar

“Aircraft Modifications”

QUESTIONS? [email protected]

407-812-7740

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Aircraft modifications 3-9-2013

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