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STC Education

Posted: Fri Sep 09, 2016 5:25 pm
by 170C
Bruce/George/Others, I need some info regarding stc's. I am aware that an stc is issued with one number from the FAA upon approval even though the "item" may be applicable to numerous aircraft. For example Rosen Visors or Horizon digital tachometers are approved for multiple aircraft and each has only one stc#. When I installed my Rosen visors, I simply followed the installation instructions and put them in, kept the stc data, but did not have my A&P/IA do a 337 or a logbook entry. Was this wrong? My Horizon tachometer was installed per mfg's instructions and my IA made a logbook entry and filed a form 337. I am not clear if ALL stc'd items must be installed by an A&P, or under his/her supervision, and both a logbook entry and 337 filed w/ FAA. I also note that many of my stc'd items are not noted by the supplier for a specific aircraft serial number and/or registration number while others (like my visors) came with my reg # & s#. Just need some guidance/clarification.

Re: STC Education

Posted: Fri Sep 09, 2016 6:23 pm
by Bruce Fenstermacher
Ole Pokey asked-
When I installed my Rosen visors, I simply followed the installation instructions and put them in, kept the stc data, but did not have my A&P/IA do a 337 or a logbook entry. Was this wrong?
  • I say-
    Yes. You modified/performed maintenance or repair without documenting it. This is basic and wrong. Also you likely did not have the authority to do what you did. So you are doubly wrong.
Ole Pokey asked-
My Horizon tachometer was installed per mfg's instructions and my IA made a logbook entry and filed a form 337. I am not clear if ALL stc'd items must be installed by an A&P, or under his/her supervision, and both a logbook entry and 337 filed w/ FAA.
  • I say-
    All work performed on an airplane must be performed by a person authorized to do so. Most of the time that means at least an A&P but there are exceptions. An STC applied to an aircraft is a major alteration. It must be documented on a 337 and filed with the FAA. According to AC No: 43.9-1F, the instructions how to fill out a form 337, under # 6." FORM INSTRUCTIONS. The person who performs or supervises a major repair or major alteration must prepare Form 337. " So only persons authorized to perform major alterations can fill out a 337. This is not an owner operator unless they have an A&P.
Ole Pokey asked-
I also note that many of my stc'd items are not noted by the supplier for a specific aircraft serial number and/or registration number while others (like my visors) came with my reg # & s#. Just need some guidance/clarification.
  • I say-
    All STC's have a eligibility list that states exactly what model and serial number of those models that the STC can be applied. Permission of the STC holder was always required from the STC owner which allowed an STC to be applied to a aircraft. In the beginning of the STC program this was very loose. It is not anymore. ALL STC owners are required to issue a document of permission specifying exactly, by serial number, what aircraft their STC can be applied. This document must be included with the 337 and the eligibility list sent to the FAA.

    As FAA inspectors/mechanics of today are not so knowledgeable how it was they will often apply today's standard to yesterday's paperwork. The owner with inadequate documentation today is left in the cold

Re: STC Education

Posted: Fri Sep 09, 2016 9:59 pm
by GAHorn
Bruce Fenstermacher wrote:Ole Pokey asked-
When I installed my Rosen visors, I simply followed the installation instructions and put them in, kept the stc data, but did not have my A&P/IA do a 337 or a logbook entry. Was this wrong?

  • I say-
    Yes. You modified/performed maintenance or repair without documenting it. This is basic and wrong. Also you likely did not have the authority to do what you did. So you are doubly wrong.


Ole Pokey asked-
My Horizon tachometer was installed per mfg's instructions and my IA made a logbook entry and filed a form 337. I am not clear if ALL stc'd items must be installed by an A&P, or under his/her supervision, and both a logbook entry and 337 filed w/ FAA.

  • I say-
    All work performed on an airplane must be performed by a person authorized to do so. Most of the time that means at least an A&P but there are exceptions. An STC applied to an aircraft is a major alteration. It must be documented on a 337 and filed with the FAA. According to AC No: 43.9-1F, the instructions how to fill out a form 337, under # 6." FORM INSTRUCTIONS. The person who performs or supervises a major repair or major alteration must prepare Form 337. " So only persons authorized to perform major alterations can fill out a 337. This is not an owner operator unless they have an A&P.


Ole Pokey asked-
I also note that many of my stc'd items are not noted by the supplier for a specific aircraft serial number and/or registration number while others (like my visors) came with my reg # & s#. Just need some guidance/clarification.

  • I say-
    All STC's have a eligibility list that states exactly what model and serial number of those models that the STC can be applied. Permission of the STC holder was always required from the STC owner which allowed an STC to be applied to a aircraft. In the beginning of the STC program this was very loose. It is not anymore. ALL STC owners are required to issue a document of permission specifying exactly, by serial number, what aircraft their STC can be applied. This document must be included with the 337 and the eligibility list sent to the FAA.

