I'll point out AN B073 to my AME, see what he thinks, here's a direct link for those interested:
http://www.tc.gc.ca/eng/civilaviation/s ... 3-2642.htm
I think I have 2 outs the AME might go for:
1) He accepts the interpretation that the "Certificate of Conformance" complies with paragraph d) of the AN
2) Since the tire change and wheel mounting is elementary maintenance, I will propose that I sign for that particular bit of work, since I am comfortable with the traceability of my parts based on that AN.
3) I'll ask TC directly for their interpretation of the "Certificate of Conformance" and hopefully they'll find it adequate, which will appease the AME.
I may ask TC anyways, since I want to know what I need in terms of parts certification for drop in replacement parts that are part of elementary maintenance (Like the new LED landing lights).
8130 Form
Moderators: sky's the limit, sepia, Sulako, North Shore
Re: 8130 Form
I hate to burst your bubble but I think the policy is pretty clear. Aircraft Spruce is famous for buying "surplus" parts and distributing them without properly informing the buyer what he's getting.
Surplus parts from a US supplier can't be installed on aircraft without an 8130-3 or a conformity statement backed by a "direct ship" authority from the aircraft manufacturer. That means that Aircraft Spruce would either need to pay an authorized repair station to issue the 8130-3 or enter in to an agreement with the aircraft manufacturer to act as an authorized distributer.
That typically includes a thorough review of the potential seller's quality system and some sort of commercial agreement. Aircraft Spruce has no such agreements in place as far as I know. They are "pure" distributors with no in-house FAA approved quality system and they aren't required to have one since they're supposed to provide traceability for parts to be installed on production aircraft.
Operators don't seem to see the value added by providing proper documentation. Without it, your part may well be "bogus". it doesn't matter if it looks like, feels like, or smells like the right part, it may very well have been manufactured by anyone using any random quality control.
http://www.avbuyer.com/PDFs/Bogus%20Parts%20Aug06.pdf
I would highly caution any AME considering installing undocumented parts on aircraft. Your customer may seem like a "common sense" kind of guy who wouldn't blame you if the tire you installed failed at a critical time and caused damage to his airplane, but that can change in a hurry when he's being challenged in court to take responsibility for damages. And let's not forget the lawyers.
Do you think a lawyer is going to forgive you for your "common sense" approach of installing tires with no traceability documentation? And believe me, if you invalidated the C of A in that manner, it won't even matter if the tires came right from the same factory as documented tires.
Surplus parts from a US supplier can't be installed on aircraft without an 8130-3 or a conformity statement backed by a "direct ship" authority from the aircraft manufacturer. That means that Aircraft Spruce would either need to pay an authorized repair station to issue the 8130-3 or enter in to an agreement with the aircraft manufacturer to act as an authorized distributer.
That typically includes a thorough review of the potential seller's quality system and some sort of commercial agreement. Aircraft Spruce has no such agreements in place as far as I know. They are "pure" distributors with no in-house FAA approved quality system and they aren't required to have one since they're supposed to provide traceability for parts to be installed on production aircraft.
Operators don't seem to see the value added by providing proper documentation. Without it, your part may well be "bogus". it doesn't matter if it looks like, feels like, or smells like the right part, it may very well have been manufactured by anyone using any random quality control.
http://www.avbuyer.com/PDFs/Bogus%20Parts%20Aug06.pdf
I would highly caution any AME considering installing undocumented parts on aircraft. Your customer may seem like a "common sense" kind of guy who wouldn't blame you if the tire you installed failed at a critical time and caused damage to his airplane, but that can change in a hurry when he's being challenged in court to take responsibility for damages. And let's not forget the lawyers.
Do you think a lawyer is going to forgive you for your "common sense" approach of installing tires with no traceability documentation? And believe me, if you invalidated the C of A in that manner, it won't even matter if the tires came right from the same factory as documented tires.
Re: 8130 Form
According to TC, there would be traceability documentation, as canadian distributors at least (I understand in the US this is NOT so) are *required* to be able to prove the sourcing of the part if required, which is why paragraph d) makes it sufficient to have a signed document from the distributor attesting that the part is indeed authentic.
