FAA 8130-3: Making Export Tags Look Like Domestic Tags


The FAA really is trying to make it easier for industry to use safe aircraft parts. I have been writing blog articles about the FAA’s problems with the 8130-3 (Airworthiness Approval Tag), but relatively little press has been given to the FAA’s efforts to make the 8130-3 tags better. A recent policy memo from the FAA actually removes unnecessary distinctions and makes it easier to use the 8130-3 tag in parts transactions.

On June 28 the FAA issued a policy memo (AIR100-16-110-PM04) that forbade parties from stating ‘domestic shipment only’ or “not an export approval” on the 8130-3 tag:
“This memorandum provides clarification on the use of ‘domestic shipment only’ and ‘not an export approval’ in block 12 of FAA Form 8130-3 (hereafter, tags). Inspectors, designees, delegated organizations, and persons authorized in accordance with a production approval holder’s approved quality system to issue tags are directed to not add ‘domestic shipment only’ and ‘not an export approval’ to block 12.”

This export-specific language tended to impede subsequent exports.  Many people mistakenly thought that this language was meant to prevent a subsequent export. The FAA has removed the export-specific language because it found that the language impeded commerce without adding any safety value.

Use of this sort of export-specific language ignored the original purpose of the ‘domestic tag.’  It was originally meant to create a kludge that made 8130-3 tags available to exporters – at a time when the regulations limited access to the traditional export tag.  It was called a ‘domestic’ tag because it only certified compliance to domestic US standards, and not to any special import requirements of an importing nation.

Years ago, exporters (who were not the manufacturer) were unable to obtain an export tag for parts. The reason for this began in 1963, when the FAA published a Notice of Proposed Rulemaking (NPRM) to establish the rules for export airworthiness approvals (Subpart L of 14 C.F.R. Part 21).   They classified the world of aircraft assets into three classes:
(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;
(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.

This three-part distinction can be found today in older versions of the Code of Federal Regulations.  But this distinction no longer exists in the modern regulations.

The original 1963 NPRM (Nnotice of Propose Rule Making) suggested that export airworthiness approvals would be available for Class I and Class II products. It explained that export airworthiness approvals would not be necessary for Class III products, and that exporters could self-certify airworthiness with respect to those units.   This dramatically limited the impact of the proposed rule, because most articles fell into class III.

During the comment period for this new rule, a manufacturer wrote to the FAA and said that it could foresee a possible need in the future to apply for Class III export airworthiness approvals for its own articles.  The stated purpose of the rule was to facilitate trade, so when the Final Rule was published in 1964, the FAA added a clause stating that manufacturers could also apply for Class III export airworthiness approvals in order to meet the request of the commenter.  No one was asking for these tags for piece-parts, so there was no objection to the additional permission.

Airlines for America Nondestructive Testing Forum: Uniting in the Name of Safety


The corporate climate is highly competitive, the competition fierce; best your competitors or be bested. Narrow margins between profit and loss, urgent deadlines to meet, and logistics are all challenges that corporations face. Perhaps nowhere is this truer than in the airline industry. There is one venue, however, where the airlines put aside their competitiveness in the name of safety: The Airlines 4 America (A4A) Nondestructive Testing (NDT) Forum.

The A4A NDT Forum enables NDT professionals and industry leaders to meet each year and discuss current trends, issues and successes in NDT methodologies. The Forum draws participants from various disciplines, including equipment designers, technicians, vendors, regulatory authorities, Original Equipment Manufacturers (OEMs), Maintenance and Repair Organizations (MROs) and airline personnel. The Forum exhibit hall features displays, including the latest NDT and related equipment, processes and services.

NDT plays a huge role in the safety of commercial and general aviation. Throughout an aircraft’s life, there is the potential for damage from numerous sources including: bird strike, hail, runway debris, lightning, ground service equipment (GSE), incursions with other aircraft, and fatigue damage from repetitive loads from normal operation. The role of the inspector is first to determine if there is damage from an event and, if there is damage, to determine the severity of the damage by sizing it. This information can then be used by structural analysis engineers, who use tools like Finite Element Modelling (FEM), to determine the residual strength of the structure. The extent of the damage will determine whether the part needs to be repaired or replaced. NDT even plays a role in making sure the repair is done properly. Regardless of the decision that is made of whether to repair or replace or to bolt or to bond, the airplane must still meet the Federal Aviation Regulations (FARs) in order to be considered airworthy. For example, in the United States, Title 14 (Aeronautics and Space) CFR Part 25 (Airworthiness Standards, Transport Category Airplanes) Subpart C (Structure) contains the regulations that set forth the standard for an aircraft’s ability to withstand the loads (forces) that it will experience in flight.

