The Tag: Reviewing FAA Order 8130.21C

The last time I wrote about the 8130.3 Airworthiness Approval Tag was nine years ago when it first came into existence. Since then, the original FAA Order 8130.21 that created the tag, has been revised three times. This is why the current Order 8130.21C has the suffix letter C on the tail end. To review the current FAA Order including change 1 in detail you can log on to http://av-info.faa.gov/dst/8130.21CCh1.pdf.

One of the "C" revisions was to hang a new title on the tag. It is now called "Authorized Release Certificate, FAA Form 8130-3, Airworthiness Approval Tag." Another change created by the "C" revision is the cancellation of the old 8130-3 Form, dated November 1993 and it is replaced with a new 8130-3 form. You can take a look at the new tag by logging on to http://www.specson-line.com/faa/8130-3.doc.

After June 1, 2002 you must use the new 8130-3 form, but if you have a part on the shelf that was issued a —3 tag prior to June 1, 2002 the tag is still good. You can order the new —3 tag from Customer Care Center, AML-30 in Oklahoma City at (405) 954-3793 or toll free at 1 (888) 322-9824. The new form’s stock number is 0052-00-012-9005. With that said let’s take a look at the new "revised" form.

Overview:

The 8130.3 Airworthiness Approval Tag is basically a record-keeping device that declares that the identified product, part, or appliance is airworthy. The tag is not an authorization to install the part! In the early ’90s, the tag creators had high hopes that it would be a universal airworthiness tag, an aviation document that would be recognized worldwide at face value. Alas, it was not to be. This lack of universal acceptance is because there are many big and small regulatory differences between us and other civil aviation authorities on this ball of dust we call home. Plus, we have not achieved the level of trust among all nations to make this concept work. So as of this date we have not achieved the hoped for "universal status" for the 8130-3 tag.

However, there has been some progress made in the harmonization process in the past nine years with Europe and Canadian CAAs and the 8130.3 tag can be used to document:

1. Conformity determinations.

2. Airworthiness approval of aircraft engines and propellers for domestic shipments only.

3. Airworthiness approval of parts and appliances under Part 21 Certification Procedures for Products and Parts.

4. Splitting bulk shipments of previously shipped parts.

5. Approval for return to service after maintenance, preventive maintenance, rebuilding, and alterations.

6. Export airworthiness approvals of Class II and III products.

With the exception of item 6, Export airworthiness approvals of Class II and III products, the FAA considers the use of the 8130.3 tag as an "optional" form of record-keeping. Before we review the six uses of the tag, there are some things you should know about the tag itself. First, the tag can be made smaller but not so small that it cannot be read and the overall design of the form and its wording cannot be revised or altered in any way. Second, using an electronic signature may be authorized by the FAA, however an electronic signature does not relieve the responsible individual from ensuring that the part or product described on the tag is airworthy. Third, the tag’s blocks 14 through 18 are used for conformity determinations, airworthiness approval of products/parts, export airworthiness approvals, and splitting bulk shipments of parts. Block 19 through 23 of the tag are used for approval for return to service. Do not put any information in both the airworthiness section (14-18 blocks) and approval for return to service blocks (19-23) or the tag will self-destruct.

Conformity determinations:

The 8130.3 tag may be used to record conformity inspections made by or on the behalf of the FAA on a prototype or test product, part, or appliance prior to type certification to determine that it conforms to the specified data. As a mechanic working for a repair station or an air carrier chances are you might spend your entire career without seeing a 8130-3 tag used for this purpose.

Airworthiness approval of new products, parts, and appliances

Production Approval Holders (PAH) can use 8130.3 tag to identify their Class II (turbine blades, actuators, pumps, fairing, etc.) parts and Class III (rivets, fasteners, etc.) parts. The tag can also be used for shipping bulk shipments. For example a PAH that is shipping 1,000 O-rings to a repair station can use only one 8130.3 tag instead of killing a couple of trees to make a thousand tags. In a policy change the FAA will allow PAH to use the tag to ship new Class I parts (engines and propellers) that are produced and located in the United States and shipped to destinations within the United States.

