Major Alteration or Log Book Entry?

[Bob Turner]

Edit: these posts were moved from another thread in order to promote the conversation based on the FAA's definition of a "Major Alteration". It started with Bob's creative addition of a panel for basic electrical switches and stuff.

Couple photos as promised. The locomotive is of course way off topic, but might be of interest to some. It is all bronze, and is one of a kind (foundries are almost all unwilling to talk to me, and I am not courageous enough to pour bronze). The band was done by Callie, and it took several re-dos, for which she never charges. I always send a little extra - she is my secret weapon.


And this is my Cub with its latest radio - the lettering was done over a rattle-can sprayed aluminum sheet, using a Leroy set and India ink. Then it was clear-coated gently with another rattle can, and finally coated with Future Floor Wax applied one-way with Q-Tips. We have had pretty good success with this formula, although I bet the vinyl would last longer. I have also used water-transfer decals with great success - the secret is, as always, the over-coat.

 

[Bartman]

Nice work Bob!

That's an interesting way to add an electrical system in a Cub.

@Big Ed , I forgot to mention, the trick to make the labels look integrated into the panel is to run a sharpy around the edge. After they're printed and trimmed to size, the edge stays white and makes it look like a sticker, especially on the dark panel. A quick dressing with the right colored Sharpie and it's a big improvement.

 

[Bob Turner]

Hopefully it is not a "system." There are ambiguous statements in FAA guidance that indicate a fundamental change of an electrical system might be a major alteration.
"System" elsewhere (not in FAA guidance documents) comprises a continuous source - a generator or alternator. We are just portable batteries.

 

[Bartman]

So all of that is just a logbook entry?

 

[Bob Turner]

Yes. Look up the definition - would your switch panel have an appreciable effect on any of the listed criteria? Lemme see if I can post it here.

Definitions provided in 14 CFR Part 1.1 state, “Major alteration means an alteration not listed in the aircraft, aircraft engine, or propeller specifications—

(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.”

And “minor alteration means an alteration other than a major alteration.”

 

[Bartman]

So Bob, according to that definition, the changes I made to the electrical system by mounting the switches and breakers on the panel instead of overhead, they wouldn't constitute a major alteration and should only need a logbook endorsement?

 

[Bob Turner]

Your IA is the last word on that. If he says major, and you get along with him (or her), ask him what part of that definition applies.

Can you make a case for even a minimal effect on performance, airworthiness, weight, etc? And there is interpretation out there on the weight/balance part that says the FAA means a dramatic change, like in changing the gross weight or envelope, and not a few pounds here or there.

 

[Big Ed]

So Bob, according to that definition, the changes I made to the electrical system by mounting the switches and breakers on the panel instead of overhead, they wouldn't constitute a major alteration and should only need a logbook endorsement?

New factory Decathlons have the switches and breakers on the panel, correct? If so, then your alteration is listed in aircraft specifications. You might want to find a drawing or something to reference.

 

[Bartman]

That's actually the plan Ed, I have a factory drawing and we're going to reference it when doing the logbook endorsement. I was just using my panel as an example in response to Bob's post about major alterations. It's so weird to me that there are A&P's out there that will defer to the FAA on just about everything which ultimately just makes life that much harder. Bob's take on stuff makes a lot of sense and it's all there in the writing but it still seems controversial to just do as it says!

 

[Big Ed]

it's all there in the writing but it still seems controversial to just do as it says!

Well sure, as long as you have ALL of the writing.

14 CFR 43 appendix A

Appendix A to Part 43 - Major Alterations, Major Repairs, and Preventive Maintenance

(a) Major alterations -
(1) Airframe major alterations. Alterations of the following parts and alterations of the following types, when not listed in the aircraft specifications issued by the FAA, are airframe major alterations:

(i) Wings.
(ii) Tail surfaces.
(iii) Fuselage.
(iv) Engine mounts.
(v) Control system.
(vi) Landing gear.
(vii) Hull or floats.
(viii) Elements of an airframe including spars, ribs, fittings, shock absorbers, bracing, cowling, fairings, and balance weights.
(ix) Hydraulic and electrical actuating system of components.
(x) Rotor blades.
(xi) Changes to the empty weight or empty balance which result in an increase in the maximum certificated weight or center of gravity limits of the aircraft.
(xii) Changes to the basic design of the fuel, oil, cooling, heating, cabin pressurization, electrical, hydraulic, de-icing, or exhaust systems.
(xiii) Changes to the wing or to fixed or movable control surfaces which affect flutter and vibration characteristics.
(2) Powerplant major alterations. The following alterations of a powerplant when not listed in the engine specifications issued by the FAA, are powerplant major alterations.

