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8130-3 Forms: “Not for Export” Still Not Required

If you are paying attention to ARSA Works, you will not be surprised by the Dec. 8 FAA memorandum reminding inspectors and designees about the appropriate use of Block 12 on FAA Form 8130-3, Authorized Release Certificate, Airworthiness Approval Tag.

When the agency released its original clarification in April, it established that the statements “domestic shipment only” or “not for export approval” are not required anywhere on FAA Form 8130-3. However, the new memorandum indicates that the some designees continue to require those statements on the form.

The new policy reaffirms that the statements are not required in Block 12 and instead cause confusion. The FAA mandates that those authorized to issue FAA Form 8130-3 not add “domestic shipment only” or “not an export approval” to Block 12 of FAA Form 8130-3. The agency also noted that future revisions of FAA Order 8130.21 would incorporate this clarification.

Previously from ARSA

Symposium Engagement to FAA Action—the Form 8130-3 Story

 

April, 2014 Hotline

Lee Thomas was given the opportunity to raise an issue affecting his business with FAA regulators and he took it. Lee is a regular attendee of ARSA’s Annual Repair Symposium and saw a chance this year to engage directly during a Q&A session with a team from the Aircraft Certification Service (AIR). His issue, designees were insisting on putting “Domestic Shipment Only” or “Not an Export Approval” on FAA Form 8130-3 for new articles.

Lee represents Dassault Falcon Jet Corp, an ARSA corporate member since 1999. The company had previously been told by some designees the practice was being taught during FAA training even though it is no longer required by regulation or guidance material. The result was unnecessary delays and increased costs when foreign customers subsequently rejected the parts.

[The Annual ARSA Symposium] is the best event that I attend; it brings you in contact with both your peers and regulatory bodies…engaging in meaningful conversation.

When Lee spoke through ARSA, the FAA listened. The agency agreed to issue a memorandum to ensure its personnel (and its designees) do not use unnecessary verbiage or think the language is mandatory. The new guidance is clear: the statements are no longer required anywhere on the form.

The FAA made good on this agreement on April 16th, when it officially clarified the use of the form in question. The memo clearly stated that using “Domestic Shipment Only” or “Not an Export Approval” is not required.

When asked about how he felt about affecting national policy, Lee shared the credit with ARSA, “[The Annual ARSA Symposium] is the best event that I attend; it brings you in contact with both your peers and regulatory bodies…engaging in meaningful conversation.” For Lee, that meaningful conversation led to an effective policy change that will benefit his business and industry.

From a symposium Q&A session to FAA action within a month; engagement through ARSA affects regulatory change and clarification

ARSA Engagement Sparks FAA Action

April 16, 2014

On Wednesday, April 16, the Federal Aviation Administration (FAA) released guidance clarifying the use of Block 12 of FAA Form 8130-3, Authorized Release Certificate, Airworthiness Approval Tag. As first reported  at ARSA’s 2014 Annual Repair Symposium an association member informed the agency that some of its designees insisted on placing “Domestic Shipment Only” or “Not for Export” in that space.

In response, the agency agreed to issue a memorandum to ensure its personnel (and its designees) do not use unnecessary verbiage or think the language is mandatory. The new guidance is clear: “Domestic Shipment Only” or “Not for Export” statements are no longer required anywhere on FAA Form 8130-3.

From a symposium question and answer session on March 27, 2014 to FAA action within a month; engagement through ARSA affects regulatory change and clarification. To see more of what the association has done for you lately, please visit ARSA Works.

Please view the entire memorandum here.

Symposium Engagement Creates FAA Action

March 27, 2014

During the association’s 2014 Annual Repair Symposium “Opening Salvo” with the Federal Aviation Administration’s Aircraft Certification Office, an ARSA member informed the agency that some of its designees are still insisting on putting “Domestic Shipment Only” or “Not for Export” on FAA Form 8130-3s for new articles. The company was told that the practice was being taught to designees during FAA training even though it is no longer required by regulation or guidance material. The result is unnecessary delays and increased costs when foreign customers subsequently reject the parts.

The FAA representatives at the event agreed that the practice was not required and promised to look into the matter. Subsequently, the agency verified that the instructions were not being provided by its training and has agreed to issue an internal memorandum to ensure its personnel are not incorrectly advising industry that the verbiage is mandatory.



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