If the PAH wanted to ship Class I products overseas it still has to use the FAA Form 8130-4 Form Export Certificate of Airworthiness and meet the requirements of the importing country referenced in AC 21-2 Export Airworthiness Approval Procedures.

Splitting bulk shipments of previously shipped parts

Only the following individuals are authorized to split bulk shipments into smaller lots: PAH, or PAH approved suppliers, or PAH associate facilities such as PAH distribution centers, or PAH that employ a Designated Airworthiness Representative (DAR), a Designated Manufacturing Inspection Representative (DMIR), or a person authorized under an Organizational Designated Airworthiness Representative (ODAR) and finally a Designated Option Authorization (DOA). When a shipment is split, say from 1,000 units to 10 units, a new tag called a supplemental Form 8130-3 is generated. The supplemental tag may be used to issued parts within the United States or at a facility located in another country. In Block 13 Remarks, you must see the words: SUPPLEMENTAL SHIPMENT in capital letters. Any time you get a split shipment the supplemental tag must be attached to a copy of the original 8130.3 tag in order to ensure traceability of the part(s).

Approval for return to service of products and parts

This is where domestic and foreign FAA Repair Stations, and both 121 and 135 Air Carriers operators can use the tag to "approve for return to service" aircraft, products, and parts that have undergone maintenance, preventive maintenance, rebuilding, or alterations. When the tag is used for this purpose you can only use the acceptable words: "overhauled," "inspected," "repaired," "rebuilt," "altered," or "modified" in tag’s Block 12 (Status/Work). Some of you sharp-eyed English majors probably noticed one of the tag’s acceptable terms "modified" is very similar in meaning to another acceptable word "altered" but the tag creators would like "modified" to be used to identify work performed in compliance with Airworthiness Directives, or manufacturer’s Service Bulletins rather than to identify an STC or a field approval alteration. Aviation shorthand terms like "New Surplus," or "OHV" are not to be used in Block 12 because they do not match the language in the FARs.

The tag can also be used to identify new unused products and parts. However, you must first inspect the part in accordance with your air carrier or repair station’s quality control system and when it is determined that the part is airworthy you can put the word "inspected," in Block 12. Do not use the word "new." Only PAH of the part can put the word "new" in Block 12. However, in Block 13 remarks section you can identify the part as new.

Another use of the tag is for the identification of used parts that have been removed from one U.S. registered aircraft for installation on another U.S. registered aircraft. The tag can be used as long as the removal and installation is done in accordance with the repair station’s or air carrier’s manual and a determination is made that the part is airworthy. This airworthiness determination includes a statement that all the ADs are complied with, total time/cycles are within limits, and any modifications or changes to the part are identified.

Export Airworthiness Approval of Class II and Class III products

The tag can be used to export Class II and Class III products. Persons authorized to perform export functions are: The FAA, DARs, DMIRs, or persons authorized under the DOA, or the PAH’s ODAR. Class II products must be identified with the manufacturer’s name, part number, model, and serial number designation when applicable or equivalent such as lot numbers, batch numbers, work order numbers, etc. The word "Export" is not mandatory to be entered in Block 13 of the tag. However, it still remains the exporter’s responsibility to meet the special import requirements of the country to which the part is being shipped. Again most countries’ import requirements are found in AC 21-2 Export Airworthiness Approval Procedures.

You lost the tag, what can you do?

In order to get a replacement FAA form 8130-3 tag for parts that were not exported, a new tag may be reissued by the PAH’s designee, air agency, or air carrier who issued the original one but only after "re-verification" that the part’s status is the same as when the original tag was issued. The term "re-verification" in the FAA Order means the same process it took to confirm that the original part was airworthy.

In order to replace a tag for a part or product that has been exported, the foreign importer must provide a written statement to the original exporter that the 8130-3 tag has been lost and provide evidence that the part is identical to the one identified on the original 8130-3 tag.

Now that I have armed you with knowledge and power, get out there and tag something! AMT

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