Jason Dickstein, president of the Washington Aviation Group, explores the evolution of airworthiness documentation for aircraft parts.

Records play an important role in identifying aircraft parts and the condition of those parts.

The EASA system was established in Europe a little more than 20 years ago and the EASA system has always relied on documentation. Their system requires production approval holders to issue EASA Form 1 as a record of the release from the approved production system.

Because of legal standards that preclude the release of such parts unless they are found to conform to the approved design, the EASA Form 1 becomes a de facto assertion of airworthiness. The EASA system requires Part 145 organisations to look for and receive the EASA Form 1 as a record of the prior release from the approved system, but the document also records a prior safety finding that supports airworthiness within the system.

The US system relies on different traditions. It requires a finding of airworthiness prior to releasing a part from a production approval holder’s quality system, although that did not traditionally need to be documented. Repair stations and other installers could obtain an undocumented part and install it because their obligation was to confirm airworthiness for installation.

They were able to accomplish this confirmation through a variety of approaches, including inspection and assessment of parts to confirm their airworthiness based on their physical characteristics. They also relied on different forms of documentation that showed the part had come from a production approval holder (relying on the rules that required production approval holders to confirm airworthiness before releasing such a part from their quality assurance system).

In the 1980s there were concerns about suspected unapproved parts. Documentation became even more important as a means of identifying parts in order to distinguish the ‘good parts’ from the ‘bad parts’.

As the desire for documentation of such findings grew, manufacturers provided a variety of records, such as certificates of conformity, to verify that the manufacturer had made the appropriate safety findings with respect to the aircraft part.

In the 1990s, the US system began to standardise around the 8130-3 tag as a normal way of documenting a safety finding related to an aircraft part. One important factor in this was the work of Bill Tipton from Northwest Air Lines who actively promoted the use of the 8130-3 tag as a standard way of documenting airworthiness.

The history of the modern 8130-3 TAG

In cooperation with Bill Tipton and other industry leaders, we worked with the FAA to promote increased use of the 8130-3 tag. One of the problems in those days was that the FAA did not anticipate how widely used this form would be.

The 8130-3 tag started life as an export tag (originally called the FAA Form 186). The regulation that authorised it was originally proposed to allow the tag only for aircraft, engines, propellers, major assemblies (such as complete wing assemblies) and TSO articles.

Parts were specifically excluded from the proposed rule for export airworthiness tags. However, one manufacturer foresaw that it might get asked for such tags in the future and asked for the rule to permit the issue of these tags for piece parts as well. In response, the FAA added the ability for manufacturers to request the tag for parts.

In the early 1990s, the FAA began to sign significant bilateral agreements with their foreign trading partners in which they pledged to provide 8130-3 tags for exported aircraft parts in order to document the airworthiness of those parts. This quickly became a problem because non-manufacturer exporters were not allowed to apply for the 8130‑3 export tag.

This was recognised by the FAA as a problem. They also recognised that rulemaking takes time – too much time to quickly solve the problem. In order to achieve a quick solution, the FAA created a policy-based 8130-3 tag that they called the ‘domestic 8130-3 tag’. The difference between the traditional export 8130-3 tag and the new domestic 8130-3 tag was a technical difference that did not create a real distinction. Both tags required a finding of airworthiness (meets FAA approved data and is in a current condition for safe operation).

As a matter of policy though, the FAA required that designees could not issue the export 8130-3 tag without first finding that the part was in conformity with the special import provisions of the importing country. This was not a real distinction because, 25 years ago, there were not any special import conditions that applied to parts (only to full engines and full aircraft). The FAA recognised that there was domestic value in being able to use the 8130-3 tag as a record that documents the airworthiness of the part.

The FAA issued a series of ‘notices’ that permitted 8130-3 tags for domestic airworthiness approval purposes. These notices specifically allowed distributors to obtain the tags from designees upon a showing of airworthiness, which could be verified by showing that the part was issued by a production approval holder and the airworthiness of the part had not been compromised since this PAH release.