I'm not trying to suggest any one circumvent the rules, but at the same time, don't try and make it more complciated than it has to be while following them. If TC says that a "signed distributor release document" is enough, and that "Distributors are required to provide “traceability” to the original certification of product conformity or where necessary certified true copies of the certification document.", and my distributor has provided such a release document, then I (and the AME) am fully compliant with the rules, and I see no cause for concern.
Someone can fake a document such as an 8130 just as well, in the end, you've got to trust someone at some point, whether it's the "release document" or an 8130, or a Form 1, etc ...
So if my tire fails in some suspicious way, I could then just go back to AS and have them provide traceability, as required of Canadian distributors. Thsi would probably be done even if I had gotten an 8130 anyways!
I'm not trying to suggest any one circumvent the rules, but at the same time, don't try and make it more complciated than it has to be while following them. If TC says that a "signed distributor release document" is enough, and that "Distributors are required to provide “traceability” to the original certification of product conformity or where necessary certified true copies of the certification document.", and my distributor has provided such a release document, then I (and the AME) am fully compliant with the rules, and I see no cause for concern.
Someone can fake a document such as an 8130 just as well, in the end, you've got to trust someone at some point, whether it's the "release document" or an 8130, or a Form 1, etc ...
So if my tire fails in some suspicious way, I could then just go back to AS and have them provide traceability, as required of Canadian distributors. Thsi would probably be done even if I had gotten an 8130 anyways!
Re: 8130 Form
Aircraft Spruce is a US company, based in California. Even if you buy parts from Brantford, ON, you are still doing business with an American organisation. The rules for Canadian distributors don't apply.
If you read a little further down Airworthiness Notice - B073, Edition 1 - 3 February 2006 (link as posted previously) you will see the requirements for parts sourced from a US distributor.
It's explicit in this case that an 8130-3 is not required, because it is not required under US regulations.
However it also states: "Receiving parts from a U.S. distributor also differs from our regulations in that distributors in the U.S. are not approved by the FAA, but rather controlled through a voluntary industry distributor accreditation program. Parts procured from such “accredited distributors” will convey an assurance to the purchaser that the part (s) is/are the quality stated and that the appropriate documentation is on file at the distributor’s place of business. However, the original document or a certified true copy must accompany the part."
It is not 100% clear to me which document here is being referred to here - and I will try to find out from TC.
If you read a little further down Airworthiness Notice - B073, Edition 1 - 3 February 2006 (link as posted previously) you will see the requirements for parts sourced from a US distributor.
It's explicit in this case that an 8130-3 is not required, because it is not required under US regulations.
However it also states: "Receiving parts from a U.S. distributor also differs from our regulations in that distributors in the U.S. are not approved by the FAA, but rather controlled through a voluntary industry distributor accreditation program. Parts procured from such “accredited distributors” will convey an assurance to the purchaser that the part (s) is/are the quality stated and that the appropriate documentation is on file at the distributor’s place of business. However, the original document or a certified true copy must accompany the part."
It is not 100% clear to me which document here is being referred to here - and I will try to find out from TC.
DId you hear the one about the jurisprudence fetishist? He got off on a technicality.
Re: 8130 Form
I would be very surprised if TC said they didn't agree. They were the ones who wrote the Airworthiness Notice that says that.kamikaze wrote:"Note the "or a signed distributor release document" part. You don't necessarily need an 8130-3 to install a part on an aircraft. Some AME's think you do, but if one is familiar enough with the regs ,you can plainly see that you don't. Hope this helps."
If I (or my AME) ask Transport Canada, will they agree with that statement ?
Re: 8130 Form
I've just spoken to a TC officer on a very similar subject. He said some useful things including this: that AN B073 is advisory, not mandatory, and you can't be busted for not complying with it. You can only be busted for not complying with the CAR's; CAR 571 is the one that applies, specifically 571.07.
DId you hear the one about the jurisprudence fetishist? He got off on a technicality.
