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Acceptance of Airworthiness Documents

As a kid growing in the Bronx, I remember playing a game called ‘tag’. You’d have to run after everyone until you touched a person and said “Tag, you’re it.” Then that person would have to run after everyone and try to tag someone else. Frankly, I did not like the game because I was a slow runner. That meant you were the target of faster runners who would unlikely be re-tagged by your slothful maneuvering. The more skillful tag players were adept at dodging, much like football players dodge a tackler. If you were fast and could dodge, you were not going to be ‘it’; the more for my distaste of this form of entertainment. Here’s a subject I’ll not dodge; a different tag, an airworthiness tag.

If you’re a typical airline purchasing agent needing to buy an aircraft part, you’ll generally concern yourself with the following:

1) How much will it cost?
2) Where is it traced to?
3) What type of airworthiness documents will accompany the part?

For this blog, let’s just talk about the airworthiness documents. We’ll start with the easy, and ratchet to the perplexing.

An Airworthiness document is an attestation from the issuer that the part is worthy of being placed into flying service; it’s Air-Worthy. Many countries have a specific form they use to document this condition. Here’s a small sampling of the form numbers:

Regardless of the number of the form, the title will be “Authorized Release Certificate” and/or “Airworthiness Approval Tag”, and are widely, generically called ‘tags’. For a person or company to issue one of these, they have to be specifically authorized to do so by their country’s applicable Civilian Aviation Authority. The signature on such a document will be accompanied by an authorization number peculiar to that person or company. If you were to place each of these forms side by side, you’d notice a great deal of similarity. This is due to their use and evolution over many years, and efforts in the international community to reportedly harmonize the forms. So, whose tags are acceptable to you and your company?

I recently had this conversation:

• “Royboy, can you do an FAA-DAR 8130-3 for this part?”
• “It depends Joe, what are the details of the part?”
• “It already has a Transport Canada 24-0078 tag on it. That should make it easier for you to issue the 8130-3 tag, right?”
• “Joe, if it has a 24-0078 tag on it already, it does not need an 8130-3 from me”
• (At this point Joe is seen to shake his head in the horizontal plane, and escalate the tone of his voice) “But Royboy, my customer says they require an 8130-3.”
• (Remember Sherlock Holmes? After much contemplation on a problem, he’d excitedly squint his eyes with a gleeful AHA! And so it was with Royboy) “AHA! Another diabolical black and white rule that does not withstand reason”

It turns out that the customer has rules stipulating if the part came from the USA, it required an 8130-3. If it came from Canada, it required a 24-0078, and from Europe, an EASA Form 1, etc. At first glance that appears to be a sound policy. The problem is that this black and white policy overlooks the international aspects of aircraft parts purchasing and selling, and in particular, the aftermarket.

Let’s amplify this, and protect the guilty. There is a country called the Republic of Resto, or RoR. Its national airline is ARoRA, or Amalgamated Republic of Resto Airlines (neat huh?). ARoRA has the aforementioned black and white policy.

 ARoRA desires to buy an altimeter for its 737 aircraft, and locates one at a distributor in the USA. It has a Canadian 24-0078 tag on it because the distributor purchased it from a Canadian airline that surplused it from its stock. Result? ARoRA says it cannot purchase the part without an 8130-3 because it is coming from the USA. There are some remedies for this:

• The most obvious is that ARoRA needs to amend its policy. For example, if ARoRA’s maintenance instructions consist solely that the Altimeter be repaired or overhauled in accordance with the OEM’s Maintenance Manual, and the Canadian tag states that the altimeter was repaired or overhauled in accordance with the same manuals, then ARoRA should accept it even if it is being shipped from the USA.
• The USA distributor can send the part to a repair station of ARoRA’s choosing to be tagged with an 8130-3. Of course this will (unnecessarily) raise the price of the part. There are some other possible remedies, but I think you get the point.

Is there anything else that influences the acceptance of Airworthiness tags? Yep.

As you would expect, aviation is quite prone to the world of international politics. The method by which one country accepts the aviation policies of another is through the instrumentality of documents called ‘Bilateral Agreements” (which may go by other names). Bilaterals are negotiated by the State Departments of their respective countries. For example, RoR has a bilateral agreement with the USA. Part of that Bilateral states the conditions RoR requires when aircraft or aircraft parts are imported into its country, and coincidentally, parts will require an 8130-3.

My personal experience with Bilaterals is that globally, there is great variation in the degree of enforcement and implementation of these procedures. It seems that the import or export of entire aircraft gets the greatest degree of compliance, with aircraft parts experiencing the most deviation, but that is an issue for Heads of State, whom I am not in a position to influence.

By the way, I’m told that the RoR fastidiously observes and enforces its Bilaterals.

6/6/08

Roy Resto - VP Technical Operations, FAA-DAR
Phone: 414 875-2191   Fax: 414 875-0200
royboy@mbtrepair.com

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