There are many tools that an inspector has available to them to inspect damage on an aircraft. Each tool has a unique purpose and there is really no tool that can do it all. The most basic of all inspections is the visual inspection. This can be as simple as a walk around the aircraft, looking for signs of damage. The shortcoming of this method is that some spots on the aircraft can be difficult to see from a walk around and the human eye isn’t always going to catch everything. In some cases, such as on a composite structure, there is no external indication of damage even though there may be hidden damage beneath the surface of the aircraft.

New Adventures

by Joy Finnegan, Editor in Chief

Since 2004 I have been working at Aviation Maintenance – first as managing editor and then, starting in 2006, as editor-in-chief. I met a former editor-in-chief of this publication, Matt Thurber at the 100th Anniversary of Flight celebrating the monumental accomplishments of the Wright Brothers in Kitty Hawk, North Carolina. He was without a managing editor at the time and learned I was looking for work. He offered to have me out for an interview and said he’d rather teach someone who knew aviation to run a magazine than to try to teach a journalist the intricacies of our unique and complex industry.

When he left for greener pastures, I became editor-in-chief and have been ever since. I did take a brief hiatus to work as editor-in-chief of another aviation publication, Rotor & Wing. I had left that magazine due to a family relocation and when the interim editor of this magazine also found another position and left, I quickly returned to Aviation Maintenance – that was five years ago.
For a total of ten years I have followed, written about, rooted for and been amazed by the dedication and hard work put in by each and every person in this industry. It has been my honor and pleasure to head up this magazine and cover the amazing things you do.

I have never been at a loss to find things to write about – quite the contrary. I am constantly challenged to find room to include all the news, features and information I would like to. From continuous improvement to Lean to software to borescopes to refurbs to high-velocity maintenance to innovation, there never seems to be a lack of things to write about.

During the last ten years I have seen good times and bad times in the aviation industry. The magazine itself has had its ups and downs as well. I have also seen the publication change ownership from a large media company owner to its current owner, Adrian Broadbent, an entrepreneur with a keen eye toward new opportunities.

StandardAero: Cutting-Edge Independent MRO Support

StandardAero251As you read this, GE Aviation is spending millions to upgrade the GE Aviation Test Research and Development Centre (TRDC) at Richardson International Airport in Winnipeg, Manitoba. Operated on GE’s behalf by StandardAero, the world’s largest independent engine MRO, the $54 million TRDC was initially built in 2011 to test the latest GE jet engines in extreme icing conditions. Since then, the TRDC has expanded its testing capabilities to include bird, dust, and hailstone ingestion by GE jet engines, plus endurance testing as well. Additional investments are now being made to replace the TRDC’s already-gigantic 800,000-pound wind tunnel and ice-crystal projector with an even larger system.

“GE Aviation decided to expand the TRDC facility so that it is large enough to test the company’s newest engines, which will be bigger than anything built before,” said Brent Ostermann, StandardAero’s Director of Engineering (CF34/CFM56). “They have been sufficiently happy with the work StandardAero does on their behalf – and the fact that Winnipeg’s long, cold winters offer a lengthy icing test season – that they are putting even more money into the TRDC.” (The TRDC’s massive enclosed facility, which surrounds the engine being tested on three sides, is located between two runways at Richardson International Airport.) Among the engines that have been tested at the TRDC are the GENx engine flown on the Boeing B787 Dreamliner, and the CFM (joint venture between GE and Snecma) LEAP (Leading-Edge Aviation Propulsion) engine that is being used on the Airbus A320neo, the Boeing 737Max, and China’s Comac C919.

StandardAero’s critically important work as a GE Aviation engine tester exemplifies the trust and respect this company has earned as a global engine MRO over the years. Much has changed for the company since it was first established in Winnipeg as Standard Machine Works in 1911. Initially, the company founded by William S. Bickell and Charles F. Pearce specialized in repairing small automotive engines, but the growing demand for aviation engine services motivated Standard Machine Works to move into this area.

Today, StandardAero has grown and diversified into airframe/engine repair and overhaul, engine component repair, engineering services, and interior completions and paint. Its customer base covers the business, commercial, general, and military aviation markets. StandardAero maintains a large presence in Winnipeg with 1,300 employees, but this US-owned MRO also has service locations across the United States, Australia, The Netherlands, and Singapore. The company has 3,500 employees in all.