Re: 8130 Form
"Aircraft Spruce is a US company, based in California. Even if you buy parts from Brantford, ON, you are still doing business with an American organisation. The rules for Canadian distributors don't apply."
Any company operating in Canada with a location in the country has to be registered in Canada (if federally registered) or in their case, Ontario (if provincially registered). If they're located in Canada, charging Canadian sales taxes, then they're a canadian company under canadian law. There's just asome sort of relationship with the US counterpart (just like GM Canada is a canadian company, even if it's GM).
"I would be very surprised if TC said they didn't agree. They were the ones who wrote the Airworthiness Notice that says that."
I would think so too ... but you never know ...
"I've just spoken to a TC officer on a very similar subject. He said some useful things including this: that AN B073 is advisory, not mandatory, and you can't be busted for not complying with it. You can only be busted for not complying with the CAR's; CAR 571 is the one that applies, specifically 571.07."
OK, but I wonder how TC itself went from 571.07 to "signed release document" ... ? It is their own interpretation after all.
Any company operating in Canada with a location in the country has to be registered in Canada (if federally registered) or in their case, Ontario (if provincially registered). If they're located in Canada, charging Canadian sales taxes, then they're a canadian company under canadian law. There's just asome sort of relationship with the US counterpart (just like GM Canada is a canadian company, even if it's GM).
"I would be very surprised if TC said they didn't agree. They were the ones who wrote the Airworthiness Notice that says that."
I would think so too ... but you never know ...
"I've just spoken to a TC officer on a very similar subject. He said some useful things including this: that AN B073 is advisory, not mandatory, and you can't be busted for not complying with it. You can only be busted for not complying with the CAR's; CAR 571 is the one that applies, specifically 571.07."
OK, but I wonder how TC itself went from 571.07 to "signed release document" ... ? It is their own interpretation after all.
Re: 8130 Form
CAR 571.07 is the regulation and it is law. You have to comply with it or you are breaking Canadian law. CAR 571.07 AWM is the standard which further explains and clarifies the requirement of the regulation. Since sometimes the standards are still not clear enough, TC gets inundated with the same question about a standard. In response to that they put out some kind of publication which really spells it out what the standard is talking about. In this case it is AN B0073. It is not a legal requirement, but only informational to help you understand the regulation. In some cases CAR 571.07 means that you will need an 8130-3 or a Form One. In other cases all you may need is a signed release document, or even no certification at all. It depends on the situation.kamikaze wrote: "I've just spoken to a TC officer on a very similar subject. He said some useful things including this: that AN B073 is advisory, not mandatory, and you can't be busted for not complying with it. You can only be busted for not complying with the CAR's; CAR 571 is the one that applies, specifically 571.07."
OK, but I wonder how TC itself went from 571.07 to "signed release document" ... ? It is their own interpretation after all.
Re: 8130 Form
Looks like it's all in how you ensure the origin of the part in the end. What no one's talked about is the Airworthiness Manual - 563, quoted as a reference in the AN, which I went to have a look at.
That document clearly specifies the standards to which distributors are held, including selling approved parts, from valid manufacturers, etc ...
So for things like tires, which are certified under TSO only (not PMA or STC), the only thing you would normally do is trace their history, which the "signed release document" would satisfy in Canada, given the constraints put on the distributor itself. In other words, the regulations control the supply chain too (in the US, this is voluntary, in Canada, it's regulated), so you can trsut the supply chain to give you valid parts in Canada.
This seems to make sense to me (for some bizarre reason, analyzing and understanding regulation is a chllenge I enjoy ... I know, that's weird).
Anyways, I've heard all the view points and opinions, so we'll see what I'll do with the information, and what my AME will think fo it all.
Thanks everyone.
That document clearly specifies the standards to which distributors are held, including selling approved parts, from valid manufacturers, etc ...
So for things like tires, which are certified under TSO only (not PMA or STC), the only thing you would normally do is trace their history, which the "signed release document" would satisfy in Canada, given the constraints put on the distributor itself. In other words, the regulations control the supply chain too (in the US, this is voluntary, in Canada, it's regulated), so you can trsut the supply chain to give you valid parts in Canada.
