Condition Codes on Parts with Multiple Tags

An association member recently asked about the “correct” condition code to use when selling a component with multiple tags.

This answer is limited to commercial condition codes, such as those used on listing services like ILSmart or PartsBase.  If one is looking for the condition code to list on an 8130-3 tag or other government tag then the answer may be different!  For example, one may not describe an article as overhauled on an 8130-3 (approval for return to service) unless the article was disassembled, cleaned, inspected, repaired as necessary, reassembled, and tested.  All of this must be performed using methods, techniques, and practices acceptable to the FAA.

The specific question involves a hypothetical fuel pump bearing two 8130-3 tags.  The first tag is an earlier overhaul tag.  we will assume for this hypothetical that the tag is in good order and that the overhaul was properly completed.  The second tag is a more recent one stating “Modified” in the status/work block, and explaining in the remarks block of the tag that the fuel pump was modified according to instructions in a manufacturer’s service bulletin. The part has remained unused and uninstalled since the overhaul.  Which condition code is appropriate for identifying the unit?

A part that is marketed as “overhauled” may be perceived as having a different value than a part that is marketed as “modified,” so knowing which condition code is commercially appropriate for marketing the part can have a real dollars-and-cents effect.

We are talking about condition codes in commercial communications (and not codes on a regulated document, like an 8130-3 tag).  These condition codes may be governed by instructions associated with the commercial medium.  Therefore, if you are using a commercial medium for this communication then you should follow the rules set by that medium.  Typically, online inventory locator services will have their own definitions and standards.  If you are communicating via a SPEC 106 form, then that specification provides some guidance about condition codes for use in the associated form.

In the hypothetical that we’ve posed, the fact that this is for a fuel pump may mean that the age of the earlier overhaul tag is relevant.  Fuel pumps include seals that could degrade over time.  This is a rather specific issue connected to the hypothetical that may not be applicable to other parts with more recent overhaul tags, or that do not have elements that are susceptible to degradation over time.

Setting those issues aside, though, it is generally acceptable for a distributor to describe an aircraft part as overhauled if the maintenance records reveal that it was properly overhauled, and has not been used or installed since the overhaul.  If there is an applicable Service Bulletin, then the customer will likely want to know about the Service Bulletin status, but that can be discussed directly with the customer (or disclosed in a remarks field, if such a field is available).  One reason that this is acceptable is because the Service Bulletin should not have done anything to the part to change the fact that it was overhauled – obviously, if the service bulletin modification undermines the overhaul, or provides alternative instructions for identification, then the service bulletin that was incorporated should take precedence over this advice.

Note that there are a variety of unusual circumstances that can change this rule-of-thumb-advice.  For example, where the subsequent service bulletin requires a part number change, it may become inappropriate to list the part under its new part number as “overhauled,” because it was overhauled under the prior part number (causing a mismatch between the part number on the overhaul tag and the new part number on the part).  In such a case, it may be more appropriate to list the new part number’s condition as modified or altered on the grounds that the new part number was not associated with the earlier maintenance, and the new part number could have different overhaul requirements.

 

 

 

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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 Air Carrier Purchasing Conference, and the Modification and Replacement Parts Association. He also represents private clients drawn from the spectrum of the aviation industry.

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