My IA says otherwise and so did the DAR I spoke with about it yesterday evening. It’d be interesting to see the FAA regulation that makes it so. 
FAR
APPENDIX D TO PART 43—SCOPE AND DETAIL OF ITEMS (AS APPLICABLE TO THE PARTICULAR AIRCRAFT) TO BE INCLUDED IN ANNUAL AND 100-HOUR INSPECTIONS
(j) Each person performing an annual or 100-hour inspection shall inspect (where applicable) each installed miscellaneous item that is not otherwise covered by this listing for improper installation and improper operation.
“Improper installation” and “improper operation” of “miscellaneous items” fails to cover a lot of FAA Major Modifications, eh? I think you’d get closer with this: FAA Inspection Authorization Information Guide but its a guide, not a regulation so its not binding in the same way. It almost agrees with you, but I don’t believe the underlying regulations actually say anything on the subject.
Here’s a concrete example: An A&P IA mechanic is inspecting a Globe Swift that’s had a field approved change in outboard wing section, represented by the logs as being covered by a 337, which covers a DER approved engineering report. The A&P IA has the logbooks with a prior A&P IA sign-off for the modification, referencing the 337 under which the approval was processed. Do FAA regulations require that that this A&P IA review and understand the 337 and the DER’s report, and compare that with the aircraft configuration before signing off an annual inspection? Neither my IA or the DAR I spoke with think the regulations require that level of review by the new A&P IA within the scope of a routine annual inspection.
Obviously, neither yourself nor your buddies have seen some of the crap that I’ve seen installed under a 337.
Just because some idiot signed off the 337 is no guarantee that it is airworthy.
It’s that simple.
Just because some idiot signed off the 337 is no guarantee that it is airworthy. It’s that simple.
Oh, I agree with that… Even a system that makes people directly responsible won’t produce quality if the people involved are dishonest. Any system relies on most people being honest, with the exceptions being few enough that the results are still generally OK.
I once bought a plane that had a logbook entry covering a configuration change that was allowable under the original Type Certificate. It was signed off by an A&P IA and referenced an airframe manufacturer’s drawing that was proprietary to the TC holder. I was subsequently told that the drawing number covered a completely different configuration… Neither me nor any A&P IA could get access to that drawing, or the correct one for that matter, and the original A&P IA was dead. My approach was to look over the installation with my own eyes – it was fine, paperwork notwithstanding.
Even a system that makes people directly responsible won’t produce quality if the people involved are dishonest
Bingo.
We can agree on that.
One issue I have seen here, which – reading US forums and speaking to some people over there – is true in the USA too, is that many A&Ps or IAs have clear difficulty reading the regs.
Here, with Part M, one doesn’t expect anybody to understand it at all 
and it does create all sorts of “fundraising opportunities” with the result that everything gets massively gold plated.
But the US system has been stable for decades and apart from some specialised avionics stuff (e.g. any EFIS product needs an STC; cannot be done as a field approval) anybody who has been around for some time should understand it.
I have seen numerous cases (not on my plane I should add) of a Part 14 company writing out a 337 to cover some mod, without any understanding of Minor v Major mod, and never filing it to the FAA. They somehow think the 337 covers them…
But should an IA, doing an Annual, get hold of the CD for the aircraft and check every 337 in the logbooks has actually been filed to Oklahoma? That would be daft.
Anyway, this is really technical stuff and we are getting a long way from why people don’t go N-reg.
Anyway, this is really technical stuff and we are getting a long way from why people don’t go N-reg.
According to my statistics, only about 30-40 % of European private aircraft are “EASA aircraft”. The rest are Annex II, experimental, microlight, gliders etc. Further, for the N-reg business to be anything but an academic exercise, the aircraft has to have a certain value, it has to fly a lot and preferably fly IFR. This means very few privately owned aircraft, or aircraft owners, will have any benefit from it in the first place, less than 5% is my guess?
For the majority of privately owned aircraft, the EASA regulations do not even apply. Here people do the maintenance themselves, or according to national rules and regulations that are much more sane than the EASA regime. Besides, EASA regulations are improving, and a lot of the added cost today is there simply because people are willing to pay, and don’t know any better, resulting in a situation where the maintenance organizations can get away with anything it seems.
… without any understanding of Minor v Major mod, and never filing it to the FAA. …
… But should an IA, doing an Annual, get hold of the CD for the aircraft and check every 337 in the logbooks has actually been filed to Oklahoma?
The way the FARs are written concerning Major vs Minor mods & repairs is somewhat ambiguous and remains a subject of debate among A&Ps. That said, every now and again, the FAA brings out an AC (Advisory Circular) that clearly states that such and such a mod is considered minor or not.
The IA performing an annual inspection should ask the owner/operator to show all the 337s that have been issued. Although there is no requirement for this, it is just good recommended SOP . It is an FAA requirement that the owner/operator maintain these records although they are not required to be on-board during operations, with the exception of fuel tank modifications.
Agreed that this is somewhat removed from the OP, but it demonstrates the complexity of the system and any owner/operator would be advised to understand this before acquiring or transferring a acft to FAA reg.
any owner/operator would be advised to understand this before acquiring or transferring a acft to FAA reg.
I doubt the risk in modifications done in the past would feature strongly in the decision. After all, there are many more mods covered by an FAA STC than by a Euro STC, and nobody will argue with an STC-backed 337.
As regards incompetence, that is pretty universal…
There is always a risk in transferring (in terms of what might be found) but it is applicable to any reg transfer. If going say G to D you have the same issues, surely? There is an Export CofA involved.
Nice plane BTW
