Additional Guidance Concerning FAA Form 8130-3

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Sofema Online (SOL) www.sofemaonline.com looks at some of the common questions associated with the use of FAA 8130-3.

Introduction - Does the 8130-3 Guidance Seem Confusing?

8130-3 was not designed to be solely a return-to-service document for use in complying with 14 CFR 43.9. Its other uses include export airworthiness approvals of Class II and Class III products; conformity determinations; identifying the airworthiness approval status of products (engines and propellers) in domestic transactions; airworthiness approval of parts and appliances under 14 CFR 21.305; and splitting bulk shipments of previously shipped parts.

When the agency released its original clarification in April, it established that the statements “domestic shipment only” or “not for export approval” are not required anywhere on FAA Form 8130-3. However, the new memorandum indicates that some designees continue to require those statements on the form.

The new policy reaffirms that the statements are not required in Block 12 and instead cause confusion. The FAA mandates that those authorized to issue FAA Form 8130-3 not add “domestic shipment only” or “not an export approval” to Block 12 of FAA Form 8130-3. The agency also noted that future revisions of FAA Order 8130.21 would incorporate this clarification.

Note concerning “not for export & Domestic use only” - The new guidance is clear: “Domestic Shipment Only” or “Not for Export” statements are no longer required anywhere on FAA Form 8130-3.

What is a dual release 8130?

The FAA Form 8130-3 comes in single release and dual release versions. The single release form is for domestic use only. The dual release is needed to meet both FAA and EASA requirements, provided that the part in question is assessed and approved under both regulations.

Usage Considerations

It should not hopefully cause you too much confusion In fact the form has multiple purposes:

» The form may constitute a statement from the FAA that a new product or article produced under Title 14 of the Code of Federal Regulations (14 CFR) part 21, Certification Procedures for Products and Parts, conforms to its design and is in a condition for safe operation.
» The form may be used to return to service a used product or article following inspection, maintenance, or alteration.
» The form may be used when exporting products or articles to meet the requirements of bilateral agreements between the United States and other countries. This includes the shipment, not the export, of a prototype product or article to another country.
» In all cases, the form is used to promote the identification and traceability of products and articles throughout the global aviation system. It is important to point out that the FAA only issues this form for products and articles under its jurisdiction. 

Who is able to Use Form 8130-3

In addition to repair stations, a variety of persons are authorized to use the form, such as:

»  Part 121 air carriers,
»  Part 135 air operators,
»  Part 21 production approval holders (PAHs);
»  Designated airworthiness representatives (DARs);
»  Designated manufacturing inspection representatives (DMIRs);
»  and designated alteration stations (DASs).

The provided guidance materials (in Particular 8130-21H) explaining how the 8130-3 should be completed contain a good deal of information that does not apply to repair stations returning a product or part to service following maintenance, preventive maintenance, rebuilding or alteration.

Like any FAA Order, is not legally binding on members of the public, it nevertheless sets forth standards that some customers regard as the best way to avoid possible interpretation problems down the road when dealing with the FAA.

Thus, a repair station’s customers may specify that the repair station complete the 8130-3 exactly as shown in 8130.21H.

Next Steps

 Sofema Aviation Services (www.sassofia.com) and Sofema Online (www.sofemaonline.com) offer Classroom, Webinar and Online Regulatory Compliant & Vocational Short courses related to EASA and FAA regulations – please see the website or email team@sassofia.com

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