(i) Conversion of an aircraft engine from one approved model to another, involving any changes in compression ratio, propeller reduction gear, impeller gear ratios or the substitution of major engine parts which requires extensive rework and testing of the engine.
(ii) Changes to the engine by replacing aircraft engine structural parts with parts not supplied by the original manufacturer or parts not specifically approved by the Administrator.
(iii) Installation of an accessory which is not approved for the engine.
(iv) Removal of accessories that are listed as required equipment on the aircraft or engine specification.
(v) Installation of structural parts other than the type of parts approved for the installation.
(vi) Conversions of any sort for the purpose of using fuel of a rating or grade other than that listed in the engine specifications.
(3) Propeller major alterations. The following alterations of a propeller when not authorized in the propeller specifications issued by the FAA are propeller major alterations:

(i) Changes in blade design.
(ii) Changes in hub design.
(iii) Changes in the governor or control design.
(iv) Installation of a propeller governor or feathering system.
(v) Installation of propeller de-icing system.
(vi) Installation of parts not approved for the propeller.
(4) Appliance major alterations. Alterations of the basic design not made in accordance with recommendations of the appliance manufacturer or in accordance with an FAA Airworthiness Directive are appliance major alterations. In addition, changes in the basic design of radio communication and navigation equipment approved under type certification or a Technical Standard Order that have an effect on frequency stability, noise level, sensitivity, selectivity, distortion, spurious radiation, AVC characteristics, or ability to meet environmental test conditions and other changes that have an effect on the performance of the equipment are also major alterations.

(b) Major repairs -
(1) Airframe major repairs. Repairs to the following parts of an airframe and repairs of the following types, involving the strengthening, reinforcing, splicing, and manufacturing of primary structural members or their replacement, when replacement is by fabrication such as riveting or welding, are airframe major repairs.

(i) Box beams.
(ii) Monocoque or semimonocoque wings or control surfaces.
(iii) Wing stringers or chord members.
(iv) Spars.
(v) Spar flanges.
(vi) Members of truss-type beams.
(vii) Thin sheet webs of beams.
(viii) Keel and chine members of boat hulls or floats.
(ix) Corrugated sheet compression members which act as flange material of wings or tail surfaces.
(x) Wing main ribs and compression members.
(xi) Wing or tail surface brace struts.
(xii) Engine mounts.
(xiii) Fuselage longerons.
(xiv) Members of the side truss, horizontal truss, or bulkheads.
(xv) Main seat support braces and brackets.
(xvi) Landing gear brace struts.
(xvii) Axles.
(xviii) Wheels.
(xix) Skis, and ski pedestals.
(xx) Parts of the control system such as control columns, pedals, shafts, brackets, or horns.
(xxi) Repairs involving the substitution of material.
(xxii) The repair of damaged areas in metal or plywood stressed covering exceeding six inches in any direction.
(xxiii) The repair of portions of skin sheets by making additional seams.
(xxiv) The splicing of skin sheets.
(xxv) The repair of three or more adjacent wing or control surface ribs or the leading edge of wings and control surfaces, between such adjacent ribs.
(xxvi) Repair of fabric covering involving an area greater than that required to repair two adjacent ribs.
(xxvii) Replacement of fabric on fabric covered parts such as wings, fuselages, stabilizers, and control surfaces.
(xxviii) Repairing, including rebottoming, of removable or integral fuel tanks and oil tanks.
(2) Powerplant major repairs. Repairs of the following parts of an engine and repairs of the following types, are powerplant major repairs:

(i) Separation or disassembly of a crankcase or crankshaft of a reciprocating engine equipped with an integral supercharger.
(ii) Separation or disassembly of a crankcase or crankshaft of a reciprocating engine equipped with other than spur-type propeller reduction gearing.
(iii) Special repairs to structural engine parts by welding, plating, metalizing, or other methods.
(3) Propeller major repairs. Repairs of the following types to a propeller are propeller major repairs:

(i) Any repairs to, or straightening of steel blades.
(ii) Repairing or machining of steel hubs.
(iii) Shortening of blades.
(iv) Retipping of wood propellers.
(v) Replacement of outer laminations on fixed pitch wood propellers.
(vi) Repairing elongated bolt holes in the hub of fixed pitch wood propellers.
(vii) Inlay work on wood blades.
(viii) Repairs to composition blades.
(ix) Replacement of tip fabric.
(x) Replacement of plastic covering.
(xi) Repair of propeller governors.
(xii) Overhaul of controllable pitch propellers.
(xiii) Repairs to deep dents, cuts, scars, nicks, etc., and straightening of aluminum blades.
(xiv) The repair or replacement of internal elements of blades.
(4) Appliance major repairs. Repairs of the following types to appliances are appliance major repairs:

(i) Calibration and repair of instruments.
(ii) Calibration of radio equipment.
(iii) Rewinding the field coil of an electrical accessory.
(iv) Complete disassembly of complex hydraulic power valves.
(v) Overhaul of pressure type carburetors, and pressure type fuel, oil and hydraulic pumps.