This seems to make sense to me (for some bizarre reason, analyzing and understanding regulation is a chllenge I enjoy ... I know, that's weird).
Anyways, I've heard all the view points and opinions, so we'll see what I'll do with the information, and what my AME will think fo it all.
Thanks everyone.
Re: 8130 Form
- not quite. It specifies the standards to which approved distributors are held. The inspector yesterday told me that there's no requirement to use an approved distributor in Canada; you can get parts from anywhere.That document clearly specifies the standards to which distributors are held
Presumably getting them from an approved distributor discharges your responsibilities to ensure traceability etc; otherwise, you have to do the work yourself.
DId you hear the one about the jurisprudence fetishist? He got off on a technicality.
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ruddersup?
- Rank 5
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- Joined: Wed Apr 09, 2008 7:10 pm
Re: 8130 Form
It seems to me the issue is to have traceabiltiy back to the manufacturer to confirm a legit part.
Well tires have a manufacturer name, model, serial number and batch number. What else is needed?
Should be able to talk your way through tires by, if nothing else, calling the manufacturer if you were challanged. Other parts without such details are more of a problem.
Anyone agree with this?
Well tires have a manufacturer name, model, serial number and batch number. What else is needed?
Should be able to talk your way through tires by, if nothing else, calling the manufacturer if you were challanged. Other parts without such details are more of a problem.
Anyone agree with this?
Re: 8130 Form
And this is a Rolex watch.
It says ROLEX right on it so it must be a Rolex right?
It says ROLEX right on it so it must be a Rolex right?
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ruddersup?
- Rank 5
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- Joined: Wed Apr 09, 2008 7:10 pm
Re: 8130 Form
CID,
I was just trying to help Rudder Bug and his AME out here so they would not have to return the tires for an 8130 tag. Myself I would look the other way, this time, just because of the product and traceability on the tire. Go ahead and beat me up, I'm new to the industry.
I was just trying to help Rudder Bug and his AME out here so they would not have to return the tires for an 8130 tag. Myself I would look the other way, this time, just because of the product and traceability on the tire. Go ahead and beat me up, I'm new to the industry.
Re: 8130 Form
Inspect the tires, are they serviceable? That's what it comes down to.
Re: 8130 Form
CID said this before. It's worth posting again.
It's best to stick with reputable dealers that provide certification. Is it really worth saving 75 bucks a tire?
Unfortunately, without the PROPER certification, you open up a can of worms that is not worth getting into. Just because the tires have markings that "give you traceability", doesn't mean they are real. Outfits that make bogus parts know how to put on bogus markings as well. I've seem some exquisitley made swashplate parts for Bell medium helicopters bearing all the requierd markings, that we were able to identify as bogus before they got installed.I would highly caution any AME considering installing undocumented parts on aircraft. Your customer may seem like a "common sense" kind of guy who wouldn't blame you if the tire you installed failed at a critical time and caused damage to his airplane, but that can change in a hurry when he's being challenged in court to take responsibility for damages. And let's not forget the lawyers.
Do you think a lawyer is going to forgive you for your "common sense" approach of installing tires with no traceability documentation? And believe me, if you invalidated the C of A in that manner, it won't even matter if the tires came right from the same factory as documented tires.
It's best to stick with reputable dealers that provide certification. Is it really worth saving 75 bucks a tire?
Re: 8130 Form
And just how many times would you be willing to "look the other way"? If you're new to the industry, you've already got the wrong attitude. You really need to consider what you're doing when you turn a blind eye to something you know that is wrong. Sure, nothing may happen 99 times out of 100, but it's that 1 time that can cause painful issues that last a life time.ruddersup? wrote:CID,
I was just trying to help Rudder Bug and his AME out here so they would not have to return the tires for an 8130 tag. Myself I would look the other way, this time, just because of the product and traceability on the tire. Go ahead and beat me up, I'm new to the industry.
Last edited by robertw on Thu May 19, 2011 12:06 pm, edited 1 time in total.
