Using I/A/W on Approval for Return to Service

A member of the ASA community recently inquired about acceptable language for approval for return to service documents following repairs.  The member asked whether it is acceptable, on an approval for return to service document, to state in the description of work performed that the work was performed in accordance with (“I/A/W”) a reference from a manufacturer’s manual and ALSO state that other work was done pursuant to another source?

The short answer to this question is “Yes.”

Currently, the two most common approval for return to service documents are the FAA Form 8130-3 and the EASA Form One.  Each of these are used by repair stations to document work primarily subject to FAA or EASA regulations (respectively).

The instructions for the EASA Form One are found in the regulatory appendices, so these instructions are regulatory in nature.  The EASA Form One regulatory appendix requires the completer of the EASA Form One to “[d]escribe the work … either directly or by reference to supporting documentation, necessary for the user or installer to determine the airworthiness of item(s) in relation to the work being certified.” Examples of information to be entered in the remarks block of the EASA Form One include the maintenance data used, including the revision status and reference, as well as any other repairs or modification accomplished. The EASA guidance clearly anticipates remarks to describe the work performed that are written in the format “Repaired I/A/W [reference] and also [list of additional repairs or alterations].”

Thus, it is safe to say that it is acceptable to use the phrase “repaired I/A/W [reference]” when work beyond the specific manuals limits is performed, as long as additional language is added to clarify the additional work or the exceptions to the manual instructions.  Think of these sort of entries as ‘composite’ entries because they reference more than one source of data.

What you want to avoid is language that ONLY says “repaired I/A/W [reference]” when the work has diverged from the reference (either through additional work or through exceptions to the reference provisions). The reason you want to avoid such abbreviated recordkeeping is because it could misleadingly imply that you EXACTLY followed the reference, when a more accurate description would clarify the divergences.

We arrive at a similar result under the FAA system. The most important guidance when completing an 8130-3 tag as an approval for return to service is the language of 14 C.F.R. 43.9. This regulations requires “[a] description (or reference to data acceptable to the Administrator) of work performed.” Order 8130.21H provides additional guidance, although it should be noted that this is an internal FAA Order and therefore not a binding interpretation applicable to the public. In reference to the description of work performed, that guidance states, “This can be done either directly or by reference to supporting documentation.” Thus, a description of the actual work is permitted, and the reference to manufacturer’s manuals or other sources is a permissible shortcut. I have seen 8130-3 tags that state “I/A/W [reference]” and then include additional provisions, and I have also seen “I/A/W [reference] except [list of exceptions].” For example, I have seen logbook entries (which are governed by the same FAA rules) that stated “Repaired I/A/W [OEM manual reference] except used PMA Parts Number [PMA Part Number].”

Examples of acceptable composite language (assuming that the language accurately describes the work performed) could include:

  • Overhauled I/A/W [OEM manual reference] except used PMA Parts Number [state PMA Part Numbers used]
  • Repaired I/A/W [OEM manual reference] and also repaired I/A/W DER Repair [state DER Repair identifier]
  • Repaired I/A/W [OEM manual reference] except repaired I/A/W DER Repair [state DER Repair identifier] instead of [the specific elided OEM manual reference]
  • Repaired I/A/W [OEM manual reference] and also performed service bulletins [state service bulletin identifiers]

An example of potentially unacceptable language would be a situation where work that materially diverged from the OEM manual was performed, but the description of work performed only said:

  • Repaired I/A/W [OEM manual reference]

This could be potentially unacceptable under U.S. law if disclosure of the divergence was necessary to allow the installer to make a determination concerning airworthiness.  For example, if a service-bulletin-based alteration was performed that changed the dash number on the part, then that sort of work probably needs to be disclosed in the approval for return to service.  Similarly, a major alteration based on independent DER-approved data (so, something that was not in the OEM manual) would likely need to be separately disclosed on the approval for return to service.

 

This discussion is general in nature and is not based upon any particular fact pattern. It does not constitute legal advice and it does not create an attorney-client relationship.

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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.

One Response to Using I/A/W on Approval for Return to Service

  1. Jason Dickstein says:

    One of my OEM friends sent me an email about this post. He asked why I did not state that it is acceptable to just write I/A/W and not put some thing else.

    The question asked was “whether it is acceptable, on an approval for return to service document, to state in the description of work performed that the work was performed in accordance with (“I/A/W”) a reference from a manufacturer’s manual AND ALSO state that other work was done pursuant to another.

    The question was focused on the so-called composite statement. Perhaps I should have indicated that the questioner actually had a concern over whether they were allowed to accept an 8130-3 in that format.

    I do not know how you efficiently record an overhaul that includes an additional DER repair unless you are permitted to create a composite statement. Thus, as a matter of good record keeping, composite statements make sense.

    But of course, a simple I/A/W statement (where you have relied on only one source of data) is both permissible and common in the industry.

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