Ticking all the Right Boxes

By Mike Broderick — March 31, 2014

Psst!  Hey buddy .  .  .  are you using the revised 8130-3?
If not, here’s your chance to come up to speed with the new-look form.

Welcome once again my faithful students. Yikes! Look at your calendar. I’ll bet that February 1, 2014 has now passed. Do you know what this means? Well, take a look at the last FAA Authorized Release Certificate, Form 8130-3, Airworthiness Approval Tag you just completed. Now look in the lower left hand corner of the form. Is it inscribed  “FAA Form 8130-3 (02-14)” or is it inscribed “FAA Form 8130-3 (06-01)”?

If you are using (02-14) you have been keeping up to date and have read the latest best seller from the FAA: “ORDER 8130-21H”.
Although this page-turner is written in typical FAA prose, it is a must-read, and more importantly, a must-comply if you want to avoid an unpleasant confrontation with your local FAA Inspector. Ah-ha! I see a surprised look on some of your faces. Uh-oh! You didn’t hear about Order 8130-21H?

Okay, stick with me because we can fix this and get you back on the straight and narrow.
First, fire up your computer and go to the World Wide Web using this link:
http://www.faa.gov/regulations_policies/orders_notices/
Look up Order 8130-3H and there you will find all the information regarding the new look 8130-3. But don’t leave. As I have gone through considerable research on Order 8130-21H, let me share what I have come up with.

So that we have a complete understanding of the 8130-3, we will go through a short history of the 8130-3 before we go through the changes to the new 02-14 form. Thus, when you finish with our lesson today you will have a better understanding of the 8130-3 form itself.  Ready?  Okay here we go.

8130-3 Defined

FAA Advisory Circular (AC) 20-62E provides a current description of and purpose for the 8130-3: “FAA Form 8130-3, Airworthiness Approval Tag, identified a part or group of parts for export approval and conformity determination from production approval holders. It also serves as approval for return to service after maintenance or alteration by an authorized part 145 repair station, or a U.S. Air Carrier having a Continuous Airworthiness Maintenance Program under parts 121 and 135.”

So as you can see Form 8130-3 clearly has two distinct purposes:
1. It used to approve or certify that new and used parts meet conformity requirements from the “Original” Airworthiness side of the FAA.
2. To certify approval for return to service following maintenance from the “Recurrent” Airworthiness side of the FAA.

8130-3 History

Now, as part of the history, I need to give you guys some descriptions of the term “Aviation Products” which is used within the Export version of the 8130. Aviation products have been separated into three different classes, dependent upon the complexity and / or use of the product, and are defined as Class I, II, and III and Newly Overhauled, by 14 CFR Part 21.321.

The following definitions have remained unchanged since March 1979:

(1) A Class I product is a complete aircraft, aircraft engine, or propeller, which:
i) has been type certificated in accordance with the applicable Federal Aviation Regulations and for which federal aviation specifications or type certificate data sheets have been issued, or
ii) is identical to a type certificated product specified in paragraph (b)(1)(i) of this section in all respects except as is otherwise acceptable to the civil aviation authority of the importing state.

(2) A Class II product is a major component of a Class I product (e.g., wings, fuselages, empennage assemblies, landing gears, power transmissions, control surfaces, etc.), the failure of which would jeopardize the safety of a Class I product or any part, material, or appliance, approved and manufactured under the Technical Standard Order (TSO) system in the ‘C’ series.

(3) A Class III product is any part or component which is not a Class I or Class II product and includes standard parts, i.e., those designated as AN, NAS, SAE, etc.

(4) The words “Newly Overhauled” when used to describe a product means that the product has not been operated or placed in service except for functional testing since having been overhauled, inspected, and approved for return to service in accordance with the applicable Federal Aviation Regulations.

In the beginning, FAA form 8130-3 was used strictly for the purpose of exporting Class II and III new and/or Newly Overhauled products. The certification for export approval for these parts came from the FAA or an FAA designee (DAR). These Export Certificates of Airworthiness were and are required when we need to ship a Class II or Class III product that was New or Newly Overhauled to foreign customer. We would then call the local FAA or a DAR with whom we had established a relationship, and ask them to issue the 8130-3 certificate for the part(s). We then placed the 8130-3 certificate with the part and shipped it to the foreign customer.

