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The Aviation Lawyer 

The 8130 Trap - Part 1

Virtually every aviation maintenance professional takes the FAA Form 8130-3, Airworthiness Approval Tag very seriously. After all, your name goes on it certifying to the world that the part or component is in an airworthy condition. It provides assurance that the maintenance work has been performed properly. Failure to accurately complete a Form 8130-3 can result in civil liability for you and your employer, possible FAA certificate action and, in certain cases, criminal charges for individuals and companies. In this article I will touch on an area that presents a threat to unwary technicians: specifying "repair" or "overhaul" in Section 11 of the Form 8130.

Sometimes the difference between a repair and an overhaul can be subtle. I have heard technicians say that when overhauling a component, if they "crack the case" the work is considered an overhaul and not a repair. Not true. The FAA does not consider it an overhaul unless the component has been disassembled, cleaned, inspected, repaired when necessary and reassembled to the extent possible. In addition, the component must be in complete conformity with applicable service tolerances specified in the type certificate holder's or equipment manufacturer's instructions for continued airworthiness, or in data approved or accepted by the FAA or applicable authority. This includes being tested in accordance with approved or accepted data.

Unless each step of the overhaul instructions are followed, and all parts are confirmed to comply with the applicable standards, it is not an overhaul. You may or may not have completed a valid repair, but an overhaul it is not. Listing such an item as "overhauled" in Section 11 of the Form 8130-3 would be a violation of regulations and possibly criminal statutes.

Please email me at info@pama.org to submit any aviation law and regulation questions that you would like to see addressed in future columns.

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