Avionics News January 2015 - 55

THE VIEW FROM WASHINGTON
Continued from page 13

listed in an otherwise accepted document should meet the
criterion of an accepted practice.
Elementary operations are more challenging: elementary
for whom? I don't believe the regulation is defining a
major alteration as being elementary to the installer. For
any trained and qualified technician, there are tasks they
are trained and qualified to perform, and there are tasks
they are not trained and qualified to perform.
For elementary operations, I like to look to the aircraft
(product) itself. Was the aircraft manufactured using this
type of operations (riveting, still welding, composite,
etc.)? If yes, the operation is elementary; if no, it is not
elementary. Keep in mind, the only difference it makes is
in the approval of data - a major alteration (a modification
that does not continue the type of manufacturing) simply
required approved data.
Appendix A to Part 43xA then further lists specific
alterations that are considered major.

And finally, if you have completed this "checklist" and
the modification does not meet the earlier criterion, the
regulations state that the alteration must be minor.
Minor alteration means an alteration other than a major
alteration. (§ 1.1)
The final step here is that the administrator has the
prerogative to require a modification to be treated to a
higher level of certification for various reasons; however,
that criteria will typically be published in advisory circulars.
An excellent quick reference for policies that drive a
higher level of certification is the Field Approval Job Aid
- a nice tabulated resource that addresses most of the
common alterations and many of the new technologies.
As we evaluate alterations and make a determination
of what does and does not require field approvals, an
analytical approach to alterations is needed. Sorry, "I
think" doesn't hold water. A soft determination of major
and minor from industry is no longer applicable in
today's not-so-simple world.
Why is an alteration minor? Because the analysis
shows that it is not major! q

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Avionics News January 2015

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