Technical Data required in Block 13 (Remarks) or FAA 8130-3

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Dan AMT

#1
Hi!,

This Is post number one for me and hope this is a valuable resource for me in my hunger for aviation knowledge. So, hello to all!

Here is my situation. I work at a Part 145 repair station repairing aircraft components and appliances. We work on no airframes, engines or propellers at this shop.

In School and in every company I have ever worked at, it is common knowledge that any work done on an FAA certified article cannot be signed off in accordance with an illustrated parts catalog (IPC).

An article I returned to service had the 8130-3 brought to me with the return to service statement and the EASA statement for part 145 repair stations in block (13) as per FAA ORDER 8130-20 (or 21). Then was the technical data used to perform the work in this case the CMM in which it was tested in accordance with to prove its airworthiness. Below it however, was the IPC reference. This particular CMM has a separate CMM and IPC digital file but both make up the manual and revisions are checked together when checking revision status per our repair station manual. Normally our CMM's and IPC's are one digital file so we can add them into the computer system as one manual. Because of the way the system was designed we had to add the digital files separately so it automatically populates both of them into block 13 when printing the 8130.

My issue was that since maintenance cannot be signed off per an IPC, there was no reason for our IPC reference and revision date to be printed on the 8130. A supervisor who has worked in aviation a long time insisted that it did not matter if the IPC reference was notated on the 8130 or not. He went on a rant about it and the more he got into it the more he was convinced that you could actually sign off work done IAW an IPC for small things like light bulbs that have no replacement reference in an AMM or CMM. I think he is flat out wrong.

His argument was that certain small things do not have technical data to sign it IAW in which case it might be acceptable to use an IPC as a reference. Another argument he made was that you must have an IPC reference for return to service to show the parts you replaced are the most current.

I argued that a return to service does not identify specific parts replacements, only the status of the work performed I.E. INSPECTED, REPAIRED, OVERHAULED has been tested for function at the completion of work and the work was done in accordance with the applicable technical data and with regards to the work done is considered airworthy. References to the technical data used must be documented on the 8130, but an IPC reference is not applicable on an 8130 and only creates potential for a through receiving inspector to reject an article for having an out of date IPC reference.

This particular supervisor pulls the 'I've worked in aviation for twenty years bla bla bla!' all the time. It really gets old and wears me out. Please let me know your thoughts and if you have a reference to put this issue to rest give me some direction of where I may find it. Thanks in advance for any help you might be able to provide.
Dan
 

errhine

Involved - Posts
#3
I would question work performed under an IPC. All the IPC can show you is the configuration, there are no inspections or maintenace activities in any IPC I have ever seen. If the IPC was referenced in the 8130-3 along with the correct CMM/AMM then it would only be additional information and not techinally incorrect.
My opinion.
 

darkopsghost

Starting to get Involved
#4
A Quick Bump!

Can someone help?

Thank you very much!!
I understand that the way your form is set up it automatically loads your info into your 8130 as you are populating it, but I don't think the IPC reference should be anywhere other than your traveler or inspection documentation.

IPCs hardly ever change after a few years unless there are mods or spares added, thus the "Effective - From" column.

I would question why it was even there to begin with, but I'm still having issues with the new 8130 period. :confused:
 

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