FAA Form 8130-3 Airworthiness Approval Tag
What does it really mean?
By Joe Hertzler
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. 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 1990’s 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 of 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.
The advent of the "new" 8130 tag
It was about 12 years ago that the FAA started trying to "harmonize" with the foreign governments — specifically the European countries, whose aviation is governed by the Joint Airworthiness Authorities (JAA). This harmonization effort spawned the advent of the "new" FAA form 8130-3 Airworthiness Approval Tag. The idea I think was that if done correctly, it would serve much 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, I guess. It seemed that JAA Form 1 had become the primary means of communicating the airworthiness status of parts within the European Community. The FAA didn’t want to reinvent the wheel and was looking for some vehicle to show a desire to create some commonality with the JAA. So, they took the JAA form, copied it, changed a couple of terms on it and used that form to replace the old export form 8130-3.
I’m sure the FAA thought the new form would be better than the old 8130-3 form. It 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 U.S., 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.
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 bad in itself to have the same form for two purposes; however, 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.
Obviously, it’s not too confusing for those who can complete the form. It’s confusing to those of us who depend on the form for specific purposes.
For example, Let’s say that as a repair station we receive a part that has been overhauled by an FAA certificated repair station and that repair station issued an FAA form 8130-3 to certify their 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 Germany. 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, the German client then asks, "Does the part have an 8130?". Asking the client to hold, we run down to find the part and look to see if it has an 8130. Getting back to the customer and 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 the part arrives in Germany without the correct Export certificate of airworthiness.
The bottom line, the 8130 has unfortunately become the answer all. So much of the time I hear, "Does it have an 8130?" when having an 8130-3 tag is only the beginning. In order to ask that question, 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?
Traps to avoid
Obviously there are a few traps to be aware of in this 8130 arena.
Know its uses - 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.
Check 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).
If a repair station or air carrier has signed the right side, they must hold the appropriate ratings for the maintenance they are signing off. Some repair stations think that they can use an 8130-3 to signify "removed serviceable." Removed serviceable is an appropriate statement; but, 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 (i.e. Cessna, Raytheon, Learjet), is proof and documentation that the part came from the manufacturer, much like 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.
FAA Order 8130.21B "Procedures For Completion and Use of FAA Form 8130-3, Airworthiness Approval Tag.
Advisory Circular AC 20-62D "Eligibility, Quality, and Identification of Aeronautical Replacement Parts"
14 CFR Part 21 Subpart L "Export Airworthiness Approvals"
FAA Order 8130.2D "Airworthiness Certification of Aircraft and Related Products"