Welcome back to our second session on aviation terms. And since I know I wore you out with a bit of information overload last time, where better to start than with the definition of fatigue failure? Enjoy.
Fatigue failure is defined as the progressive and localized structural damage that occurs when a material is subjected to repeated or fluctuating loads (cyclic loading). And for good measure here are some cute, one liner acronyms. Test yourself to see how many you really know.
EGPWS: Enhanced ground proximity warning systems
HTAWS: Helicopter terrain awareness and warning systems
IFR: Instrument flight rules (or if you are an ag helicopter pilot, I follow roads)
VFR: Visual flight rules
Taxiway: A road leading from the airplane parking area to the runway, always marked with yellow lines.
Traffic pattern: The traffic flow that is prescribed for aircraft landing at, taxing on, or taking off from an airfield.
ZULU: Greenwich Mean Time (GMT) also known as Universal Coordinated Time.
OK, had enough? Some great cocktail knowledge in that group right? And, you have my permission to use all of this CK as you see fit. So, let’s end our discussion today with a review of the now most widely used FAA form today, the FAA form 8130-3, and clear up some of some possible confusion as to its use.
FAA Form 8130-3
The FAA’s current description/definition of the airworthiness approval tag is found in AC (Advisory Circular) 20-62D under Section 7, Paragraph a. FAA form 8130-3, Airworthiness Approval Tag, identifies 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 an approved Continuous Airworthiness Maintenance Program under Part 135.
As you can see from this definition, the form has two distinct purposes:
1. It is used to approve or certify that new and used parts meet conformity requirements from the original airworthiness side of the FAA.
2. It is also used to certify approval for return to service following maintenance from the recurrent airworthiness side of the FAA.
Functions of Form 8130-3
Since the early 1990s when the form was revised to meet both these purposes, there has been some confusion about who is authorized to use the form and what the form actually signifies when it is received. The purpose of this article is to clarify the two distinct functions of FAA Form 8130-3 and identify what you should look for to determine its intended use.
The Original 8130 Form
To start with, it is important to provide a definition. 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 products by 14 CFR Part 21.321, which has 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.
Back in the old days, FAA form 8130-3 was used strictly for the purpose of exporting Class II and III parts. The certification for export approval for these parts came from the FAA or an FAA designee (DAR). These Export Certificates of Airworthiness were needed when a foreign customer called and asked us to ship a Class II or Class III part. We would then call the local FAA or a DAR with which 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 has not changed much. However, the form has changed immensely and its purpose has become a bit more complex.
(5) The beginning of the new 8130 tag
Some time about 10 to 12 years ago the FAA began the process of synchronizing with foreign governments, specifically European countries whose aviation is governed by the Joint Airworthiness Authorities (JAA). This 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, creating some form of harmony. It seemed that JAA Form 1 had become the primary means of communicating the airworthiness status of parts within the European Community. The FAA, not wanting to create more philosophical distance between themselves and their European counterpart, was looking for an instrument to create some commonality with the JAA. Thus began the reinvention of the venerable 8130-3 form. Basically, although they changed a couple of terms, they copied the JAA Form 1, and whad’ya know: a new 8130-3 form was developed.
I am sure that the FAA was really proud of their changes to the old 8130-3 form. 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 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. It’s not a bad thing to have the same form 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 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. Perhaps not knowing his specific need, 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 the part arrive in France without the correct Export Certificate of Airworthiness, but, sacre bleu, 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?
(6) Things to watch
Obviously there are a few 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 8130.21B 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 when questions come up.
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.
(7) 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.
(8) The Source
l FAA Order 8130.21B “Procedures For Completion and Use of FAA Form 8130-3, Airworthiness Approval Tag.”
l Advisory Circular AC 20-62D “Eligibility, Quality, and Identification of Aeronautical Replacement Parts”
So my faithful students, once again we are at the end of our training session for the day. Hopefully, you learned some interesting and new facts about the terms and acronyms we use on a daily basis. And once again I urge you to use the preceding CK to the best of your ability.
Finally, remember even the best pilot can’t fly until you say it is ok to fly
About The Author
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.