That procedure remains the same today. However about 20 years ago or so the form was changed immensely to accommodate its new purpose, which is an approval of a product for return to service after maintenance.

The Beginning of the Changed 8130 Tag

When The FAA began the process of synchronizing with foreign governments, specifically European countries whose aviation was governed by the Joint Airworthiness Authorities (JAA), the harmonization effort was the beginning of the new FAA form 8130-3 Airworthiness Approval Tag. The thought behind this was that if implemented correctly, the form 8130-3 would serve the same purpose of the JAA Form 1. The idea was to give the new FAA form the same look and feel as the JAA form, thus creating an atmosphere of accord, between the FAA and the JAA, because the JAA Form 1 was the primary means of communicating the airworthiness status of parts within the European Community — and so began the reinvention of the 8130-3 form. Basically, although they changed a couple of terms, the FAA copied the JAA Form 1, and whadda ya know, an additional purpose for the 8130-3 form was developed as it now became a document of approval for a product’s return to service after maintenance, and thus replacing the venerable “Yellow Tag”.

I am sure that the FAA was really proud of their changes to the old 8130-3 form, because now this was truly a dual-purpose form. The new 8130-3 would not only be used to certify exported parts, it would also meet the 14 CFR Part 43 requirements for approval for return to service following maintenance, creating for the first time in the US a common approval for return to service form (tag) other than the Yellow Tag and the FAA Form 337. Of course, the 337 form could only be used for major repairs and major alterations. Good job guys; one dual-purpose form.

However, it is the intended multiple utility of the new 8130-3 tag that caused some confusion. The same form could now be used for two purposes. But neither of the two uses of the form could be performed or certified by the same person. The Export Certificate of Airworthiness or conformity certification was (is still) required to be completed by the FAA or a designee while the approval for return to service could be done by a repair station or properly certificated air carrier.

Now, while it’s not too confusing for those who can complete the form, it can be confusing to those who depend on the form for specific purposes. Here is a possible scenario. Let’s say that the 145 repair station for whom I work has a part that we overhauled and, as a repair station, issued an FAA form 8130-3 to certify the approval for return to service. The part is on the shelf and very clearly displays an FAA form 8130-3 airworthiness approval tag.
Next, we receive a request for that part from a company in France. Looking at the inventory on the computer, we tell the customer that indeed we have one in stock and can ship it today. Knowing that he needs an Export Certificate of Airworthiness, our French customer then asks, “Does the part have an 8130?”

“You bet,” we say, forgetting that his specific need is an Export 8130-3. We assure him that the part does come with an 8130-3 airworthiness approval tag. He then asks us to ship the part and, not only does it arrive in France without the correct Export Certificate of Airworthiness, but we have now added to international tensions.

The bottom line is that the 8130 has now become the end-all form. “Does it have an 8130?” is the question I am always asked, but having an 8130-3 tag is only the beginning. We must know why we need an 8130-3. Is it for the purpose of exporting a part, or is it only for the purpose of assuring that we are not getting a part that is unapproved?

The “new” 8130-3

Welcome to 2014 and the “New” 8130-3 form. Beginning 01-Feb-2014, 8130-3 form (06-1) has been officially replaced with 8130-3 form (02-14). Why the revised form? In July 2003 the European Aviation Safety Agency (EASA) was formed, absorbing all the European Aviation Agencies including the JAA.  EASA became the single agency for the safety of the entire EU Aviation community. EASA became fully functional in 2008. It was also about that time that the FAA and EASA began a quest to fully homogenize the aviation regulations globally. The result in 2012 was the agreement between the FAA and EASA called the Maintenance Annex Guide (MAG). This was to once again bring the two Aviation Regulatory Agencies more in harmony with regards to regulations.

For the sake of expediency (and space), listed below are the changes, block-by-block, needed to complete a maintenance release 8130-3.
I suggest you look up Order 8130-21H if you need information on how to use this form for its other purposes. Refer to the two 8130-3 forms which I have provided for ease of explanation (see graphics).

Okay, the first thing to remember is: always complete the 8130-1 using permanent ink and in English and as you know this is nothing new.

