Menu Sign In Contact FAQ
Banner
Welcome to our forums

FAA Part 91 - legal process for using used parts?

US Ebay carries a lot of avionics.

It is well known that a lot of this stuff is nonworking crap, but a lot of it is perfectly OK and there is even some new or as-new stuff which was never installed. And many European pilots, needing their shagged old ADF fixed, buy replacements on US Ebay and if it works...

Assuming you get a piece with no documentation, what is the procedure for installing it?

My understanding is that an A&P has the authority to inspect an item and declare it serviceable (or not).

Is installing it and establishing proper functionality a sufficient discharge of this process?

In the UK, there is all the usual folklore about needing an 8130-3 form, or a "yellow tag" (which I believe is a US-only thing whereby the firm that removed the item confirmed it was then working).

Under EASA this folklore grows exponentially, as always, with an EASA-1 form being mandatory for the toilet paper used in between inspections. Superficially it appears that an 8130-3 is good for an EASA-reg plane if the part is new (usually this bit is gold plated by adding that the 8130-3 has to be from the original manufacturer) but an EASA-1 form is required if it is not new (even if you owned it since new and just had it overhauled or repaired).

But I see a lot of the same folklore posted on US pilot forums too so clearly there is much confusion.

To get a fresh 8130-3 issued, you need to process the item via a Part 145 Repair Station whose scope includes that specific type of work; same for an EASA-1 form. Some people do this when selling a used item; it does improve the saleability but whether it improves it sufficiently is debatable. But getting an 8130-3 issued for say an annunciator which you picked up on Ebay for $10 is just silly.

Administrator
Shoreham EGKA, United Kingdom

Under part 43, Appendix A, subsection C, preventive maintenance, task 31:

(31) Removing and replacing self-contained, front instrument panel-mounted navigation and communication devices that employ tray-mounted connectors that connect the unit when the unit is installed into the instrument panel, (excluding automatic flight control systems, transponders, and microwave frequency distance measuring equipment (DME)). The approved unit must be designed to be readily and repeatedly removed and replaced, and pertinent instructions must be provided. Prior to the unit's intended use, and operational check must be performed in accordance with the applicable sections of part 91 of this chapter.

My log entry would be: Date 8-20-2013, tach 789.0, removed KR87 serial number 1234, replaced with KR87 serial number 4567. Function test OK. Signed Joe Pilot 12345678

KUZA, United States

Assuming you're just swapping the same part, non-tray mounted and including airframe parts etc, an A&P maintenance log book entry is what you need. It typically reads something like this:

Date, removed widget P/N xxxxxx, installed used serviceable widget same part number, serial number xxxxxx. Tested for satisfactory operation. Signed, A&P Certificate Number.

No additional paperwork is required.

For direct replacement slide-in radios of the same part number, I understand from NCYankee's post that the pilot can make the logbook entry, but you can imagine that many owners don't complete the logbook entry they'd need to follow the letter of the law.

OK; I was aware of the pilot privileges for swapping over certain classes of tray mounted avionics (true in EASA-land too) but I was wondering about what an A&P can do.

If an A&P can declare a part serviceable, an 8130-3 has very little value, because it could be an old 8130-3 (which came with the item originally) whose issue was followed by the item being installed for years and even failed during that time.

A lot of Ebay stuff is so cheap that you could just buy one ADF after the other until you get one that works.

Administrator
Shoreham EGKA, United Kingdom

An 8130-3 does indeed have limited value for an N-registered privately operated aircraft, because there are a very limited number of items that require an FAA Repair Station for release to service. Two items that I understand do require a Repair Station are instrument overhauls (the A&P can install but not overhaul an instrument) and transponder checks.

Otherwise, replacing components with new or used replacements requires only an A&P logbook entry - including (for what its worth) overhauling or replacing engine components. Most A&Ps would prefer that a Repair Station sign off on engine components before installation, but they do have authority to do it themselves if they are assembling an engine - which they can legally do because engine assembly does not require a Repair Station either. In terms of paperwork what that means is that yellow tags, never mind 8130-3s, are not mandatory and do not legally need to be retained in the aircraft records. Neither must there be a work order covering the A&Ps work, just his aircraft maintenance logbook entry. All that stuff may be useful commercially when you sell the aircraft, but not a legal requirement.

Once you start striping away bureaucracy, it progresses in a geometric fashion.

