Obtain 8130-3 Tags For Your Inventory – Limited Time Only!

Have you ever wished that there was an easy way to obtain 8130-3 tags for the obviously airworthy articles in your inventory?  Now, you can become a DAR and issue your own 8130-3 tags!  ASA has worked with the FAA to develop a limited program that will allow employees of accredited distributors to obtain DAR privileges to tag certain items in existing inventory.
The program creates a new function code 56 (because of the association with AC 00-56).  This is a limited function code for employees of accredited distributors that permits issue of 8130-3 tags for parts with certain types of clear evidence of production under FAA production approval.  The program can be found in this attached file.
This program is necessary because of the new emphasis on 8130-3 tags created by the FAA-EASA Maintenance Annex Guidance (MAG).  Many FAA inspectors have required repair stations in the US to adopt receiving requirements that only permit receipt of aircraft parts with 8130-3, EASA Form One or TCCA Form One.  Parts with traditional manufacturer’s certificates of conformity (for example) are excluded from the MAG guidance!  This temporary ability to obtain 8130-3 tags permits some existing inventories of good parts to be tagged in order to meet the new standards created by the Maintenance Annex Guidance

What Can be Tagged?

A DAR with Function Code 56 privileges will be able to issue an 8130-3 tags for parts manufactured by an FAA production approval holder (PAH) if the part and its documentation meets one of the criteria below:
1. Certificate of Conformity/Statement of Conformity from the PAH.  The part number and serial number, if applicable, must match any marking on the part.
2. Certificate of Conformity/Statement of Conformity or shipping document from a PAH supplier and verification of that supplier’s direct ship authorization.
3. Part markings made under 14 C.F.R. § 45.15 that include the PAH’s name or identifier (including PMA markings, TSOA markings and critical part markings).  If the PAH name or other identification is not included in the part marking, then you will need a Certificate of Conformity/Statement of Conformity as described in paragraphs (1) or (2) above.

Qualifications

An applicant for the DAR-56 program must meet all five of the minimum qualifications:
1. AGE: Be at least 23 years of age.
2. EMPLOYMENT: Be employed by an accredited distributor at the location(s) from which the 8130-3 will be issued.  The FAA has not clarified whether this needs to be full-time or part-time nor have they excluded contract employment.  In the absence of clarification, applicants should assume that all categories of employment are acceptable.
3. INDEPENDENCE: Be assigned to a position in the business with sufficient authority to allow the DAR to administer the delegated function effectively without undue pressure or influence from others.
4. EXPERIENCE: Have a minimum of 12 months actual working experience for the accredited distributor under the distributor’s quality system, specifically:
a. Experience in either receiving inspection and/or quality assurance processes; and,
b. Experience reviewing documentation which can be used to verify that the article is traceable to the PAH, such as a FAA Form 8130-3 and Certificate of
Conformity/Statement of Conformity from a PAH.
5. TRAINING: Must have successfully completed FAA course: Issuance of 8130-3 for Domestic and Export Approvals of Engines, Propellers, & Articles Only.

Application Process

Scan and submit the following three documents by email to 9-AIRI60-LimitedDARF@faa.gov:
1. FAA training certificate of completion from the required class [FAA course: Issuance of 8130-3 for Domestic and Export Approvals of Engines, Propellers, & Articles Only]
2. FAA Form 8110-14, Statement of Qualifications (should be signed by the individual employee).
3. A letter of endorsement signed by a management representative from the accredited distributor location where that individual employee is requesting to exercise the authorization.
  • Where the accredited distributor has more than one accredited location, the applicant may apply to exercise privileges at each accreditation location
    under a single management endorsement letter.  The Memo includes a sample letter and explains what must be in the letter.

The applicant is expected to retain the original application materials in his/her records.  FAA Headquarters will review the application.  When an applicant is selected, the FAA will email the applicant a Certificate of Authority.

Limits

There are many categories of airworthy parts without 8130-3 tags that will not be covered by this DAR-56 program.  This is not a solution to all of the problems caused by the implementation of the Maintenance Annex Guidance.  many ASA members will still need to rely on traditional DARs.
The DAR-56 program is limited in time.  All Limited DAR-56 appointments under this program will be terminated on September 30, 2017.  We have discussed with the FAA that there will be a continuing need for the program, because some FAA-PAH manufacturers continue to produce parts without 8130-3 tags.  ASA intends to petition for an extension of the program if it appears that the program remains necessary, but ASA members should not plan on the FAA granting that petition (they have already told us that they will reject such a petition).

Advice

The FAA intends that this DAR-56 program be used to tag existing inventory in order to make it saleable under the new documentation standards of the MAG.  The FAA has stated that they intend to issue privileges to all eligible applicants, in order to facilitate this process (note that this does not give you a legal right to the privileges – the FAA retains the discretion to limit or terminate the program at its discretion).
Many of our members have a substantial existing inventory that is eligible to be tagged under this program.  We have spoken with members who have said that some inventories could take YEARS in order to tag the entire inventory.  We advise accredited members to seek DAR-56 privileges for EACH eligible employee, in order to maximize your potential for issuing 8130-3 tags.  Accredited members should also apply as early as possible.
Once employees have received their certificate of authority, they should start to review existing inventory and issue tags for eligible parts immediately, in order to maximize the documentation of the inventory.
We also advise unaccredited ASA members to seek AC 00-56 accreditation in order to be eligible for the DAR-56 program.  ASA can discuss the process with you and can accommodate members who need AC 00-56 audits in order to participate in the program.
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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.

2 Responses to Obtain 8130-3 Tags For Your Inventory – Limited Time Only!

  1. Pingback: Getting Training to Support Your DAR-56 8130-3 Tag Privileges | ASA Web Log

  2. Pingback: DAR 56 Extended Until August 2018 – Submit Your Request For Extension NOW! | ASA Web Log

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