8130 Form

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Rudder Bug
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8130 Form

Post by Rudder Bug »

I am in the process of the annual of my certified Piper PA-22. My AME asked me to buy some new tires so I did.

Odered a pair of McCreary 600 x 6 yesterday morning and the're on their way, which is fine.

Now my AME asks me if I asked for a 8130 form. I call back and I'm told they can not provide a 8130 form on an already ordered part.

The only way to change my tires legally is to send them back, pay shipment both ways and order again THE SAME tires WITH the 8130 form. The darn piece of paper is $100.

If I don't, my aircraft won't be airworthy because it has new tires.

I now understand why 1/3 of an Canadian registered aircraft is politics!

:twisted:
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Re: 8130 Form

Post by AME 283 »

:prayer: Welcome to the regulatory world of TC, more to do with paper than safety :prayer:

Mind you any supplier worth their salt should have sent you the paper work
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Rudder Bug
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Re: 8130 Form

Post by Rudder Bug »

That was Aircraft Spruce and they're now telling me I should have ordered the form with the tires, for a slight supplement of $100.

I am anxious to see what my AME will do with it when he sows up to comlete the annual Saturday morning...

What would YOU do?

RB
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Re: 8130 Form

Post by SeptRepair »

Good question, what would I do. Im at the point I could gave a careless about some stupid piece of paper that miraculously certified those tires. Of course there are those sitting on the side lines waiting to crucify a guy if he signs off the install with out that magic piece of paper. Personally I would just install the tires and use a copy of the invoice as a traceability that the part was secured from a known reliable source.
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Last edited by SeptRepair on Wed Feb 23, 2011 8:54 am, edited 1 time in total.
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Re: 8130 Form

Post by Bulawrench »

One of the problems is always customer acquired parts. Most of us old schoolers remember a different time.
If the part was purchased for a Lindair type of source they know to supply it.I have had the same problem from aircraft spruce.
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Rudder Bug
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Re: 8130 Form

Post by Rudder Bug »

Thanks a bunch for your input gentlemen!

I just found out in the CAR's that replacing a tire on a small aircraft is part of the Elementry Maintenance list thus can be performed by the ownwer.

http://www.tc.gc.ca/eng/civilaviation/r ... a-2458.htm

Bula vinaka!

RB
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Re: 8130 Form

Post by iflyforpie »

You've really got to watch dealing with Aircraft Spruce. They cater more to the homebuilt crowd and though I've got certified parts from them before they don't really differentiate unless you hound them.

Every part you buy should have some type of certification, even if it is just written the packing list/invoice (which is how Leavens and Lindair usually do it).
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mmartin1872
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Re: 8130 Form

Post by mmartin1872 »

I've found most Aircraft Spruce invoices, have the 'certification statement' on the bottom of them also..
Atleast every order i've placed.
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Re: 8130 Form

Post by BeaverFixer »

My rant for the day: Aircraft Spruce Canada sells parts cheaper than I, as an AMO can buy them supposedly wholesale.
That makes it tough for me to supply parts. I checked on a starter from Aviall (supposed to be wholesale) and my price was about $50.00 more than the owner could buy it himself from Spruce. I leaned on Aviall and they said the Spruce price was close to their cost, no way could they match it. So, I told the customer to order it himself.
Tires, batteries etc I can usually compete, but mainly because I have them on the shelf. A cutomer looking for a EI engine scanner system or any bigger ticket item can buy it for the same price as me as an AMO.
Not trying to get rich on parts, but I have to make a little mark up.
Sometimes I get to smile, like when the customer shows up with his new Spruce supplied compass that he got a screamin deal on, only to find it is made in China for uncertifed use only.
I second, you have to watch what Aircraft Spruce sells you if it going on a certifed aircraft. They seem to cater more to the homebuilt market.
Sorry to rant off topic. I feel better now though.
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Re: 8130 Form

Post by tiny »

Beaver Fixer, If you cann't buy it cheaper else where then why not buy it from spruce?

As for the 8130, its not necessary as long as you have the conformity certificate (Statement on the invoice)

Tiny
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Re: 8130 Form

Post by brownbear »

AMO guy,
I would charge a 10% administrative fee on customer supplied parts. or 25 bucks minimum, as there is work for you to ensure they did the right amount of qa when ordered. Also state in the jl entry the parts were customer supplied. As they may order something not on your approved vendor list. its all fair.

yah and cheap tire guy, you have to have an AME sign your logbook to qualify for signing the tire install yourself. Has to be approved by an AME one time.

