Dual brakes - paperwork?

[N96337]

Re: Dual brakes - paperwork?

Mike, I'm sure that was a mis-type on Dave's part. Throw that 2002 FAR book away and use current regs! Yes, they mean ANY repair/replacement to a longeron is a major... and just because the tailpost isn't specifically mentioned, doesn't mean it's not a major repair. You have to read the whole paragraph and reg...they slip in a "and" or "or" in there and it makes it inclusive. Like I said, they stress to us that any time you weld, it's automatically a major repair.
Yes, you can include more than one repair on a 337, but I tend to try to keep them a little bit seperate, like all the structure repairs on one, then the recover on another, alterations I try to keep seperate and individual.... makes it easier for the next guy to keep track of and easier for the Feds to keep seperate for approvals.....but that's up to the PMI and IA.
I totally agree with Dave...if your IA is reluctant to submit a 337, you need to drop him like the plague and find someone qualified....he's gonna get you in trouble in the long run most likely.
JH

[mhorowit]

Re: Dual brakes - paperwork?

I totally agree with Dave...if your IA is reluctant to submit a 337, you need to drop him like the plague and find someone qualified....he's gonna get you in trouble in the long run most likely.
JH

I haven't approached him so I don't know that he would ; I sort of think he is thinking it's just easier to make a log entry. What reason would he have for not wanting to submit a 337? is it hard or takes a lot of research to do one? - Mike

[Forrest Barber]

Re: Dual brakes - paperwork?

Hmmm perhaps the clamp on's would work too! I now have acquired the pulleys and bushings. They are offered on the F-19 under the TC. OR just copy and weld in...

[mhorowit]

Re: Dual brakes - paperwork?

Ran into an interesting problem. I fabricated the main tube with the bend, tacked the pedal support in place, placed a pedal on the support and clamped it into place. Now, one would think the brakes would be symmetrical, i.e. the pilot side brakes and the pax brakes would be the same distance from the centerline; however, if you do that, the right pax pedal will not cover the same arc before striking a diagonal member! To maintain the position of the main tube and gain more pedal arc, I'm going to have to move the pedal support aft about an inch. If anyone has their pax brake exposed, could you see if those pedals are about an inch further aft than the pilot side? If they aren't, I'll have to come up with a scheme for moving the main tube closer to the a/c centerline. - MikeH.

[mhorowit]

Re: Dual brakes - paperwork?

I did it.
Here are the results = Mike

[mhorowit]

Re: Dual brakes - paperwork?

oh yeah I forgot, I added dual brakes to mine. May have pics, not sure

Dave - having recently installed a second set of brake pedals , could I get a look at your 337? I need to learn how to word them for my IA - Mike

[N96337]

Re: Dual brakes - paperwork?

Mike,
You still haven't gotten this approved by your IA and FAA yet? What are you welding stuff in for??? Nobody's 337 is going to do you much good unless they have approved engineering attached. These things need to be run by the IA and inspectors before you start doing things.... it makes alot better relationship with them, and alot higher chance of getting an approval.
JH

[Mark Julicher]

Re: Dual brakes - paperwork?

Nice job Mike!

[mhorowit]

Re: Dual brakes - paperwork?

Mike,
You still haven't gotten this approved by your IA and FAA yet? What are you welding stuff in for??? Nobody's 337 is going to do you much good unless they have approved engineering attached. These things need to be run by the IA and inspectors before you start doing things.... it makes alot better relationship with them, and alot higher chance of getting an approval.
JH

Are you saying I need pre-approval from the FAA? I'm looking at the collection of 337's that came with this a/c and no-where does it indicate the 337 was sent forward, approved, then executed. The action seems to be wholly between me and my IA. Yes, I should have gotten agreement from my IA first, but the logic for going ahead seemed reasonable. First, we've seen previously approved dual brakes welded in place and second, this appears to be a minor alteration. Why do I say minor? Because "A minor change is one that has no appreciable effect on the weight, balance, structural strength, reliability, operational characteristics of other characteristics affecting the airworthiness of the product"(I don't believe I've done anything to cause an "appreciable effect"); and why do I think this is OK? Because I believe I have acceptable data for proceeding. Let me quote from the June 2009 Sport Aviation Magazine " One of the most significant differences between major and minor alterations is the data require for approval. Minor alterations require data that is acceptable to the FAA. Acceptable data is data that the installer can refer to from FAA guidance material… . However, data from the manufacturer also can be used or even interpreted from. For example, let’s say the aircraft manufacturer offers an option for a coat hook in the baggage compartment of the aircraft and you want to relocate it or add a second one. If the installer uses the same mounting methods to the same structure on the opposite side of the aircraft, it could logically be concluded that acceptable data was provided by the manufacturer when the original coat hook was designed. The point is that for any minor alteration, the installer should be able to demonstrate logical reasoning and a clear path from existing data to the work done.”

