Pilot Co-Pilot
Pilot Co-Pilot
(OP)
Hello,
I am looking for some type of FAA documentation that clearly states that an FAA Form 8130-3 is not required on a Pilot/CoPilot Seat cushion...that as long as it has the Vertical Burn Test certification and MFG certs there is no need for an 8130-3. We have never had a problem with this issue until today. If anyone knows where I can find something to show the airline I would greatly appreciate it.
Thanks
I am looking for some type of FAA documentation that clearly states that an FAA Form 8130-3 is not required on a Pilot/CoPilot Seat cushion...that as long as it has the Vertical Burn Test certification and MFG certs there is no need for an 8130-3. We have never had a problem with this issue until today. If anyone knows where I can find something to show the airline I would greatly appreciate it.
Thanks





RE: Pilot Co-Pilot
In short, just because it may pass the burn test, it still may not meet the "Airworthy" test. Most airlines want to see an 8130-3 for parts they procure. It gives them a warm and fuzzy feeling. Unless they specify in their Maintenance Manual required under 135 or 121 that all parts must have an 8130-3, there is no FAA requirement for it.
RE: Pilot Co-Pilot
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If you are getting your cushion from somebody who does not hold a PMA, then they cannot issue an 8130. If it is incorporated into a larger assembly bt someone who holds a PMA, they may issue the 8130 for the larger assembly if it comforms to thier approved control process.
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If the manufacturer certs it as complying with a certain part number, TSO, or other applicable control document, that also meets the requirement.
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And it boils down to, if the customer wants an 8130, you need to find someone who can and will issue it.
RE: Pilot Co-Pilot
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RE: Pilot Co-Pilot
For new parts, thos parts need to be produced under an approved inspection system, either a Production Certificate, Parts Manufacturing Approval, or TSOA. In all three cases, you approved inspection system (14CFR21)dictates what documentation you will use when you deliver the parts. If the parts are to be exported, then the 8130-3 becomes a requirement for export.
For parts that are outside the approved production inspection system, 14CFR43 applies. Under part 43, more specifically 43.9 requires a maintenance record entry for approval for return to service. This could be on the proverbial "Yellow Tag", on an 8130-3, on a work order, or on a piece of toilet paper, so long as it contains the information required by 43.9. Order 8130-21 spells out the use of the 8130-3 in the FAAs eyes. Keep in mind that Orders are for the FAA and are not regulatory in nature. Just because Order 8130-21 says only a repair station can use the 8130-3 for return to service doen't make it so. A mechanic is reqquired to make a record entry with specific requirements (43.9) If an A&P uses the 8130-3 for return to service he hasn't violated any regulations, and has met the regulatory requirement of making a record entry. I've done it lots of times.
In short, the 8130-3 can be used by lots of agencies for lots of purposes. FAA has made it quite confusing when it really shouldn't be.
RE: Pilot Co-Pilot
And, aren't some of the newer seat structures certified to a higher load factor?
I have been told, (anecdotes will sometimes bite you) that some FSDIO's are requiring the new 23G seats to have a form 337 (major repair/alteration) for re upholstery work at the trim shop.
RE: Pilot Co-Pilot
The same goes for the amount of flammability testing required. Vertical burn is not enough for newer Part 25/29 seat requirements. Bottom line is to make sure that you know all the customers certification requirements and what amendment level of the FARs the item has to meet.
It gets very complicated and airlines have an extremely difficult task trying to keep up all the paper work so that they meet the regulations. They may be asking for more based on a number of reasons; recent audit, change in policy, or simply someone not knowing the exact requirements.
RE: Pilot Co-Pilot
We've been selling them for years like this. What I gather from everyone is that basically if the specific airline requires 8130-3's you need to provide them huh?
RE: Pilot Co-Pilot
Tons of "NEW" stuff is installed without a 8130, but it has something called a "Certificate of Conformity".