FAA Says Form 337 Takes Only 30 Minutes to Complete

SUMMARY: In accordance with the Paperwork Reduction Act of 1995, the FAA invites public comments regarding its request to the Office of Management and Budget for approval to renew the information collection related to the FAA Form 337.
[Federal Register]

MAJOR HIGHLIGHTS: According to the FAA, the information collection associated with FAR 43 is necessary to ensure maintenance, rebuilding or alteration of aircraft, aircraft components, etc., is performed by qualified individuals and at proper intervals. Furthermore, the FAA said proper maintenance records are essential to ensure an aircraft is properly maintained and is mechanically safe for flight.

In this notice and request for comments, the FAA estimated there are 87,769 certified mechanics, repair stations and air carriers authorized to perform maintenance. According to the FAA, Form 337 is collected only annually, and it takes approximately 30 minutes to complete and submit the form to the government.

The FAA asks the public to provide the following information regarding comments:

  1. Whether or not the proposed collection of information is necessary for the FAA’s performance.
  2. The accuracy of the estimated burden.
  3. Ways the FAA could enhance the quality, utility and clarity of the information collection.
  4. Ways the burden could be minimized without reducing the quality of the collected information.

(The AEA recommends also including a “reality check” as to how you use this form annually and the actual time for completion and submission.)

Comments should be submitted to:
Carla Scott
Federal Aviation Administration
800 Independence Ave., SW
Room 712, IT Enterprises Business Services Division, AES-200
Washington, D.C. 20591

AEA COMMENTARY: The Aircraft Electronics Association highly encourages every member to comment on the FAA’s request. Clearly, FAA Headquarters has no idea of the real time and effort it takes to complete Form 337 to the satisfaction of its field personnel, much less what it actually is used for (87,769 certified mechanics, repair stations and air carriers authorized to perform maintenance). The form is used only to record major alterations and major repairs, not simply “maintenance” as implied by this notice.

Contact Ric Peri, AEA vice president of government and industry affairs, by email at ricp@aea.net or by phone at 202-589-1144.