The Engine Specialist
Although StandardAero offers a full range of aircraft MRO services, it is renowned for its attention to the health and well-being of aerospace engines. Despite operating the TRDC on GE Aviation’s behalf, StandardAero offers engine MRO services for all major makes and models. They include the CFM International CFM56; GE Aviation’s CF34 and LM100; Honeywell’s CFE738, HTF7000, TFE731 TPE331, and GTCP36 series/RE220 APUs; Pratt & Whitney’s F100-220/220E; Pratt & Whitney Canada’s PT6A, PW100, PW600 and APS2300 APUs; and Rolls-Royce AE 1107, AE 2100, AE 3007, Model 250, RR300, T56/501D, and 501K. StandardAero also services Hamilton Sundstrand 54H60 propellers.

Borescope Technologies Fit Every Need

Aviation Inspector251Borescopes, the tools that are used to assess the health of everything from engines to airframes, are a mainstay of the aviation industry, from the original equipment manufacturers to the MROs, to the smaller repair stations and FBOs. The technology can yield an almost immediate return on investment if it allows a facility to avoid unnecessary downtime for valuable assets or prevents an accident. The market is mature and highly competitive. The technology moves quickly, tracking advances in areas such as optics and microelectronics.

Aviation is a prime consumer of these remote inspection products. But oil & gas, power production, pharmaceuticals – any industries that use machinery with piping and internal cavities – invest in the technology and drive its advances. There’s also a wide range of capability. At the high end there are scopes that not only let technicians view the turbines of pricey commercial jets but let them measure identified defects to thousandths of an inch.
Mid-tier scopes provide fewer bells and whistles but offer much the same basic remote visual inspection capability. They tend to be used in general aviation and business aviation by smaller aviation maintenance and repair facilities. The equipment is used for inspecting items such as engines – especially the PT6 – wing spars, and landing gear assemblies, says Frank Menza, owner and president of Titan Tool Supply, a distributor that has been in business since 1952.

At the low end are inexpensive and basically disposable products that might be used for very simple tasks but that are not really intended for aviation.

Mid-Market Dynamics
From the low end to the high end prices range from less than $100 to more than $40,000. Customers sometimes employ a combination of high-end and mid-tier scopes to meet different needs. “A lot of aviation maintenance and repair facilities don’t need a $30,000 to $40,000 scope,” Menza says. Titan sells video scopes in the $3,995 to $10,000-$12,000 range, competing in quality, availability, and delivery times. The company offers a combination of video scopes, fiber scopes, and rigid scopes across all of the borescope markets.

Gradient Lens Corp. also competes on price as well as quality and believes in keeping its products simple. “We make a Ford or a Chevy, not a Mercedes,” says Doug Kindred, Gradient’s president and chief scientist. Ninety percent of customers don’t need all the bells and whistles of high-end scopes, he adds. Gradient’s prices start at about $9,000 and go up to about $14,000. In the aviation market the company targets smaller and medium-sized FBOs. Its equipment is used on “a lot of helicopters.” The company’s new Hawkeye V2 video scope includes features such as 5x to 10x magnification – depending on the tip – and 2x digital zoom, plus a 60 degree standard tip. There are two optional tips – a 90 degree tip and a close focus tip with a 60 degree field.

What’s Up with Aviation Parts Distribution?

All indicators show that the aviation industry is expected to grow marginally in upcoming years. The predicted boost in commercial flights will benefit aviation industry distributors; increased domestic trips by U.S. residents will result in higher demand for commercial aircraft repair and maintenance. As commercial flights increase, demand for aircraft parts will grow.

Introducing next-generation aircraft increases the demand for aircraft components compatible with the newest models. Moreover, new parts are increasingly being delivered by manufacturers themselves, thereby increasing the segment’s markets share as producers claim a larger share of the aftermarket. Declining used part and supply prices helps new parts gain a greater share of the industry’s revenue stream.

An airline’s reliability is largely dependent on the maintenance of its aircrafts and this in turn is decided based on turnaround time and lead time of aircraft parts procurement and repair. So, what’s available today to make it easier for the customer to get the aviation parts they need?

Parts Procurement
Aviation parts procurement is a collection of processes that involves many steps and interactions with other company departments and with suppliers. Traditionally, procurement was paper and conversation-based, and with procurement officers interacting with long-time partners or well-known suppliers, purchasing was done at fixed prices. This process then involved creating RFQs (request for quotations), purchase orders, order acknowledgment, shipping, invoicing, and other steps, which over a period of time were done via e-mail, fax and other forms of communication.

