FAA Feedback: The Yellow Tag

Oct. 7, 2014
The yellow tag doesn’t tell you what approved data was used, what ADs were done, what standards were met, what parts were replaced, what service bulletins or letters were complied with, or what total time was on the propeller or engine

A question often asked as I travel around the country giving safety seminars is: Does a yellow tag satisfy the requirements of a maintenance release?

You must first understand that there’s no legal definition of a yellow tag. Regardless of the fact that there are logbooks out there that are full of them, the term “yellow tag” isn’t mentioned anywhere in FAR Part 43.

Yellow tags were first used by the Army Air Corps back in the early days of World War II. No reason was given why the color yellow was picked to indicate a serviceable component. Most of us would have picked the color green for serviceable and yellow for repairable – not the other way around.

I suspect, based on my own military experience, that the decision to use yellow for serviceable parts was probably made by an Army supply clerk who ordered a million yellow tags by mistake and had to find a use for them or be shipped to a combat area.

Regardless, after the war, the airlines stayed with the military tradition of using yellow tags as a serviceable item. Following their lead, the rest of general aviation bought in – and yellow tags became part of aviation terminology and culture.

So what’s the problem with using a yellow tag as a maintenance release?

The yellow tag only satisfies half of the requirements for a maintenance release under Part 43, Appendix B, and many repair stations are sending only this document along with a repaired component. On one side of the tag, they identify the part and use single words like “repaired” or “overhauled” that are one-word descriptions of all the work accomplished. On the other side of the tag, they put the maintenance release statement. The work order with all its important information isn’t sent and the technician is left holding the bag because he has no idea of what’s happened to the component.

The yellow tag doesn’t tell you what approved data was used, what Airworthiness Directives (AD) were done, what standards were met, what parts were replaced, what service bulletins or letters were complied with, or what total time was on the propeller or engine. The only thing a yellow tag tells you is that you’ve got a great big hole in your record keeping.

The “yellow tag – only” repair stations defend their position by hiding behind the maintenance release statement that says “all pertinent details are on file at the repair station under a work order number______.” That’s great, but if the repair station goes out of business, the records may no longer be available. And even if it’s still in business, a repair station is only required to keep their records for a period of two years! Some repair stations “lose” their records after two years to avoid liability issues.

Here are a few things that you should keep in mind regarding maintenance releases:

  • A maintenance release is a document that only a certificated Part 145 repair station can use in lieu of FAA Form 337.
  • A maintenance release is used to identify only major repairs to an aviation component(s). They are not to be used to identify minor repairs, or minor or major alterations.
  • A maintenance release is a two-part document. The first part is the work order. It must be signed, dated, have a description of the work performed (e.g. service bulletins, ADs, repairs accomplished, etc.) and the approved data used for the major repair. The second part is called the maintenance release statement. It must be signed by an authorized representative of the repair station.
  • The maintenance release must have the following information:

- Identification of the airframe, engine, propeller or appliance worked on.

- If an aircraft, it must include: the registration number, make, model, serial number and the area repaired must be listed.

- If an airframe, engine, propeller or appliance it must include: the manufacturer’s name, name of the part, and model and serial numbers if any must be listed.

- The following or similarly worded statement must be included: “The aircraft, airframe, aircraft engine, propeller or appliance identified above was repaired and inspected in accordance with the current Regulation of the Federal Aviation Administration and is approved for return to service. Pertinent details of the repair station under Order No. _____Date _____ Signed______ (authorized representative for the repair station). Repair station address and certificate number ________.

• The maintenance release statement and required information don’t have to be on a yellow tag. They can be stamped or printed on the repair station work order. Here are a few suggestions for dealing with repair stations that don’t provide a thorough maintenance release.

• Make sure the repair station has all the information it needs. When you send in a component for repair/overhaul on your work order request, give the repair station all the required information on the part such as make, model, serial number, total time/cycles, history, etc.

• Formally request a maintenance release as required by FAR Part 43, Appendix B. State very clearly on your work request, “No complete maintenance release – no payment.”

• When you want an engine or propeller overhauled, tell the repair station that you want its maintenance release to show the total time since new and total time since overhaul.

• If the repair station won’t comply with the above, ask for a FAA Form 337 for the major repair instead.

• If you have continuing problems trying to get both parts of the maintenance release or the Form 337 from the repair station, notify the Flight Standards District Office in charge of that repair station to assist you.

If you still have problems – look elsewhere. Loss of a customer base will bring the repair station around to the correct way of doing business.

This article originally appeared in the September/October 1991 issue of Aircraft Technician

About the Author

Bill O'Brien