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FAA Part 91 - legal process for using used parts?

Unfortunately, as we all know, large chunks of the maint business don’t want to know because a part with “aviation paperwork” brings much more bread to the table at home, and this is true in the US

I have discussed with more A&Ps than I can recall that no paperwork is required for parts installed on an N-registered plane used for Part 91 operations, and it is a source of amusement to them that some of their customers don’t know that to be true. However the only place I have seen this issue actually be the subject of a debate that includes people doing this as their livelihood (?) is on EuroGA.

All airframe parts I buy for my N-registered plane come with an EASA Form 1, which gets filed in my records and never seen by anybody but me. They do not come with an 8130, and it is no issue whatsoever for anybody.

Last Edited by Silvaire at 19 Apr 14:19

There is some pretty good stuff in that doc – thanks for posting it.

Unfortunately, as we all know, large chunks of the maint business don’t want to know because a part with “aviation paperwork” brings much more bread to the table at home, and this is true in the US and even more in Europe.

Administrator
Shoreham EGKA, United Kingdom

You might try finding an FAA regulation that requires parts traceability paperwork for airliners, and then note that the same regulation does not exist for GA.
There are no FAA regulations to specify what is not required.

The A&P does not BTW document any particular inspection or declare anything in any formal sense. He just makes an installation logbook entry that states he installed a particular part, noting that it was a used, serviceable part. A (non-IA) A&P mechanic is not an inspector but in this case no formal inspection is required, just a functional check if applicable.

A friend just finished harvesting some parts off a Debonair that’s being parted out by a guy at a nearby airport, control surfaces mostly because his ailerons and flaps have minor hail damage that apparently cannot be legally filled-in by the paint shop. The plane has already been repainted so the ‘new’ parts will be cleaned up and repainted too before installation. I learned in going over this with him that Debonair ailerons come off and go on very easily. He got a very good deal on the parts, almost a gift, but his $45K Debonair is none the less a $100K Debonair now His current engine was also bought used, and he sold the original as a core. It’s become a really nice plane over time.

Prior to this project he rebuilt what is now a beautiful Globe Swift at home, from multiple aircraft but using one of them for the C of A and N-number. A 210 HP engine was installed via an STC and came out of a Skymaster (used). The best mount for that conversion is that from a Reims Rocket or T-41, and is hard to find. He’s not an A&P but I believe he has a guy he’s worked with for a long time who supervises and signs off the work (and parts). The two planes are stored in adjacent hangars and are what keeps him busy as a recent retiree.

Last Edited by Silvaire at 18 Apr 14:36

I think @ncyankee and @silvaire will be the authorities on this, but I strongly suspect you will not find a US reg stating that you need an 8130-3 for something.

The US is full of Repair Stations and these routinely issue an 8130-3 (because it looks good and anyway they alone are authorised to issue one) but practically all the work one can do on a plane (context: unpressurised GA, Part 91) can be done by an A&P. This includes an engine overhaul. Not a prop overhaul, and a prop shop must be 145, so you will get an 8130-3 with a prop.

And an A&P has the authority to inspect a part and declare it airworthy (or not). This is one thing which Europe just can’t get its head around. Yeah – you probably now want a reference for that

Administrator
Shoreham EGKA, United Kingdom

Silvaire wrote:

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.

Old thread revival. I was looking to find the reference for this in the FAA regs. The best I could come up with was these:

https://www.ecfr.gov/current/title-14/chapter-I/subchapter-C/part-43/section-43.13
https://www.ecfr.gov/current/title-14/chapter-I/subchapter-C/part-43/section-43.9

Has someone else here researched the matter, and got a better link to the relevant scripture to quote…

Buying, Selling, Flying
EISG, Ireland

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.

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

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.

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
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