Re: 8130 Form
"Serviceable" is a pretty subjective term. The question is whether or not the tire is "airworthy". At least that's the legal question that the AME is answering when the replacement is signed off.
The CARS define airworthy as follows: "airworthy: in respect of an aeronautical product, means in a fit and safe state for flight and in conformity with its type design".
An AME can't determine if the airplane or the tire for that matter is "in conformtity with its type design" without a tag that provides traceability of the tire.
The CARS define airworthy as follows: "airworthy: in respect of an aeronautical product, means in a fit and safe state for flight and in conformity with its type design".
An AME can't determine if the airplane or the tire for that matter is "in conformtity with its type design" without a tag that provides traceability of the tire.
Re: 8130 Form
Want to give your insurance company a loop hole not to pay, or a lawyer an open check book, install parts on a certified aircraft with out traceability, or do not make log entries. You may get away with it for a while, but it could bite you when you least expect it. Not to mention giving TC the oportunity to ground your aircraft
Keep it safe guys
Keep it safe guys
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ruddersup?
- Rank 5
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Re: 8130 Form
Rudder Bug is approved with elementary maintenance to install his own purchased tire. He probably wouldn't know an 8130 tag or a conformity form. Fat dumb and happy he puts on the Aircraft Spruce tire. What' the problem? Of course I understand what you guys are saying about bogus parts but I bet some of you are doing bogus work, that' a whole other topic, right. Don't get too anal, it is slowly killing general aviation. I worked with the Airworthiness Manual and the E & I manual, now the friggen CARS. Transport would rather you not fly but if you have to then......................hmmmmmm. GET IT? Use your common sense. Who the hell is going to make a bogus tire for $50?
Re: 8130 Form
The text of the rules have changed but the requirement for traceable parts hasn't. By the way, the airworthiness manual is part of the CARs. They aren't two different things.
When you do maintenance and replace parts, your airplane either conforms to the type design or it doesn't. That means that legally your C of A is in force or it isn't.
The maintainer or operator might not care but at very least the insurance company does. And they'll be doing cartwheels when they find out they don't have to pay out because the owner/operator didn't fulfill his part of the contract and keep the C of A valid.
It's not a question of being anal. It's a question of integrity. Are you suggesting everyone just turn a blind eye to stimulate general aviation? Who's gonna make a bogus tire? Maybe the same guy who made the bogus bolts that some poor CV580 operator installed causing the vertical stab to fall off.
http://en.wikipedia.org/wiki/Partnair_Flight_394
When you do maintenance and replace parts, your airplane either conforms to the type design or it doesn't. That means that legally your C of A is in force or it isn't.
The maintainer or operator might not care but at very least the insurance company does. And they'll be doing cartwheels when they find out they don't have to pay out because the owner/operator didn't fulfill his part of the contract and keep the C of A valid.
It's not a question of being anal. It's a question of integrity. Are you suggesting everyone just turn a blind eye to stimulate general aviation? Who's gonna make a bogus tire? Maybe the same guy who made the bogus bolts that some poor CV580 operator installed causing the vertical stab to fall off.
http://en.wikipedia.org/wiki/Partnair_Flight_394
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torquey401
- Rank 3
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Re: 8130 Form
This thread is interesting.
The answer is pretty easy to find. Tires are considered standard parts in that they should meet a TSO. The requirements for standard parts require traceability at a minimum. An 8130 is one way to prove it, but so is a packing slip. As long as you can back one step in the process, you should be good.
I don't have the CARS link handy, but it is there. Google it!
The answer is pretty easy to find. Tires are considered standard parts in that they should meet a TSO. The requirements for standard parts require traceability at a minimum. An 8130 is one way to prove it, but so is a packing slip. As long as you can back one step in the process, you should be good.
I don't have the CARS link handy, but it is there. Google it!
Re: 8130 Form
torquey401, here's a scenario to consider. A tire manufacturer finds a defect in a batch of tires. Maybe some lettering got fouled up or the cure time was wrong or some materials were past their shelf life. They decide to unload the "defective" stock to someone to use on non-aerospace applications. Anything from agricultural vehicles to raw material for some product that can use shredded tires.