    As FAA inspectors/mechanics of today are not so knowledgeable how it was they will often apply today's standard to yesterday's paperwork. The owner with inadequate documentation today is left in the cold[/list
    ]
What Bruce said. :lol:

Alright, I know you'd feel cheated if I didn't add something:..

It's possible that a modification which is considered major for one make/model aircraft... may only be minor for a different make/model. The STC holder might apply for an STC in order to "cover themselves" in whatever installation is made regardless. In the sun visor example, the mounting instructions in a King Air (pressurized airplane) may involve drilling/altering the pressure-vessel structure near the critical windshield. Therefore an STC is required because it is a major alteration of a type certificated airplane (the Supplemental T.C replaces/modifies the original TC).

In a C-170.. it may not require an STC even tho' the mfr'r has included the aircraft model (for legality or proprietary reasons). If the sun visors are only a minor alteration , it requires an A&P to make a logbook entry (No Form 337). But if it's an "Interior refurbishment item"...(no alteration of critical structure)..then the owner-pilot may do so, again with only a logbook entry, under Appdx A, "Preventive Maintenance". (I'm not intimately familiar with Rosen installations so I'm not passing judgment on it, I'm only attempting to explain the different reasons an STC may or may not be req'd in all aircraft, and why a Form 337 may be req'd in some aircraft but not all. If your installation made use of existing structure with no major alteration... or if it utilized previous mounting with no major change...then it might be considered interior refurbishment which is allowable under Appdx A.)

Is now foggy-er?

Meanwhile, your IA (who performed your last Annual inspection) should have noticed the alteration and searched for supporting approval (STC authorization and Form 337). If he missed it, he was sloppy...or perhaps he didn't miss it and agrees with you that it was a minor alteration/interior refurbishment that required no STC. (If he missed it, perhaps he'll not charge you to document the installation out of his embarrassment.) :wink:

Why would an STC holder issue the STC serialed to an airplane for which it is a minor alteration? In order to provide the 1) owner with the documentation that he is the legitimate owner of the mod and has the ICAs (Instructions for Continued Airworthiness, if any), and 2) so that any subsequent owner who wishes to contact Rosen for replacement/repair parts can provide evidence they own a legitimate authorization for them to be installed by the STC holder. Otherwise, Rosen might presume they were lifted out of a wrecked airplane from the salvage yard and therefore Rosen would have no obligation to provide service.)

Hope this helps understand why it's sometimes foggy.

Re: STC Education

Posted: Sat Sep 10, 2016 3:25 pm
by Metal Master
To further muddy the waters!
What an “STC” is and what it is not:
STC is not a word it is an acronym: Supplemental Type Certificate
It supplements the original Type Certificate.
It is not an approval for manufacturing Parts. That is a PMA another acronym: Parts Manufacturing Authority. A replacement part manufactured under an FAA PMA does not require a form 337 to be installed, as it must fit (replace) the original part in Form Fit and Function. Do Rosen sun visors meet that qualification? (Maybe) A manufacture cannot manufacture a part and sell it to another person for use in a Type Certificated Aircraft without a PMA. That does not necessarily mean that the part is TSO’d another acronym: Technical Standard Orders (TSO) TSO is a minimum performance standard for specified materials, parts, and appliances used on civil aircraft. When authorized to manufacture a material, part, or appliances to a TSO standard, this is referred to as TSO authorization. Receiving a TSO authorization is both design and production approval. But a part having TSO part is not an approval for you to install it in your aircraft. It would still need to be installed by an authorized individual with the proper rating and or licenses and the appropriate log entry made. Many aircraft parts are manufactured that do not have TSOs

A part manufactured under PMA and sold as an STC is a way that an STC holder can sell and ensure and along with the FAA be sure a part is installed under proper guide lines by qualified people on type certificated aircraft. The part will have a PMA but probably not a TSO.

However an owner operator may manufacture a part as an owner produced part for use in his own aircraft if manufactured with Acceptable Techniques and Practices such as those contained in AC 43.13-1B. He may not install that part in the type certificated aircraft unless it falls under the Category under Appdx A, "Preventive Maintenance" otherwise it would have to be installed as either a Minor alteration and an entry made in the Log book by an A&P (Airframe & Power Plant rated technician). Or as an Major Alteration which would require being installed by and A&P or properly supervised individual and inspected by an IA (Inspection Authorization), DER (Designated Engineering Representative) or field approved by and FAA maintenance Inspector and installed by those approved individuals. And then the appropriate log entry made or if required form 337..
An STC holder (the person who owns the STC) may not even manufacture the part or parts. He may only have drawings of the parts which he then may give an approval in writing and supply the drawings to the owner of the aircraft who then may manufacture the part or parts, must document and have inspected by the criteria in the previous paragraph. But it is Still a Major Alteration if performed in accordance with the STC instruction.
An STC may be issued as a one-time only STC which then is only applicable to the aircraft in which it was originally installed. In fact a FAA Field Approved Modification done on a form 337 is actually a one-time STC although it will not be given an STC number, and the form 337 shows that the aircraft was modified in accordance with the instructions as written in Block 8 of the Form 337. And will require instruction, for continued airworthiness and other items be included in Block 8 of the form and must meet the criteria of this AC: AC No: 21-47 http://www.faa.gov/documentLibrary/medi ... 021-47.pdf

