A piper PA38 had a major airframe repair accomplished with no form 337 filed per far 43 pt 17.

Attributes
ACN	410981
Time
Date	199804
Day	Wed
Local Time Of Day	1201 To 1800
Place
Locale Reference	airport : zzz
State Reference	US
Altitude	agl bound lower : 0 agl bound upper : 0
Environment
Light	Daylight
Aircraft 1
Operator	general aviation : instructional
Make Model Name	PA-38 Tomahawk
Operating Under FAR Part	Part 91
Flight Phase	other
Flight Plan	None
Person 1
Affiliation	Other
Function	other personnel
Qualification	other other : other
ASRS Report	410981
Person 2
Affiliation	government : faa
Function	observation : air carrier inspector
Qualification	other other : other
Events
Anomaly	non adherence : far non adherence : published procedure
Independent Detector	other other : unspecified
Resolutory Action	none taken : detected after the fact
Consequence	Other
Supplementary
Air Traffic Incident	other

Narrative:

During a 100 hour inspection, I found bulkhead P/north xyzxx cracked beyond limits. Removed and replaced the bulkhead with a new bulkhead P/north xyzxx. Failed to file FAA form 337 for stated action. Discrepancy was found during annual inspection. FAA form 337 for this action has since been filed. At the time of the item replacement it was perceived as just a replacement of a defective part with a new serviceable part by means of riveting for attachment. Further reading and understanding of far 43.17 appendix a paragraph (B)(1) states replacement of this part by riveting is considered an airframe major repair. Perception of items was a factor in this incident.

Original NASA ASRS Text

Title: A PIPER PA38 HAD A MAJOR AIRFRAME REPAIR ACCOMPLISHED WITH NO FORM 337 FILED PER FAR 43 PT 17.

Narrative: DURING A 100 HR INSPECTION, I FOUND BULKHEAD P/N XYZXX CRACKED BEYOND LIMITS. REMOVED AND REPLACED THE BULKHEAD WITH A NEW BULKHEAD P/N XYZXX. FAILED TO FILE FAA FORM 337 FOR STATED ACTION. DISCREPANCY WAS FOUND DURING ANNUAL INSPECTION. FAA FORM 337 FOR THIS ACTION HAS SINCE BEEN FILED. AT THE TIME OF THE ITEM REPLACEMENT IT WAS PERCEIVED AS JUST A REPLACEMENT OF A DEFECTIVE PART WITH A NEW SERVICEABLE PART BY MEANS OF RIVETING FOR ATTACHMENT. FURTHER READING AND UNDERSTANDING OF FAR 43.17 APPENDIX A PARAGRAPH (B)(1) STATES REPLACEMENT OF THIS PART BY RIVETING IS CONSIDERED AN AIRFRAME MAJOR REPAIR. PERCEPTION OF ITEMS WAS A FACTOR IN THIS INCIDENT.

Data retrieved from NASA's ASRS site as of July 2007 and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.