Can a 145 company issue a 337 other than the usual ways ie
Your question needs clarifying :
- “a 145 company” – Are you referring to an FAA 14 CFR Part 145 Certified Repair Station or ?
- What are you trying to establish since the authority to “issue” a Form 337 is one thing and the “Supporting Data”, STC, Field Approval, etc. is something else.
Yes. I thought that was obvious since a 337 is FAA
I am trying to establish whether a 145 firm can do an airframe mod (say, fitting an antenna) and just write out a 337 without any evident supporting docs. It is widely done, it seems, in the USA and elsewhere. I have seen it myself.
AFAICT it means nothing; it’s just a warm feeling for the customer. I doubt they send the 337 to AFS-750 in Oklahoma, too
In the case I am thinking of, the work is (IMHO) a Minor Alteration anyway, so why do a 337? It’s because, IMHO, the concept is misunderstood.
If it is a Major Repair or Major Alteration it requires Approved Data such as an STC or DER/Field Approval….if it is not major the all you need is Acceptable Data which means conformance with AC43.13-1a and 2a and/or MM, service letters/bulletins….
If installing an antenna is not Major then you are OK….
In terms of whether a RS can fill in a 337, yes if they gave the appropriate RS Authorizations (Airframe in this case)….but an A&P could just as easily fill it in…but in this case if it is not Major then s 337 is not required at all!
I guess my Q was whether a 145 firm has any additional authority in connection with a 337 compared to an A&P/IA.
I would say less….you don’t even need an A&P to have a RS certificate! Let alone with IA privileges…
Peter wrote:
I guess my Q was whether a 145 firm has any additional authority in connection with a 337 compared to an A&P/IA.
With regards to filing 337s, the Part 145 Repair Station has no more “authority” than an A&P WITH IA .
AnthonyQ wrote:
.you don’t even need an A&P to have a RS certificate! Let alone with IA privileges…
Whilst that may be true, the Process to obtain AND maintain a Part 145 Repair Station Licence is far more rigorous than obtaining and maintaining an A&P with IA licence.
So such a 337 is bogus?
Peter wrote:
So such a 337 is bogus?
Bogus ? no just not required & unnecessary .
The FAA has published guidelines about Major vs Minor and filing 337s to cut down on the proliferation of what I will describe as “CYA” filings.