BLOCK 1: Approving Civil Aviation Authority
The change here is from “National” to “Civil”.

BLOCK 2: Authorized Release Certificate
No Change.
BLOCK 3: Form Tracking Number
Depending on your work order software, this number may be automatically assigned. If not, you need to establish a numbering system that is separate from your work order system. No Change.

BLOCK 4: Organization Name and Address
The organization name, address and pertinent company information you wish to put in this block. No change.
BLOCK 5: Work Order/Contract/Invoice number
Fill in the work order number, contract number, and/or invoice number related to this maintenance release.  If a work order/contract/invoice number is not available, enter N/A. This is a change in clarification for the information in Block 5.

BLOCK 6: Item
When the 8130-3 is issued a single item number or multiple item numbers (for example, same item with different serial numbers) may be used for the same part number. Multiple items must be numbered in sequence. For example: 001, 002, etc. If a separate listing is used, enter the “list Attached”. No Change.

BLOCK 7: Description
Enter the name or description of the product or article.  You should use the term or name used in the instructions for continued airworthiness or maintenance data. No Change.

BLOCK 8: Part Number
Enter each part number or the product or article. In the case of an aircraft engine or propeller, the model designation may be used. No Change.

BLOCK 9: Quantity
The change in this block is, remove the term “eligibility” and replace it with “Quantity”. Enter the quantity of each product or article shipped.

BLOCK 10: Serial Number
The change in this Block is the term “Quantity” is replaced with “Serial Number”. Enter serial number of the Part. If no serial number is applicable, then enter N/A.

BLOCK 11: Status/Work
The change in this Block is the term “Serial Batch/Number” which is replaced with “Status/Work”. The following table describes what to enter in a specific situation.  The Term entered in Block 11 should reflect the majority of the work performed by the organization.  (See graphic on page16)

BLOCK 12: Remarks
The change here is that the term “Status/Work” has now been replaced with “Remarks”, Block 13 has been replaced with Block 12. Describe the work identified in Block 11 and associated results necessary for the user or installer to determine the airworthiness of the product or article in relation to the work being certified. This can be done either directly or by reference to supporting documentation. If necessary, a separate sheet may be used and referenced from the main FAA Form 8130-3. Each statement must clearly identify which product or article in Block 6 it relates to.

 

The following are examples of conditions that could necessitate a statement in this block:

a) Data required by Part 43.9, including the reference and revision status. If the certificate holder to comply with Part 43.9 and 43.11 uses other documents, such as work orders, they must be specifically referenced in this block.
b) Compliance with AD’s or service bulletins
c) Repairs carried out
d) Modifications carried out
e) Replacement articles installed
f) Life-Limited parts status e.g. Total Time; Total Cycles; time since new
g) If a specific batch or lot number is used to control or trace the product or article, enter the batch or lot number in this block.
h) Deviations from the customer work order
i) Release statements to satisfy a CAA maintenance requirement
j) Information needed to support shipment with shortages or re-assembly after delivery
k) NOTE: As noted in (i) above Block 12 is also the location to place a statement about dual release against both part 43 and another CAA’s (EASA) approved maintenance requirement. However, care must be taken to check the relevant box(es) in Block 14a to validate the release. A dual release requires the approved data to be approved/accepted by both the FAA and the appropriate CAA.
l) When An authorized person from a PAH completes Blocks 14a through 14e and they have entered “See Block 12” in Block 11 one of the following statements will be entered in Block 12: “rebuilt to original PAH’s specifications” or “Altered to original PAH’s specifications.”

BLOCKS 13a through 13e: The conformity release signatures/approval and date
The changes here are these blocks replace blocks 14 through 18. When the 8130-3 is used as a maintenance release instrument these blocks are shaded or marked out to preclude inadvertent or unauthorized use.

BLOCKS 14a through 14e: The maintenance release signatures/approval and date
The changes here are these blocks replace blocks 19 through 23.
(Block 14a) must be checked in both boxes.
(Block 14b) is the authorized signature, and it must be manually applied at the time and place of issuance except as provided in paragraph 3-1j of Order 8130-21H.
(Block 14c) Enter your repair station, PAH or air carrier number.
(Block 14d) The typed or printed name of the authorized signatory
(Block 14e) The Date (The change here is the format.) This is the date on which the original work was completed and must be in the following format: two-digit day/ first three letters of the month/and four-digit year e.g. 03/feb/2014.  (The use of slashes, hyphens or spaces in the date does not matter.)

