FAQ

1.Is a properly completed FAA Form 8130-3 required before an air carrier or repair station may accept a new or used replacement part into inventory?

Answer: No A Form 8130-3 is only one of several ways of determining a part's eligibility for installation on a type certificated product. The use of the 8130-3 is not regulatory and FAA Inspectors cannot insist that airlines or repair stations obtain them as a prerequisite for accepting a part through their inspection systems. (See Advisory Circular 20-62D)

Answer: No. In 1999 President Clinton signed into law an amendment that exempts virtually all hardware from the Act. You can check the Web Site of the NIST (National Institute of Standards & Technology) and click on the hyperlink for the Amended Fastener Quality Act and you should carefully read the section under definitions for the term "Fastener".

3. Can a DAR (Designated Airworthiness Representative) or the FAA issue an 8130-3 Export Airworthiness Tag without being associated with the Product Manufacturer?

Answer: No. FAR 21.323 (b) states that, "Any manufacturer may obtain an export airworthiness approval for a Class III product if the manufacturer - (1) Has in his employ a designated representative of the Administrator who has been authorized to issue that approval; and (2) Holds for that product - (i) A production certificate;(ii) An approved production inspection system; (iii) An FAA Parts Manufacturer Approval (PMA); or(iv) A Technical Standard Order authorization." Therefore, Aircraft Parts Vendors that are not associated with the Prime Manufacturer or Manufacturers that not meet the requirements of this FAR are not entitled to receive an 8130-3 Export Tag. However, this in no way implies that the products are not airworthy. The products may still be purchased by the foreign entity and installed in their aeronautical end product after determining the part's eligibility for installation.

4. Are "Back-to-Birth" records required by the Federal Regulations for life limited parts?

Answer: No. The FAR's require that the owner, operator or certificate holder keep records containing the current status of life limited parts of each airframe, engine propeller, rotor, and appliance. The operator needs to maintain a recordkeeping system that will substantiate the time that accrued on the life limited part. A complete audit trail to the origin is not needed for all life limited parts. However, it is the responsibility of the operator to substantiate that its recordkeeping system produces sufficient and accurate data to determine how the current status was obtained. The requirement is merely to show with a sufficient degree of certainty that the time elapsed on the part is correct. An audit trail back to its origin would be required only in those situations where the operator's records are son incomplete that an accurate determination of the time elapsed on the life limited part could not be made. (ref: FAA Legal Interpretation # 92-34)

5. What is the key to detecting "Bogus Parts"?

Answer: Because there are literally thousands of different types of parts and accessories, the task of identifying a "Bogus Part" can be extremely difficult for any inspector. However, if the inspection effort is concentrated in a logical manner, then the task becomes easier. Keep in mind that counterfeiters want to turn a profit right away and do not want to keep their investment stagnant. An Inboard Flap Assembly from a B747 could never be considered to be counterfeit due to its size, complexity and ultra-high cost of production. However, the bearings and bushings installed on this unit may very well be counterfeit. Another reason for this is because bearings and bushings sell at a much higher rate than the Flap Assembly by at least 20 fold. Therefore, the Flap Assembly would be inspected for damage, corrosion, lack of preservation, proper packaging, return to service paperwork from an approved maintenance facility (if used) and traceability back to the previous source (if new or purchased "As Is"). In contrast, the bushings and bearings should be scrutinized even more to assure that these parts were in fact manufactured under an industry standard or a TSO, if applicable. In either case, the best method of identifying "Bogus Parts" BEFORE they get to your receiving area is to "KNOW YOUR SUPPLIER". This last point can not be stressed enough.

6. Are there any dangerous or hazardous materials used in aircraft construction?

Answer: Yes !!! Aircraft Parts Brokers, as well as Aircraft Maintenance Personnel, should be aware of the different types of hazardous materials that are found in a couple of obvious components and one not-so-obvious component. For example, smoke detectors contain radioactive Americium 241 in a seal chamber. No one should attempt to open this seal chamber due to the risk of radioactive exposure. Another component is the Luminous EXIT signs. These signs contain a radioactive Tritium which allows it to be seen in the dark. Lastly, the component that poses the greatest risk are the Flight Control Counter-Balance Weights. The weights are made of depleted Uranium 238, which are 100% Cadmium Plated, emits low levels of radiation that is not harmful to humans, but these weights must be handled with caution. The true danger arises if a person were to grind through the cadmium plating. This action would cause radioactive Alpha particles to become airborne. Ingestion of these particles may cause irreparable damage to one's internal tissues. Maintenance professionals should remember that, if grinding is a required action, use gloves, industrial eye protection and a respirator. Gloves, wrapping material, wiping cloths, respirator filters, or any other articles used in the handling of damaged balance weights should be discarded and appropriately labeled as radioactive waste and disposed of accordingly. For more information see Advisory Circular 20-123 - AVOIDING OR MINIMIZING ENCOUNTERS WITH AIRCRAFT EQUIPPED WITH DEPLETED URANIUM BALANCE WEIGHTS DURING ACCIDENT INVESTIGATIONS.