An unscrupulous middle-man sells a set of tires to an aircraft owner and provides a packing slip. The packing slip just proves you got it from some guy who didn't give you an airworthiness release. The guy who installed the tires has just done something contrary to the Aeronautics act, ie:broken the law
A packing slip is not an airworthiness release.
An unscrupulous middle-man sells a set of tires to an aircraft owner and provides a packing slip. The packing slip just proves you got it from some guy who didn't give you an airworthiness release. The guy who installed the tires has just done something contrary to the Aeronautics act, ie:broken the law
A packing slip is not an airworthiness release.
Re: 8130 Form
I would think the manufacturer should then mark the tires in some way, either by adding a new marking or obscuring an existing one.
If someone can go through the trouble to manufacture a bogus part surely they can manufacture a 8130 as well. Its not exactly a high security document.
I just went through this for a muffler on a 172, the muffler had the FAA PMA markings, serial number etc, the actual manufacturer could confirm that it was suitable for the particular model of 172 that we were installing it on but aircraft spruce did not provide an 8130 (because I didn't want to pay $100 for a piece of paper I guess). They did have a statement of conformity on their invoice but this still did not satisfy my AME, I ended up having to work with the manufacturer to get this resolved.
If someone can go through the trouble to manufacture a bogus part surely they can manufacture a 8130 as well. Its not exactly a high security document.
I just went through this for a muffler on a 172, the muffler had the FAA PMA markings, serial number etc, the actual manufacturer could confirm that it was suitable for the particular model of 172 that we were installing it on but aircraft spruce did not provide an 8130 (because I didn't want to pay $100 for a piece of paper I guess). They did have a statement of conformity on their invoice but this still did not satisfy my AME, I ended up having to work with the manufacturer to get this resolved.
Re: 8130 Form
cgartly, an 8130 is an airworthiness release that is issued from an approved source. If you get a part from a supplier without qualifying them, you're in a "buyer beware" situation. The courts aren't going to care that you got swindled by a dishonest supplier with a phony 8130. They will just determine that your C of A was in force, or it wasn't. That's the odd thing about this discussion. The system is in place to ultimately protect the operator. To make sure the parts you buy are airworthy and that your C of A remains in force.
People seem to willing to accept possibly substandard parts or parts without adequate traceability just to save a few bucks. The general public tends to be convinced that people who own and operate airplanes maintain them to a higher standard than an automobile. It appears that many aircraft owners don't prescribe to that.
When I buy parts from the US to put on an airplane, I don't even think twice. I want to see an 8130 or a Form 1. Reading about so many going around that system and accepting the consequences is a little disturbing.
I appreciate that owning an airplane is expensive. That's why you don't see a lot of welfare recipients own them. Owning a car is expensive too but I wouldn't recommend you never change the oil or tires or use straight water in the radiator because it's cheaper.
People seem to willing to accept possibly substandard parts or parts without adequate traceability just to save a few bucks. The general public tends to be convinced that people who own and operate airplanes maintain them to a higher standard than an automobile. It appears that many aircraft owners don't prescribe to that.
When I buy parts from the US to put on an airplane, I don't even think twice. I want to see an 8130 or a Form 1. Reading about so many going around that system and accepting the consequences is a little disturbing.
I appreciate that owning an airplane is expensive. That's why you don't see a lot of welfare recipients own them. Owning a car is expensive too but I wouldn't recommend you never change the oil or tires or use straight water in the radiator because it's cheaper.
Re: 8130 Form
To continue with your metaphor, I don't think anyone was suggesting not changing the oil or tires, or using straight water. I think the thing that hurts is being mandated to use expensive, special oil and tires that are specially expensive because they come with a special bit of paper to tell you all about how special they are.but I wouldn't recommend you never change the oil or tires or use straight water in the radiator because it's cheaper.
DId you hear the one about the jurisprudence fetishist? He got off on a technicality.
