This is now my third article on this topic and here’s the link to the previous post:
https://www.aviationsuppliers.org/REVISITED-MILITARY-8130-3-S
What prompted me to write this is a major, welcomed
update regarding the use of the 8130-3 for Return to Service (RTS) for military and/or government parts. But first the big picture:
The big picture:
FAA Form 8130-3 Instructions are now in different documents:
For MROs who are not Production Approval Holders (PAHs), AC 43-9D now contains the instructions for filling out the 8130-3 for purposes of a Return to Service, after for example, Overhaul, Repair, Inspect/Testing, etc.
Background:
From my previously cited article it appears the FAA has supported the use of the form for military/government purposes for some time. There was a big problem with this however, there was no guidance whatsoever in the historic Order 8130.21 and so there was varying, if any degree of implementation. When the FAA asked for feedback at an ASA QA committee meeting regarding the pending big picture items above, I put forth the argument for the FAA to finally put this issue to rest and give us simple guidance for this purpose. The language they presented in the subsequent draft was kept and now resides in revision D of AC 43-9. Bravo .
Before getting to specifics there should be a point of clarification about the parts in question. For purposes of this discussion, we can generally group military/government parts into two groupings:
Dual use parts. Loosely, these are parts that can be used in either civilian or military applications. For example, the Air Force uses 737s for VIP transport, designated the C-40. The 737 is of course a type certificated product and many of the parts on the C-40 are dual use. Use of 8130-3s for these parts has long been transparently in use with no issues. Non-dual use parts, an F-16 landing gear actuator for example. It is these parts which are the subject of this article . Why use the 8130-3 for these types of parts?
It would be desirable to have a single form to attest to the airworthiness of civilian or military/government parts; uniformity and simplicity. Many of you perform MRO work for nations flying for example, UH-60 Blackhawks, F-16s, F-15s, C-130s, and F-35s among many others. I have seen more than a few solicitations from those nations whereby they are seeking MRO providers for component maintenance. Often, they insist in their terms and conditions that it be accomplished by a FAA Part 145 MRO, and further that an 8130-3 be issued with the parts. The insistence on the 145 is for the reasonable expectation that the 145 Quality System will be applied to the parts even though they’re military parts . The requirement for the 8130-3 was problematic. Some FSDOs told their MROs that they couldn’t do it, other FSDOs insisted they could. Guess who got the work contract from the overseas customer? Yes, the MROs doing it. Cries of alacrity and market distortion from those who didn’t get the contract. Remarkably some MROs altered the 8130-3 form for military purposes. Thankfully we now have some guidance! AC Excerpt:
A compliant form:
According to the AC the form would be filled out in all respects with the exception of the 14a block not being checked.
The form would not be eligible for a dual release since those rely essentially on the FAR being followed. For military parts this is typically not an issue.
Notice that there is still no FAA FAR requiring use of an 8130-3 for any purpose, so the use of the form for this purpose remains voluntary.
If you’re implementing this, Royboy highly recommends that you create a transparent procedure, process, or work instruction to support its use.
As with all things new, the industry may have growing pains as this rolls out. For example, a customer may think you made a mistake by not checking block 14a. In this case it is recommended that an explanatory NOTE be added as shown in the example. By the way, I also wrote another article titled “REMARKS On Your Documents Are Your Friend”. Here’s the link:
https://www.aviationsuppliers.org/remarks-on-your-documents-are-your-friend
Make it happen, over ‘n out
Roy ‘Royboy’ Resto
www.AimSolutionsConsulting.com
Crafted without the use of AI.
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