April 14, 2010. The first effective date for the new Part 21 rules. It’s a date that many FAA employees have been toiling towards – readying Advisory Circulars and orders so that the industry would be able to use the guidance when the rule becomes effective.
With all of this activity, it is a welcome relief to see that the distribution industry has not been forgotten.
Order 8130.21G was revised to reflect the changes in the new regulations. One of those changes was the removal of distributors from the list of permissible parties who could apply for domestic 8130-3 tags. This was a concern because under FAA order 8100.8C designees are only permitted to issue domestic 8130-3 tags for parts held by distributors in accordance with the instructions published in Order 8130.21. So we neeedd to have instructions in Order 8130.21G, or else DARs might not be permitted to issue domestic 8130-3 tags for demonstrably airworthy aircraft parts.
We met with senior officials from the Aircraft Certification Service to discuss this matter. The senior officials promised that the issue would be addressed. And they kept their promise. On the same day that the “G” revision became effective, the FAA issued a “Change One” that returned distributors to the list of parties qualified to apply for 8130-3 tags under paragraph 2-5 of order 8130.21G.