So I really don't think I've done anything incorrect, except for not discussing this with my IA.

- MikeH.

[N96337]

Re: Dual brakes - paperwork?

Like was said in here a few posts back Mike, the minor/major thing is a can of worms...and if your IA should decide that this is a major alteration, you're going to have to get it field approved. As far as it's being a major or minor alteration, my PMI (FAA maintenance inspector) says that ANY change to the brake system or landing gear is automatically a major. I don't know if that's what your local guys say, or not..... but the main thing here is that you don't know either. You need to know that before proceeding. Your interpretation of whether it's a major or minor alteration is not what holds the weight with your IA or the FAA...it's their interpretation that is bottom line. Something I've learned from dealing with this stuff for the past 25+ years is that you never count on anything to be the same from inspector to inspector, and from FSDO to FSDO. I've gotten things approved here that people tried and couldn't get done elsewhere.... on the same idea, there's people that have gotten things approved elsewhere that I couldn't get here..... but the main thing is not to jump ahead and do something before getting the ok to do so. If I was your IA and you did that without talking to me, you'd be looking for a new IA. I agree with Mark, it looks like you've done a very nice job, but I'd be really suprised if your IA is very enthused about just signing it off like that. (anything can happen...I've known more than a few that would sign annuals off without ever seeing the aircraft...) If my PMI walked in here and saw that brake setup already installed, and I hadn't run it by him first, my chances of getting it approved would be in the toilet, pretty much. Someone else's 337 is NOT approved data, unless it was done back prior to '57 (or some such date). It may be acceptable data... but that's going to be up to the PMI that has to do the field approval. Some PMI's want to come look everything over before anything's done, some want to see it only after it's completed, and some never want to see it...it's all up to the individual inspector, and it can go either way. I can't stress the importance of communication between you and your IA and him and the FAA enough. That's the main "breakdown" in most of the problems in getting things approved anymore. Whoever said that it's easier to ask forgiveness than it is to ask permission hasn't dealt with the FAA.
Mike, I'm not trying to hurt your feelings or be mean... I'm just trying to save you some agravation, work, and maybe even heartache down the road.
JH

[Hank Jarrett]

Re: Dual brakes - paperwork?

Mike,
I'm afraid I have to agree. I thought you had ALREADY gotten approval. You need to always get prior approval before you weld anything on an airplane. There are some IA's here who think ANY welding counts as a major.
Your work looks nice and a lot like the original RH brakes on my 45 with the exception of the two different diameter tubes. On the original the smaller tube connects at both ends with no slip fit tube.
Hopefully you have a close enough relationship with your IA for him to accept your work with profuse apologies (with suitable hat in hand). Have him look at it and the info you have and hope for the best. Worst case is he may make you cut it off, make a "repair" to the fuselage where it was welded and then re-weld it in under his acceptance of the modification. Don't get mad at him if he does. That's his job and he could loose his ticket if he gets caught accepting it after the fact.
I DOES look like pretty nice work, and if he can see everything he may pass it. I hope so, and good luck.
Hank
P.S.
Don't forget to promise him you will never do it again. Your IA is your partner in this. Make him a friend.

[Hank Jarrett]

Re: Dual brakes - paperwork?

Don't know if it will carry any weight with your IA but this is a photo of an original RH brake.
Hank

[lfries]

Re: Dual brakes - paperwork?

I got violated on an IFR flight plan once. 3/4 of the FAA people I spoke to said I did the right thing after losing my electrical system. The FAA attorney almost apologized when he said he had to go with the inspector who said I did the wrong thing. There is no conistency in the FAA so the best is to plan for the lack of consistency. What I'm saying is that unless one has a lot of money to try to pursue an issue "our interpretaion" of the rules don't count.

[mhorowit]

Re: Dual brakes - paperwork?

I'm OK with my IA.
I explained what I wanted to do and he said OK. We didn't discuss major v minor.
I'll try and behave myself in the future. - MikeH.

[jim cooper]

Re: Dual brakes - paperwork?

If I had been intent on putting in an extra set of brake pedals, I would have simply done it, painted the whole project the proper color. Done in a professional manner, (good welding, etc.) I doubt anyone would have ever picked it up. My answer would have been "I guess it was manufactured that way" Now, everyone knows! But again, as the FAA says , "We're here to HELP you!"