(c) Preventive maintenance. Preventive maintenance is limited to the following work, provided it does not involve complex assembly operations:

(1) Removal, installation, and repair of landing gear tires.
(2) Replacing elastic shock absorber cords on landing gear.
(3) Servicing landing gear shock struts by adding oil, air, or both.
(4) Servicing landing gear wheel bearings, such as cleaning and greasing.
(5) Replacing defective safety wiring or cotter keys.
(6) Lubrication not requiring disassembly other than removal of nonstructural items such as cover plates, cowlings, and fairings.
(7) Making simple fabric patches not requiring rib stitching or the removal of structural parts or control surfaces. In the case of balloons, the making of small fabric repairs to envelopes (as defined in, and in accordance with, the balloon manufacturers' instructions) not requiring load tape repair or replacement.
(8) Replenishing hydraulic fluid in the hydraulic reservoir.
(9) Refinishing decorative coating of fuselage, balloon baskets, wings tail group surfaces (excluding balanced control surfaces), fairings, cowlings, landing gear, cabin, or cockpit interior when removal or disassembly of any primary structure or operating system is not required.
(10) Applying preservative or protective material to components where no disassembly of any primary structure or operating system is involved and where such coating is not prohibited or is not contrary to good practices.
(11) Repairing upholstery and decorative furnishings of the cabin, cockpit, or balloon basket interior when the repairing does not require disassembly of any primary structure or operating system or interfere with an operating system or affect the primary structure of the aircraft.
(12) Making small simple repairs to fairings, nonstructural cover plates, cowlings, and small patches and reinforcements not changing the contour so as to interfere with proper air flow.
(13) Replacing side windows where that work does not interfere with the structure or any operating system such as controls, electrical equipment, etc.
(14) Replacing safety belts.
(15) Replacing seats or seat parts with replacement parts approved for the aircraft, not involving disassembly of any primary structure or operating system.
(16) Trouble shooting and repairing broken circuits in landing light wiring circuits.
(17) Replacing bulbs, reflectors, and lenses of position and landing lights.
(18) Replacing wheels and skis where no weight and balance computation is involved.
(19) Replacing any cowling not requiring removal of the propeller or disconnection of flight controls.
(20) Replacing or cleaning spark plugs and setting of spark plug gap clearance.
(21) Replacing any hose connection except hydraulic connections.
(22) Replacing prefabricated fuel lines.
(23) Cleaning or replacing fuel and oil strainers or filter elements.
(24) Replacing and servicing batteries.
(25) Cleaning of balloon burner pilot and main nozzles in accordance with the balloon manufacturer's instructions.
(26) Replacement or adjustment of nonstructural standard fasteners incidental to operations.
(27) The interchange of balloon baskets and burners on envelopes when the basket or burner is designated as interchangeable in the balloon type certificate data and the baskets and burners are specifically designed for quick removal and installation.
(28) The installations of anti-misfueling devices to reduce the diameter of fuel tank filler openings provided the specific device has been made a part of the aircraft type certificiate data by the aircraft manufacturer, the aircraft manufacturer has provided FAA-approved instructions for installation of the specific device, and installation does not involve the disassembly of the existing tank filler opening.
(29) Removing, checking, and replacing magnetic chip detectors.
(30) The inspection and maintenance tasks prescribed and specifically identified as preventive maintenance in a primary category aircraft type certificate or supplemental type certificate holder's approved special inspection and preventive maintenance program when accomplished on a primary category aircraft provided:

 

[Big Ed]

Here is another useful one:

AC 43-210a - Standardized Procedures for Obtaining Approval of Data Used in the Performance of Major Repairs and Major Alterations

 

[Bob Turner]

Scary list, until you start looking for switch panels. Also note that it clarifies the change to weight and balance - just adding weight or moving the empty CG doesn't count.

 

[Bartman]

Scary list, until you start looking for switch panels. Also note that it clarifies the change to weight and balance - just adding weight or moving the empty CG doesn't count.

If I had to guess, I'd bet a lot of A&P's would rather err on the side of caution, submit the paperwork, and let the FAA flag it if it's wrong or inappropriate somehow. The alternate for them is to not submit it, have an incident or inspection find them accused of acting in error, and then have to dig themselves out of the FAA's investigation after the fact.

I get that but it's still unfortunate that the environment created by the FAA has people on the defensive instead of doing what is clearly correct based on well written standards. CYA shouldn't be the standard.