This form of procurement meant a smaller number of the suppliers and fewer parts available in the database. Moreover, the dependency on existing suppliers and inaccessibility to adequate parts pricing details occurred. These problems caused higher expenditures, and delays in aircraft maintenance and movement, thus hindering the airlines’ reliability.

All of this necessitated advanced aviation procurement technology. “The speed of technological development and its rapid pace has brought about new advancement and capabilities throughout the industry,” says Eric Strafel, president, Availl, A Boeing Co., DFW Airport, Texas. “Customers continue to see increased digital activity, web portals and other optimized channels that offer greater access to information, while also providing a faster and more seamless parts fulfillment process. Aviall expects this to continue and is constantly looking for ways to leverage improved technology and innovation to further increase connectivity and integration, data analysis and customer value management and optimization.”

Because of Aviall’s successful use of technology advancements, it aviation parts (including its best-in-class inventory) are more easily accessible for its customers.

Improving MRO Processes Using Distributed Part History Data — “Smart Assets”

For many products the cost of service, maintenance, replacement parts, and upgrades over its lifecycle can be a larger proportion of lifecycle cost of ownership than the original acquisition cost. Managing these “downstream” activities efficiently is an essential element of ensuring product availability, product safety, and minimizing total cost. For the product supplier this can also be a larger profit pool than that of selling new products. In aerospace in particular, maintenance, repair, and overhaul (MRO) is key to operational efficiency and safety, to maintaining airframe asset values, and as a profitable revenue stream both for part and service providers.

Why Does Part History Matter?

Effectively managing parts histories is a key element of improved MRO economics. This is especially true when the parts are time limited and/or rotable. But ensuring part authenticity, proper application of service bulletins, configuration compatibility, time in service limits and prior maintenance/overhaul status is important for many types of parts. Missing or incomplete history data can result in labor expense for researching history and possibly an inability to validate airworthiness. Incomplete part histories or counterfeit parts can lead to lower performance, compromised safety and lost revenue for MRO suppliers and their customers.

The most common way to track a part’s history includes identifying them using serial numbers which are then matched against records in paper or electronic logs. Many parts are not serialized making their maintenance histories perishable. Inspections to identify parts, researching parts histories, and validating the physical configuration of an airframe, engine or other system components can be time consuming and expensive.

Where physical serial number tags are used, they can be replaced or supplemented with machine-readable bar codes or RFID tags. However, these tags typically contain only a limited amount of information such as part number, manufacturing date and serial number and they still require researching logs for history data. Some of this can be automated with enterprise IT systems, a large investment, and in most cases is problematic when customers use multiple third party MRO providers and for rotables which may move between customers at every service or overhaul.

There is A Lot Going on with Documentation!

FAA and the European Aviation Safety Agency (EASA) have been discussing new ways to document and transfer aircraft articles across international borders. This ends up affecting the rest of the world, because it sets standards for how both of those authorities will operate that they then incorporate into their other international relationships.

Many of the recent changes have their roots in the FAA-EASA Maintenance Annex Guidance (MAG). This document is meant to reflect that working procedures for shared maintenance oversight between FAA and EASA. In theory, it should not add any new legal requirements. But in practice, it has recently evolved into a document that is setting new legal standards that do not exist in the regulations of either FAA or EASA. Because inspectors for the two authorities are requiring compliance to the MAG, it is important to review it and understand what new standards are included in that document.

The MAG changes are motivated in part by a recent change in US law that has permitted US production approval holders (PAHs) to issue their own 8130-3 tags for their articles. Those who take advantage of this option would no longer need to rely on the legal fiction of designees. This was meant to ease the process of creating 8130-3 tags, which have recently been viewed by the FAA as an administrative matter that merely documents a finding of airworthiness that is made whether the tag is created or not. This change also helps to harmonize with EASA, which has permitted European manufacturers to issue EASA Form One since EASA’s inception.

Although this new privilege should permit more manufacturers to issue 8130- 3 tags, thus creating a wider pool of documented articles, the fact remains that many existing aircraft articles do not bear EASA Form One or 8130-3 tags. Real-world implementation hurdles have mean that manufacturers needed some time before they could start issuing the tags. In addition, there is a huge quantity of existing articles in distributors’, air carriers’, and repair stations’ inventories. Many of those existing articles do not bear EASA Form One or 8130-3 tags.