The final item that was revised is the Statement in the “User/Installer responsibilities. In the first sentence on form 02-14 the words “aircraft engine(s)/propeller(s)/article(s)”, replaced the words “parts/components/assemblies” on form 06-01. In the second sentence on form 02-14 the block numbers ‘13a and 14a’ replaced the block numbers ‘14 and 19’ on form 06-01.

Things to Watch For

Okay, you were in a hurry and sent the form with the part to a customer and he lets you know that there was a typo. What do you do? Well, don’t despair. Below is the procedure for fixing a “fat finger” mistake.

First the recipient of the incorrect form must request replacement in writing and return the incorrect form to you. You do not need to verify the serviceability of the article again. A corrected form may be honoured without re-verification of the article. The reissued 8130-3 is not a statement of current condition of the article and must reference the 8130-3 being corrected. In block 12 the following statement will be entered: “This FAA form 8130-3 corrects the error(s) in block(s) [enter block number(s) corrected] of the FAA form 8130-3 [enter form tracking number] dated [enter issuance date] and does not cover conformity or condition or release to service.”

Next, let’s talk about the customer who has lost their 8130-3—again, no problem here either. If a copy of an 8130-3 is requested, correlation must be established between the form and the applicable article. As the originator you must retain a copy of each form issued to allow verification of the original data. And, there is no restriction on the number of copies sent to the customer or retained by the originator. Obviously there are a few other things to be aware of in this 8130 minefield. First, know what the form can and is used for. Don’t become complacent with the use of 8130-3 tags. Get a copy of “FAA order 8130.21H Procedures for Completion and Use of FAA Form 8130-3, Airworthiness Approval Tag”. Look through it and keep it handy if you are in the parts side of the business so that you can refer to it.

Next, review the signatures. Look at each 8130-3. Signatures on the left side of the form must be that of the FAA or an FAA designee. Those on the right must be that of an FAA repair station or an air carrier (in certain cases).

And finally, if a repair station or air carrier has signed the right side, be sure they hold the appropriate ratings for the maintenance for which they are signing. I have found that some repair stations think that they can use an 8130-3 to signify “removed serviceable”. Although “removed serviceable” is an appropriate statement, the method used to determine the parts serviceability must be included AND the repair station must be rated to perform those methods.

Manufacturers and Repair Stations

An FAA form 8130-3 received with a new part from the manufacturer (Rolls-Royce, Pratt & Whitney, Bell Helicopters) is considered proof, and documents that the part came from the manufacturer—the same as a letterhead packing slip with a conformity statement. In this case, the certification is for the benefit of the receiver of the part (repair station) more than the owner of the repaired aircraft, and a copy should be kept with the original purchase order.

An FAA Form 8130-3 received from a repair station as approval for return to service with the part should first be scrutinized to ensure the repair station is authorized to sign for the approval for return to service, then the airworthiness approval tag should become a part of the aircraft permanent records as required by 14 CFR Part 91.417.

And there you have it, my faithful students: the explanation of the new 8130-3. I would go to the FAA website (http://www.faa.gov/regulations_policies/orders_notices/) and get a copy of the order 8130-21H as I have suggested and keep it handy. Now go forth, confident that you will not be intimidated by the new 8130-3 form.

About The Author

Mike Broderick

Mike Broderick is V.P. of Business Development at Helicopter Engine Repair Overhaul Services (HEROS). Over the past 35 years, he has served as a shop technician, engine shop supervisor, Engine Program Director, Director of Maintenance, Director of Operations, and owner of a Rolls-Royce engine overhaul and MD Helicopter component overhaul shop. He is a certified A&P, and holds a Bachelor of Science degree in Aviation Administration. As well, Mike has been appointed as an FAA representative for the FAA Safety Team (FAAST) and is a member of the HAI Tech Committee. Mike is a regular contributor to Air Maintenance Update.

View all articles by Mike Broderick.