I'd charge 100 bucks for it.
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Re: 8130 Form

Post by robertw »

Rudder Bug,

Please be aware that, yes, changing tires is elementary work for small privately operated aircraft and as such, does not require a maintenance release by an AME, HOWEVER, you must still have the proper certification required by Transport Canada to install anything onto your aircraft. What TC requires for parts varies depending on what you are installing and what classification of part you are installing. This is what the regulations say with regard to installing a "new part" on an aircraft. CAR 571.07:

Installation of New Parts

571.07 (1) No person shall install a new part on an aeronautical product unless the part meets the standards of airworthiness applicable to the installation of new parts and, subject to subsections (2) and (3), has been certified under Subpart 61.
(amended 2007/12/01; previous version)

(2) No certification referred to in subsection (1) is required where

(a) a new part is a foreign-manufactured part that is certified pursuant to an agreement with Canada, which agreement provides for the acceptance of export airworthiness certification;

(b) a new part is a foreign-manufactured part that is obtained from a manufacturer holding a type design recognized in Canada and the part is certified in accordance with the laws of the state of manufacture;

(c) a new part, whose accompanying documentation has been verified, has been inspected in accordance with the requirements of Chapter 571 of the Airworthiness Manual;

(d) a new part is installed on an aircraft that is operated under a special certificate of airworthiness in the owner-maintenance or amateur-built classification; or
(amended 2002/03/01; previous version)

(e) a part is made in accordance with subsection 571.06(4).

(3) No certification referred to in subsection (1) is required in respect of a new part that bears markings identifying it as a part specified in the type design and that

(a) is a standard part;
(amended 2002/03/01; previous version)

(b) is a commercial part;
(amended 2002/03/01; previous version)

(c) is a part that was not originally designed and manufactured for aeronautical use but has been approved for use on the aeronautical product in the type design.
(amended 2009/12/01; previous version)

Transport Canada has also put out AN B0073 to clarify what the requirements are for part certification. Here is what it says about "new parts":


d) New part received from a Canadian distributor:

Must have the original release certificate from the manufacturer/supplier or a signed distributor release document. Distributors are required to provide “traceability” to the original certification of product conformity or where necessary certified true copies of the certification document.

e) New part received from an AMO:

Must have the original release certificate from the manufacturer or the Canadian AMOs own maintenance release tag for the new part, which shall contain traceability back to the original certification of the manufacturer or distributor.

Aircraft Maintenance & Manufacturing Policy Letter #8, Distribution of Aeronautical Products, contains clarification on the distribution privileges of AMOs. The intent of this was not for AMOs to issue a distributor release tag. Rather, the idea was that once an AMO received a part into its own stores and attached its own company tag, the part could be passed to another user with the AMO company tag still attached, indicating that the records for the part (including if applicable the original 24-0078 tag) are on file with the original receiving AMO.

An AMO has several alternatives when exercising their distributor privileges:

They can leave the original manufacturer or distributor tags on the product; or
Develop and use a maintenance release tag which indicates that the certification documents are on file at the AMO; or
Use a standard maintenance release tag and enter the phrase “Receiving Inspection” in the description of work done.

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.
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Re: 8130 Form

Post by Rudder Bug »

Thanks for extensive explanation Robert!

What I like best in it is the two last lines, meaning that I just install the bloody rubbers and staple the ASC invoice in my tech log! Voilà!

:D

Gilles
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Re: 8130 Form

Post by Heliian »

I think if you give the invoice and tyres to the AME, he can then make up a Serviceable tag from his AMO which can then go with the rest of the paperwork. Unless you bought condor tyres in which case, IMO, are not worthy of any certification.

Cheers

I
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Re: 8130 Form

Post by BeaverFixer »

The invoice you get from A/C Spruce does have a certification on the bottom. At first glance it looks like a "conformity certificate".
If you read it, it is definitely not a certification of the products, actually I think it is preprinted on the invoice, the same as the letterhead. It is a preprinted signiture by Jim Irwin, president of Aircraft Spruce. I think it actually says Spruce makes no claims as to the airworthiness of the products.
Some items from Spruce, such as a Slick mag come with an 8130 from Slick right in the box with the mag.
Otherwise you have to ask them for an 8130. I would not put my AMO certification on an item based only on Spruces invoice!
Rudder Bug, what would you tell your AME if he told you he wanted a 10% or $25.00 administration fee to use the owner supplied tires, complete with the $100.00 8130 form?
Thats about what I thought you would tell him.
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Re: 8130 Form

Post by CID »

Reference AC 20-62E.

http://rgl.faa.gov/Regulatory_and_Guida ... 20-62E.pdf

The FAA recognizes a variety of documents for the purpose of properly identifying approved replacement parts. Many of the methods mentioned here don't meet the requirements including statements on the invoice.

And it really doesn't matter if the parts are replaced under elementary maintenance. The part still has to be approved. If you simply ignore the regulations in this instance, your airplane's C of A is out of force since you have unapproved (bogus) parts on it. No C of A, means no insurance. If your airplane is damaged during flight operations, your insurance company can bow out even of the accident had nothing to do with the bogus parts if you knowingly operate without maintaining the C of A. And the AME who signed off the work is exposing himself to all sorts of possible charges for violating 571 regulations.

If a customer insisted on providing parts and there was no certification attached, I would refuse to install them. The risk just isn't worth it and if people here are implying that the extra cost isn't warranted, then I'd like them to think about how much it costs to maintain traceability and certification to the airworthiness rules. I don't know about you "questionable" airplane owners, but I don't do very much for free. As far as "approved" goes, Aircraft Spruce can also provide their own certificate of conformance (I don't think the invoice statement can be used) and often does.

