Maintenance for an N-reg aircraft in Europe, by A&P / A&P/IA / EASA145 company

I managed one Field Approval many years ago when we still had an FAA FSDO at Heathrow, but it was a painful process. Subsequently I used several FAA DERs. My electrical./avionics DER has now retired (as have I almost) but the structures guy we used is still around and offers a great service with quick turnround, particularly for fitting antennas on pressurised aircraft:

https://secure.strongaero.com/

You are lucky.

Here, I have not known any shop do a field approval, and one shop used to do DER jobs (using DER Associates) and then several other shops would buy the package which this shop produced.

But this is history since most work (that any shop here is willing to do) has an STC.

Peter wrote:

Almost no shop knows about the DER route, practically zero can get a Field Approval done

Not true in Switzerland. I’ve done several mods using both DER and Field Approval approach as well as A&P/IA Form 337 signoff using approved data. @Silvaire describes perfectly how this can work. DERs are usually specialized these days so finding one for the type of work being planned might be more effort that it used to be.

Hmmm – didn’t know you could do that.

Getting briefly back to mods, you can see why N-regs based in Europe limit themselves almost totally to STC mods. Almost no shop knows about the DER route, practically zero can get a Field Approval done, the TC route is rarely available

Presumably they would also utilize AC 41.13-2B Link as approved data? Extract from the cover letter:

This data generally pertains to minor alterations; however, the alteration data herein may be used as approved data for major alterations when the AC chapter, page, and paragraph are listed in block 8 of FAA form 337 when the user has determined that it is:

a. Appropriate to the product being altered,

b. Directly applicable to the alteration being made, and

c. Not contrary to manufacturer’s data

The restriction to note the chapter, page and paragraph on the 337 is important as it makes much clearer whether the data is directly applicable to the work, with little opportunity for sweeping statements of applicability. It is none the less a terrific resource because no FAA interaction or major mod. approval is required other than IA sign off and submission of the Form 337, just like an STC.

Unfortunately almost no Europe based A&P or A&P/IA knows about the above

Getting briefly back to mods, you can see why N-regs based in Europe limit themselves almost totally to STC mods. Almost no shop knows about the DER route, practically zero can get a Field Approval done, the TC route is rarely available (it might be e.g. replacing a KLN94+KMD550 in a TB20 with 2×GNS430 which were on the original Socata TC, so maybe you could “install” those and “immediately” pull them out and install 2×IFD440), and that’s about it.

Mind you, non-STC EASA Major Mods are very expensive unless you know how to work the system.

An IA is required to do an annual inspection. The typical sequence is the IA signs off the annual after the inspection and discrepancies/servicing is accomplished, but this is not necessary. The inspection process itself determines the discrepancies, it does not include the return to service after repairs and servicing. Once the annual inspection is complete, the IA signs off the inspection as either airworthy or unairworthy. In either case, the annual requirement is met. If the aircraft is signed off as unairworthy, the IA is required by regulation to provide the owner/operator with a discrepancy list and it is up to the owner to handle them. The list of discrepancies are not included in the logbooks, but they must be resolved by a competent person, usually an A&P. If the competent person performs maintenance, they must make a logbook entry for any maintenance to return the aircraft to service. Often more than half of the work accomplished during an annual is maintenance and servicing. Also, many shops and some IA have determined discrepancies that are not required by the FAA, for example performing service bulletins that are not an AD, replacing or overhauling engines, propellers, and parts based solely on time in service. I have had several annuals signed off as unairworthy and arranged for repairs on my own. In some this was due to disagreements with the IA as to what constituted an airworthiness discrepancy. This usually occurred when an annual was accomplished as part of a pre-purchase inspection where the seller wanted to use their own mechanic to resolve discrepancies. In one case, the IA at my shop was about to go on vacation for two weeks, so I had him sign off the annual after he completed the inspection as unairworthy and provide the owner with a list of discrepancies and then the other A&P in the shop could return the aircraft to service in his absence. One other case on my own Bonanza, occurred when I hired an out of town IA (4 hour one way drive) who I respected and some of the discrepancies were going to take a week for parts to arrive. It did not make sense to have him come back when the parts arrived (I had to pay for his travel expenses and hotel) when I could have a local A&P install them and return the aircraft to service.

My goal is to understand if indeed there is a way for an instance involving a 337 form to be arranged WITHOUT engaging the FAA in any way, shape or form. I understand this is not possible.

A 337 has to be sent off to Oklahoma, for filing. There is no inspection of it. This part cannot be avoided, but it is just €1 for airmail

The following Major Alteration methods avoid any FAA “inspection” or “approval”:

• STC
• DER 8110 (popular with European avionics shops for mods not covered by an STC, as mentioned previously)
• TC based mod (installing something which is listed on the TC but wasn’t installed on the particular aircraft)

The only method which needs an FAA “approval” is a Field Approval and this is hard to get done in Europe because there are no FSDOs here that you can pop into. You need a contact in the US. I have done a number of these myself, via a contact e.g. this this and this. But very few people in Europe do these because they haven’t got the contacts. And if you are a shop then you simply tell your customers to ignore everything without an STC! That’s how Garmin came to own the universe. The more imaginative shops, for non STC mods, use the DER route and bill the cost to the client; I’ve seen DER prices from a few hundred $ (for signing a 1 page drawing prepared by the European shop) to $10k (for a complete set of wiring diagrams for an EHSI).

I have recently been involved with a couple of N-regs, and I can personally attest that this payment for pencil power really seems to happen.

Sure; there are idiots around. I wrote this above. They eventually get kicked off and go back to working in an EASA shop because they got EASA66 on the back of their A&P work experience, and with some written exams

Given the atrocious shape some planes I’ve looked at are in, it seems that the competent authority being on another continent isn’t exactly fruitful.

There is no “competent authority” in aviation. The system hangs together like any QA system hangs together:

• a signature by an authorised person means the work was done right (whether it actually was done right, or done at all, is irrelevant – all QA systems work that way; look at ISO9000 which is the same thing) and EASA Part M has exactly the same weaknesses but is worse for the customer because whereas with an A&P/IA the buck stops with the man himself in the EASA system the buck stops with a company so a) you never find out who was responsible and b) nothing can be done about it

• in light GA, people don’t normally get killed as a result of poor work, though I got fairly close here and here (read under Installer Performance)

But pencil whipped annuals are a fact.

There is/was an engine shop, EASA145, in central Europe, which did engine overhauls with this

Pretty well impossible to prove.

Welcome to GA

You’re welcome.

As I explained relatively few 337s are created by or signed off by anybody but an FAA A&P IA, because the work is much more often done based on existing approved data. Given that situation there is no FAA involvement other than filing the IA-signed 337 in the aircraft records, and yes, the IA needs to mail the signed 337 to FAA within 48 hrs of the work being completed.

Obviously an IA reviews AD compliance and inspects for TC compliance issues as part of every annual inspection.

Interesting that local mechanics in Europe would do poor work just because they aren’t signing it off. Also interesting to believe that an IA would send Annual sign off stickers through the mail without seeing the plane. I’ve never personally met an IA who would do anything remotely like that – being caught doing it would not be a happy thing. All this sounds a bit far fetched to me.