The industry has struggled for the last twenty years to obtain these documents, or in the alternative to find ways to receive aircraft articles into inventory without these magic documents. In many cases, the easiest path has been to find a way to determine airworthiness without the Form One or 8130-3 documentation – this is a path that remains legal under United States law because we have no general documentation requirements for articles under the FAA regulations.

FAA: Providing the Safest Aerospace System in the World

The mission of the Federal Aviation Administration (FAA) is to provide the safest, most efficient aerospace system in the world. There are many ways in which the FAA seeks to accomplish its mission. Many people are aware that the FAA develops safety regulations which set the minimum safety requirements for aviation. However, many people are not aware that the FAA also conducts research and development to help it achieve its mission. There are many offices within the FAA, each with their own set of duties and responsibilities.

The Airports Organization (ARP) provides leadership in planning and developing a safe and efficient national airport system; The Air Traffic Organization (ATO) is the operational arm of the FAA and is responsible for safe and efficient air navigation services to approximately 30 million square miles of airspace; and Aviation Safety (AVS) is the organization responsible for the certification, production approval, and continued airworthiness of aircraft; certification of pilots, mechanics, and others in safety-related positions. AVS is also responsible for certification of all operational and maintenance enterprises in domestic civil aviation, certification and safety oversight of approximately 7,300 U.S. commercial airlines and air operators, civil flight operations, and developing regulations.

The William J. Hughes Technical Center in Atlantic City, New Jersey is one of the nation’s premier aviation research, development, test and evaluation facilities. Its world-class laboratories and engineering place the Technical Center at the forefront of the FAA’s challenge to modernize the U.S. air transportation system. The Technical Center serves as the FAA’s national scientific test base for research and development, test and evaluation, verification and validation in air traffic control, communications, navigation, airports, aircraft safety, and security. The Technical Center is the primary facility supporting the nation’s Next Generation Air Transportation System, called NextGen.

Within the Aviation Research Division, one of several divisions at the William J. Hughes Technical Center, there are five branches: Fire Safety, Human Factors, Airport Technology, Software and Digital Systems, and Structures and Propulsions. The Fire Safety Branch conducts long-range research to develop a totally fire resistant passenger aircraft cabin with the goal of eliminating cabin fire as a cause of fatalities in aviation. The Human Factors Branch employs scientific methods and advanced technology in the conduct of research and development to ensure that systems that include human operators and maintainers perform as effectively and safely as possible.

The Airport Technology Branch conducts the necessary research and development required to enhance the safety of operations at our nation’s airports and to ensure the adequacy of engineering specifications and standards in all areas of the airport systems and, where necessary, develop data to support new standards. The Structures and Propulsions Branch’s work includes research on structures and materials, propulsion and aircraft icing, and fuels and energy.

State of the Industry

The Top MRO Leaders Share Their Wisdom:

  • Dr. Johannes Bussmann Chairman of the Executive Board, Lufthansa Technik
  • Kevin McAllister President and CEO, GE Aviation, Services
  • Franck Terner Executive Vice President, AIR FRANCE KLM Engineering & Maintenance
  • Matthew Bromberg President, Pratt & Whitney Aftermarket
  • Mário Lobato de Faria Executive Vice President, TAP Maintenance and Engineering
  • Sarah MacLeod Executive Director, Aeronautical Repair Station Association
  • Dany Kleiman AAR, VP of Repair & Engineering
  • Leo Koppers SVP Marketing & Sales, MTU Maintenance
  • Jeff Bartlett Director – Airlines, BAE Systems
  • Pastor Lopez CEO, PEMCO World Air Services
  • Christopher Whiteside President, AJW Group
  • Jeremy Remacha CEO, SR Technics
  • Jim Sokol President MRO Services, HAECO Americas
  • Refael Matalon Senior Director & GM Marketing and BD, IAI/Bedek Group
  • Zilvinas Lapinskas CEO, FL Technics
  • Jim Martin Founder & Managing Partner ACM Aviation Staffing and President & CEO, Marana Aerospace Solutions
  • Turkish Technic Senior Official, Turkish Technic
  • Eric Strafel President and CEO, Aviall
  • Derek Zimmerman President, Gulfstream Product Support
  • Todd Duncan Chairman, Duncan Aviation
  • Neil W. Book President and Chief Executive Officer, Jet Support Services, Inc.
  • Malissa Nesmith Senior Vice President/COO, Global Parts.aero
  • Geoff Chick Vice President of Customer Service, Dassault Falcon
  • Charles Picasso CEO, Aviation Technical Publishers
  • Brad Thress Senior Vice President, Customer Service, Textron Aviation