The Rosen Sun visor example: if a log book entry was made stating that they were installed in accordance with the STC in whatever manor the entry was worded then it is required that the installation be performed by and A&P or properly supervised individual inspected by and IA and an MAJOR ALTERATION FORM 337 needs to be filed out. If the installation instructions mention in any paragraph the STC. Then the installation would drive that it is not a Minor Modification and would require that if you made an entry stating you followed the manufactures installation instructions to install it becomes MAJOR. The Maybe part comes if you install a set of ROSEN sun visors and do not install them per the STC or the manufactures installation instructions. And if you mention the manufactures name in the log entry the part then becomes an illegally installed part. If you installed the Rosen sun visors as an Owner Produced Part and you considered it as an item that falls under the Appdx A, "Preventive Maintenance" then you could sign it off as the owner operator of the aircraft. But I have to ask why would you do that? Simply to not have to pay that damned A&P I guess. No insult intended.
Installation of an STC by the owner operator of an aircraft would not necessarily have to be installed by an A&P if the instructions in the STC said that it could be performed by the owner operator. However as it is a supplement to the original Type Certificate of the aircraft it would still need to be inspected by and A&P and IA and the FORM 337 and log entry made. Or the work can be performed under the direct supervision of an A&P and then inspected by an IA and the FORM 337 and log entry made.
All of this is why people build experimental aircraft! It takes the A&P partially out of the question. And it takes the IA completely out of the question as an IA’s only job is to make certain that the aircraft conforms to its Type Certificate or properly altered condition. This is what an IA’S function is at the annual inspection or when he signs the bottom of a Form 337. (Read the small blue paragraphs on the Standard Airworthiness Certificate in your aircraft). READ IT! Experimental aircraft do not have a Type Certificate. They have an Airworthiness certificate that comes with a letter of Limitations which outline in accordance with whatever types of experimental category the aircraft is listed in how it will be operated and Maintained and how it will be signed of at its “conditional inspection”. And the Letter of Limitations must reside with the Airworthiness certificate in the aircraft when it is operated. An experimental inspection can be performed by any licensed A&P mechanic, an FAA Approved Repair Station, or by the builder of the airplane provided the builder obtains a "Repairman's Certificate" from the FAA. Note that unlike an annual for a type certificated aircraft, the A&P mechanic does NOT have to have his/her "Inspection Authorization". There are many different categories of experimental aircraft. Take a look at a 8130-6 form from the FAA web site and you will see what I mean. Found here: http://www.faa.gov/forms/index.cfm/go/d ... 19145.Note that the 8130-6 is also the form for applying for a standard airworthiness certificate and if you were requesting a new airworthiness certificate or ferry permit it is the form you would use.

In my job I fill out some 50 or so Airworthiness applications a year for both Standard Category and Experimental category aircraft. except for Ferry permits the FAA comes and inspects these aircraft every time.

It sounds to me that you may have made you aircraft so that it does not conform to its airworthiness certificate and may not be signed of buy an IA as airworthy. However it is up to the owner operator to make that determination. But an IA may not agree with you
I had a guy call me up at the shop one time and asked me to perform his annual inspection under the table so that he would not have to pay shop fee's that he hated A&P's and that he performed all of the work on his own airplane and had an IA sign it off at annual, other wise no log entries were made by him. I told him we would not be able to work together. Some time later I was asked to perform a pre-purchase inspection on this aircraft for an interested buyer not knowing it was the same guy. The list of unapproved modifications on this aircraft were mind boggling. I presume he eventually sold the aircraft to someone but not my customer.

Re: STC Education

Posted: Mon Sep 12, 2016 12:58 am
by GAHorn
Excellent post, MM! Thanks.

(PS: I know what you mean by that heavily modif'd airplane. One of the most heavily modified airplanes I"ve ever witnessed was owned by an A&P/IA who had "invented" so many mods which himself had also "inspected and approved" and signed so many 337s it would fill a library. Asked to test-fly it... I could not get a simple pre-flight performed successfully, it had so many unairworthy items. I guess it's a case of the most fiction ever written that I've seen was authored by that guy.) :roll: