FAA Proposes to Permit Manufacturers to Issue 8130-3 Tags

Tomorrow, the FAA is expected to publish a proposed rule that would allow production approval holders to have the privilege of issuing 8130-3 tags, without recourse to a designee.  This could reflect a competitive disadvantage for distributors, who would continue to have to use DARs to obtain 8130-3 tags (manufacturers would have the option to issue 8130-3 tags but would not be required to do so, so they could use this as a way to help them compete in the distribution arena against independent distributors).

The rule would also redefine to the term “airworthiness approval” by adding “unless otherwise specified.”

New Proposed RuleAirworthiness approval means a document issued by the FAA for an aircraft, aircraft engine, propeller, or article which certifies that the aircraft, aircraft engine, propeller, or article conforms to its approved design, unless otherwise specified, and is in a condition for safe operation.

This new definition would appear to authorize 8130-3 tags with disclaimers (like 8130-3 for non-conforming parts, or for parts configured for certain foreign aircraft configurations).

An advance copy of the proposed rule can be found here:

https://s3.amazonaws.com/public-inspection.federalregister.gov/2014-04330.pdf

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About Jason Dickstein
Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.

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