Silvaire

I am not so sure about it. Years ago i could install parts with yellow tag, then one day all shops started to demand 8130, we were told at the time that the FAA demands it as the parts cross border i.e. being exported. Further more, once I had to replace a trim tab that was bought from a salvage yard in the US (the FAA rep. at Heathrow provided the details where to find the part). The part arrived with details of the aircraft that the part came from and that was enough (however, the FAA guy wanted tests to prove that the part is genuene).

then one day all shops started to demand 8130

UK shops, yeah............

One problem is that most people in the business either can't read or don't want to read (a fairly good indication of which is whether they can read and write emails of more than 1 line) and consequently don't want to put their name to anything unless it is gold plated.

I often hear of this from the USA but clearly it is much worse here in Europe.

Under the FAA system, and A&P or A&P/IA signs on behalf of himself and the buck stops with him. So he needs to be careful.

Under the EASA system, you have an organisational approval so nobody is personally responsible.

Administrator
Shoreham EGKA, United Kingdom

US private aviation would stop if you needed an 8130 to install a used part. Check Barnstormers and see the parts being traded between owners - those parts are going on aircraft, installed and approved by A&Ps. Locally, parts are traded between hangars/owners and installed every day. Its perfectly legal and not in the slightest bit unusual, quite the contrary as long as there's an appropriate maintenance logbook entry.

A guy I know (one of my aircraft is in his hangar right now) is an FAA DAR who approves parts for export from the USA as his business, so that is certainly normal. However, exporting parts is a separate issue than simply installing used parts on an N-registered aircraft once the mechanic has them on hand. Also, without being 100% sure on this one I believe that when a part is physically exported outside of the US for use on an N-registered aircraft it is not 'exported' in the FAA sense of the word. Regardless of where he is or where the part came from, once the A&P has the part he does not need an 8130 to install it or make an acceptable logbook entry for a privately operated N-registered aircraft.

Another local friend designs and manufactures new parts for new, certified aircraft as part of his business. If the part is normally supplied by the airframe manufacturer under their own part number, when my friend supplies the part to somebody local he gets an 8130 from his customer, the airframe manufacturer. They'll do that as a favor and it allows him to supply the new part directly without a PMA. Sometimes he has to ship them the part and then they ship it back untouched! But again that's different than for used, serviceable parts or installing new parts manufactured under FAA PMA, as they normally are.

Also, without being 100% sure on this one I believe that when a part is physically exported outside of the US for use on an N-registered aircraft it is not 'exported' in the FAA sense of the word. Regardless of where he is or where the part came from, once the A&P has the part he does not need an 8130 to install it or make an acceptable logbook entry for a privately operated N-registered aircraft.

I am certain that is correct.

The "Export CofA" document serves a different purpose, but I am not sure what it is. Previously (some notes here from a few years ago) the 8130-4 form was required by the UK CAA for Class 1 components (engines and props) if they were to go onto a G-reg. Otherwise, the JAR-1 form (today EASA-1) was required. But I heard recently that the FAA stopped doing the 8130-4 so the UK CAA had to accept the 8130-3.

It is well known that the Export CofA form is generated for whole-aircraft registry transfers, to enable the accepting registry to accept it. It is some sort of bizzare ICAO paperwork maneuver.

I am sure your DAR will know the exact status.

I've just looked up Barnstormers - what an amazing site! People are selling all kinds of bits. I am going to put my KCS55 slaved HSI bits on there - many thanks for the pointer There are loads of avionics adverts there, and the general quality seems a lot better than Ebay where most of it is junk.

You would make a great A&P/IA, Silvaire

Administrator
Shoreham EGKA, United Kingdom

You would make a great A&P/IA, Silvaire

It's easiest if you do it before you get a 'real job'. I understand the IA bit is actually not that big a deal but the basic A&P certificate requires time and effort at the local community college, or applicable experience. I know people who earned the A&P part time to work on their own aircraft, but many others kind of backed into it with applicable experience gained in their early working lives.

Perhaps after retirement... which is sadly not on the near horizon as yet. Luckily the instructor who taught me to fly is also an A&P IA and a couple of other friends are A&Ps. Plus the DAR. They find me amusing and tolerate me :-)

Barnstormers was started by somebody I've met, and a friends wife helped on the weekends sometimes. It started small but has become a bit of a big deal. It's surely very useful, I agree.

16 Posts
Sign in to add your message

Back to Top