 

[Big Ed]

Scary or not, the list is part of FAA regulatory guidance. 14 CFR Part 1.1 by itself provides insufficient guidance.

The pertinent items from the list would be:

(a) Major alterations -
(1) Airframe major alterations. Alterations of the following parts and alterations of the following types, when not listed in the aircraft specifications issued by the FAA, are airframe major alterations:
....
(ix) Hydraulic and electrical actuating system of components.
....
(xii) Changes to the basic design of the fuel, oil, cooling, heating, cabin pressurization, electrical, hydraulic, de-icing, or exhaust systems.

Clearly the switch and breaker panel is part of the electrical system. Does moving the location of the switches and breakers from the overhead box to the instrument panel "change the basic design" of the electrical system?

I'm sure many people will argue no. I question that. You are not just moving a switch panel. You are moving the switches and breakers from a location where both pilots can access it, to a location where only one pilot can access it. I think the FAA might want to have a vote in an alteration that results in the PIC being unable to reach controls required for AFM-specified emergency procedures.

In this case, it is entirely a moot point, since the alteration is listed in the aircraft specifications, which makes it by definition a minor alteration.

 

[Bartman]

I think the FAA might want to have a vote in an alteration that results in the PIC being unable to reach controls required for AFM-specified emergency procedures.

There are a lot of controls that a rear-seated PIC (aka flight instructor) can't reach. The fuel valve, the electric fuel pump switch, the door jettison pin and handle, the radio and transponder tuning knobs (121.5 and 7700), etc. The electrical panel is up in the corner of the ceiling, if I had to guess, because there wasn't room on the panel back in the days of analog only instruments and there's no room below the crossover bar at the base of the panel where a lot of designers stuck stuff like that.

As a rear-seated PIC you have the responsibility to decide if your front-seater is capable of flipping switches and doing other things at your direction in an emergency. The airplane designer can't be there to accommodate each and every contingency, the PIC has to decide what can be defended as safe and what can't be.

For me personally, I enjoy hearing Bob's take on things, he's a smart guy, has tangled with the FAA in defense of his interpretations, and has years of experience in the system. Covering your ass will never be a bad strategy but I like hearing about different ways of doing things and I'm very grateful to have the factory's data available supporting changes that are being made.

 

[Bob Turner]

It really is personal. My philosophy is to interpret ambiguities in my favor, except maybe where a finding against me could result in serious penalty, like from mis-interpreting tax laws.

This is a guess - I would say that maybe sixty percent of pilot/mechanics tend to interpret the regs in the most restrictive way possible. That is ok with me, since, at least for now, it costs me nothing.

Ed's take is valid - if the factory hadn't moved the switches, he would have cosidered that a change to the basic design. Yet he doesn't think the factory can tell him to carry an AFM. That too is a valid take, and harm resulting from being "wrong" is minimal to non-existent. Unlike tax law . . .j

Your local ASI may want you to do a field approval on this - hand him or her the above regulations, and ask for an opinion in writing. Most will do that only after Hell freezes over.

I was a brand new IA 20 years ago, and filed a 337 with the FSDO for my new instrument panel. They were obliged by policy documents to return it to me stating that it was a minor alteration. They did not do that. They did not send it to OKC, either. So when I got more educated I made a log entry addressing that 337, and noted that it was submitted in error.

Things are different now - the only person who sees your 337 is a minimum wage clerk in OKC. When you sell your aircraft, guys like me have to look through all those major alteration 337s and spot the "approved data." Fully half the time, an IA has created the data. Then I get to go obtain a field approval - either that or insist that the alteration be removed.

File early and often. I am going to start charging big bucks for correcting 337s without approved data.

 

[Big Ed]

My point remains. 14 CFR Part 1.1 is not the only source of regulatory guidance on major vs minor. 14 CFR 43 appendix A contains many more details and should also be consulted. Does anyone disagree with that?

 

[Bob Turner]

Of course not. And no one is questioning your judgment that moving a couple switches is a major change to an electrical system. I am merely pointing out that others may view that sort of change in a different light.

 

[Big Ed]

Of course not. And no one is questioning your judgment that moving a couple switches is a major change to an electrical system. I am merely pointing out that others may view that sort of change in a different light.

I'm not saying it is a major repair. I am not qualified to make that determination. I am merely pointing out that it is not as simple as 1.1 alone might make it look.

 

[Bartman]

Of course it isn't Ed, my comment about it based on Bob's brief post wasn't just on that simple portion that Bob posted but we've discussed this before and we're familiar with Bob's take on it, which I find interesting and credible. It's always ultimately up to the specific person signing the work which, in my case, isn't Bob!