As the 8130-3 tag became more popular, the domestic tag became more important as a traceability support record. In order to reduce any perceived distinctions between the ‘export tag’ and the ‘domestic tag’, in 2003 the FAA removed the requirement to place the word ‘export’ on the export tag.

This made the two different versions look the same, thus moving toward the FAA’s end goal of having one tag (the 8130-3 tag) that uniformly would document airworthiness.

For parts coming from the US, nations that have a bilateral agreement with the US typically expect an 8130-3 tag to accompany the part as an airworthiness record. This has caused the FAA to try to streamline 8130-3 tag policies to make the forms available when airworthiness situations make the part eligible.

The FAA’s efforts to remove the guidance that required the word ‘export’ was not entirely successful, and requirements to add this language slipped into various guidance documents over the years (and were then subsequently removed). Finally, in 2016, the FAA sent policy letters to all of the US trading partners explaining that the 8130-3 tag would no longer distinguish between domestic and export tags, and that instead the US would issue a uniform tag designed to meet both purposes.

As a matter of US policy, the export distinction language would be forbidden from 8130-3 tags. The FAA also issued domestic policy memos in support of this limit. Despite the fact that FAA policy now forbids language that distinguishes a form as being an export form, or that limits the destination to only one location, such language is still used by some persons in violation of FAA policy.

Where does the 8130-3 TAG come from?

There are several ways that an 8130‑3 tag can be issued in the US today. The tag was originally issued by the FAA, and qualified FAA employees are still able to issue the tag to identify demonstrably airworthy aircraft parts. Because this is often a mistrial task, the FAA frequently delegates the task of issuing the 8130-3 tag to FAA designees. This is permitted under US federal law, which allows the FAA to delegate issue of certificates a well as the findings that lead to such issue.

FAA has delegated the authority to issue 8130-3 tags to Designated Airworthiness Representatives (DARs) and Designated Manufacturing Inspection Representatives (DMIRs). Before 2015, manufacturers that wanted to use the tags as ‘birth records’ for their parts were required to have FAA designees on-site in order to issue those tags.

Since 2015, production approval holders have been able to issue 8130‑3 tags for their new parts under their own production approval system. This privilege is available to holders of PMA, TSOA and/or a production certificate. This is authorised under 14 C.F.R. § 21.137(o). It is an option for manufacturers; it is not a requirement, so some manufacturers may choose not to issue the tag.

This brings us back to the FAA’s designee programme. When new aircraft parts are intended to be exported, the FAA issues 8130-3 tags as export airworthiness records. They do this through a designee. The designee is required to ensure that the aircraft part was produced under an FAA production approval like a PMA, TSOA or PC. This establishes a baseline for airworthiness. Then the designee is required to confirm that the aircraft part has not suffered damage or degradation since being released from the production approval holder’s quality system. This establishes that the part has not varied from its original baseline of airworthiness.

A few years ago, Japan changed its rules to require documentation on all parts. This is similar to the EASA approach. For parts coming from the US, Japan requires that standard parts, chemicals and materials be accompanied by a certificate of conformity or equivalent. This certificate should be issued by the manufacturer. Other new parts, including those described in the illustrated parts catalogue or maintenance manual, should be accompanied by an airworthiness approval (e.g. 8130‑3 tag from the US, EASA Form 1 from the EU, etc).

In Japan, the rules require that for parts that have been subjected to maintenance work, the maintenance work should be documented (e.g. JCAB form for work done under JCAB Part 145, 8130-3 tag for work accomplished by an FAA Part 145, EASA Form 1 for work performed by an AEA 145, etc). This sort of policy reflects a modern trend of reliance on documentation as a means of recording airworthiness determination upon which installers (and others) might rely.

This feature was first published in MRO Management – May/June 2024. To read the magazine in full, click here.