Now, you have to wonder why Aircraft Spruce won't send you the documents after the fact. Why do they need the tires back and why do they have to re-ship?? Well here's the answer:

There is a degree of vigilance that the regulator and operators expect in making sure the parts used are airworthy. That means traceability. Aircraft Spruce doesn't have to maintain traceability on parts unless they are asked to. For uncertified parts, the shelf life of the tires can be expired. They could be seconds or factory rejects that meet the requirements of the basic part number but that can't be certified. So why? Because they can't guarantee the condition of your tires. Is that what you want to install on your airplane?

Its sad but the skies over Canada are quite full of bogus parts and therefore bogus aircraft. Maintainers are as much to blame as the operators.

By the way, this is what Aircraft Spruce says on their order website:

Please note that 8130 forms are not available on all items, and a charge of $100 USD (subject to change without notice) for each line item will be added to your invoice. Products requiring 8130 forms must be special ordered and delays in shipment should be anticipated. Please check with your local authorities prior to placing an order for parts for a certificated a ircraft to see if the Aircraft Spruce Certificate of Conformance on each invoice is sufficient or if 8130 forms are required.
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Re: 8130 Form

Post by SkySailor »

Lots of good info on here! As a recently new owner of a Tripacer, everyday is a learning experience regarding aircraft ownership. Thanks guys!!
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Re: 8130 Form

Post by Rudder Bug »

SkySailor wrote:Lots of good info on here! As a recently new owner of a Tripacer, everyday is a learning experience regarding aircraft ownership. Thanks guys!!
Welcome to the wonderful world of Shortwingers! Where are you located?

Are you logged in there?

http://www.shortwingpipers.org/forum/forum.php

You now know what NOT to do when it comes to order a part hue? :D

RB

P.S.: Please click on my Youtube link below. Your comments are very welcome.
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Re: 8130 Form

Post by SkySailor »

^Thanks for the "shortwing" welcome, RB! The plane is a real joy to fly. And yes, you are quite correct with regards to knowing what NOT to do! I wasn't even aware of the 8130 form :roll: This is what AvCanada excels at- exchange of industry related experiences and advice.

Your YouTube video is well done. Regarding the fabric, care to share info as to where it was done? I've posted another topic on this forum regarding fabric issues on my Tripacer. I'm required to address some fabric issues before passing the annual due in April.

Regarding Shortwing Piper Club, yes, I intend to join. The previous owner passed along a couple of bi-monthly newsletters. The club provides direct access to much needed information specific to Pipers tube and fabric designs.

Your choice of paint scheme is interesting. It's almost identical to mine. The tail is exactly as mine right down to the little stars. Did you use a 1960 paint scheme as a model?

Flying the Tripacer reminds oneself it certainly isn't a Cessna 172 or 150. One attribute I'm still adjusting to is how quickly she stops flying when in the flare. A Cessna seems to float on forever, but the Tripacer "thumps" down. I'm using a touch of power to round things out.

Any Tripacer info or experiences you've had over the years will certainly have an eager listener at this end!
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Re: 8130 Form

Post by Rudder Bug »

What about another thread called "Stubby Piper Talk"? Do you start it or I do? You'd better do it instead of me, it'd be in real English!

RB
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Re: 8130 Form

Post by kamikaze »

Damn, I have this EXACT problem.

The tires are now installed. So I could remove them (really?) to ship them back to get a tag back from them, or try to convince the AME that the invoice is enough, which I'm pretty sure he's not going to be satisfied with, or I buy a new pair of everything and make sure I ask for tags that time, install those, and re-sell the other ones to the experimental world on e-bay.

I really wish there was a way for me to avoid the hard ways! I'll keep reading on the legalities.
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Re: 8130 Form

Post by kamikaze »

"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 ?
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Re: 8130 Form

Post by Rudder Bug »

I don't have a clue Kamikaze and I won't call them either!

We simply replaced the darn rubbers at the annual but it's not written in the logs; the old ones were not snagged. I can't see it like using bogus parts as they are the recommended make and model for the type of aircraft, brand new, manufactured in 2009.

If such a thing makes me flying my plane illegally, that will comfirm the thruth regarding one of our Avcanadian dude's signature, saying that an aircraft has four dimensions: lenght, height, width and politics.

Rubber Bug
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Re: 8130 Form

Post by kamikaze »

So your AME agreed to do let you go without putting that in the logs ? Mine won't, I'm pretty sure of that.

I've foudn the referenced AN. I asked AS, and they referred to that AN too. I'm going to check with TC to see if they concur, and then when everyone agrees, I'll go inform my AME ... if all goes well.
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Re: 8130 Form

Post by Rudder Bug »

kamikaze wrote:So your AME agreed to do let you go without putting that in the logs ? Mine won't, I'm pretty sure of that.
He's an open minded and clever person and he let it go for this time, but we made it clear that I won't order any part without asking his advice in the future. I now have new tires and nobody knows. Somebody's gonna cut my throat betcha?

RB
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