flyguy6a

Member
Just have had kind of a daunting experience. I had an FAA certified shop check some parts on a LYCO O-360. They agreed up front to issue the "yellow tag" aka FAA form 8130-3 if the crank, cam, and rods passed Magnaflux and Zyglo inspections.

Went to pick up the parts, and there was no yellow tag even though the invoice said it had passed.

Explanation: "We don't issue a tag for experimental engines."

Can anyone tell me if this is true, that shops don't have to do this for experimentals? ... and why wouldn't they?

Before I call the FAA on this, maybe some of the smart folks on this forum can help me???
 
I have an engine full of parts that were yellow tagged...They had no idea where they were going to be used. It is none of their business. My engine has been an experimental for many moons.

Sounds like you need to have a heart to heart with these people. Who are they by the way?
 
the yellow tags are for the individual pieces.

like crankshaft, cam, lifters, valves, etc.

If they passed I would expect to have yellow tags to staple into the engine log.

Now, the engine may be or become experimental because of uncertified accessories. Electronic ignition, etc.
 
That sounds reasonable...

....
Explanation: "We don't issue a tag for experimental engines."

Can anyone tell me if this is true, that shops don't have to do this for experimentals? ... and why wouldn't they?
....

...for the whole engine.... but NOT reasonable for piece parts...:eek:

If you ask them to check a crank, they actually don't know where it came from, or where it's going. That's your resonsiblity - you are just asking them to check that it is an airworthy part per Lycoming's doumentation.

The "yellow tag" is their "it passed" label.

Now, if your parts are missing part numbers and/or serial numbers, then it is a different issue.

"We don't issue a tag for experimental engines" - the experimental engine would not have a serial number issued by Lycoming - but if it actually had the data plate and all of the parts were airworthy per Lycomings documentation, then it probably wouldn't be "experimental"...:)
 
If they are not willing to back up their word...

With a yellow tag for each part how do you know they even did the inspection?
All the invoice is what they are willing to charge you. Each yellow tag is the suitability for that part only to be returned to service. As said earlier it has no bearing on the total assembly. Ask for proof of inspection or go and quietly cancel payment. At least you both roughly ended up where you started. Give us a heads up so we won't repeat your error in choice of vendor.
 
Just have had kind of a daunting experience. I had an FAA certified shop check some parts on a LYCO O-360. They agreed up front to issue the "yellow tag" aka FAA form 8130-3 if the crank, cam, and rods passed Magnaflux and Zyglo inspections.

Went to pick up the parts, and there was no yellow tag even though the invoice said it had passed.

Explanation: "We don't issue a tag for experimental engines."

Can anyone tell me if this is true, that shops don't have to do this for experimentals? ... and why wouldn't they?

Before I call the FAA on this, maybe some of the smart folks on this forum can help me???

Two things...

You had a business agreement. If they don't fulfil their end, you have no responsibility to fulfil your end, which is paying them.

The intended use of the part (certified or experimental) should have zero impact on the issuance of a yellow tag on a part that passed inspection. What if you changed your mind tomorrow and wanted to sell the parts on Ebay? Without yellow tags, the value of your items would be significantly reduced.
 
Truth is, if they don't issue a "yellow" tag, they don't have the liability that they do when they do issue one. Because it's for an experimental engine, they figure they can get away with it. And they can. Unless you had a contract that specifically requires them to issue you a yellow tag, they don't have to issue one.

Seems a bit shaky that there is this gulf between type-certificated aircraft non- type-certificated. But in the end that's the deal.
 
...They agreed up front to issue the "yellow tag" aka FAA form 8130-3 if the crank, cam, and rods passed Magnaflux and Zyglo inspections...

...Unless you had a contract that specifically requires them to issue you a yellow tag, they don't have to issue one...

It sounds like a contract to me. Maybe an oral contract but a contract.
 
It sounds like a contract to me. Maybe an oral contract but a contract.

Yep! I wonder how you know for sure the work was performed and that it was found to be airworthy if they don't issue a tag.

I am sure you didn't get an "experimental" discount.
 
OK then....

Truth is, if they don't issue a "yellow" tag, they don't have the liability that they do when they do issue one. Because it's for an experimental engine, they figure they can get away with it. And they can. Unless you had a contract that specifically requires them to issue you a yellow tag, they don't have to issue one.

Seems a bit shaky that there is this gulf between type-certificated aircraft non- type-certificated. But in the end that's the deal.

...ask for a full copy of the Work Order instead.

The Yellow tag from a certified Repair Station just gives a reference to a work order anyway.



Clickable thumbnail

Without a YT or Work Order, how do you actually know it passed the tests you requested?
 
A Y/T isn't a cerifying document. The work order is where the buck stops.


Hmmm, I don't think your right there. The Yellow tag is the Return To Service. It is a certifying document. The work order is a supplemental document. Without a Yellow tag (serviceable tag) you can't use it on certified aircraft.
 
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If I were a repair station I doubt I would issue a yellow tag for an experimental application. There's simply too much liability. The work order is sufficient for a description and assurance that the work paid for was performed. However, I would expect a "discount". Part of the price of repair/inspection is to cover the liability. If I don't get that insurance, I shouldn't have to pay for it.
 
Talk to Bill

The Yellow TagFAA Feedback By Bill O'Brien
AMT Contributor

A question often asked as I travel around the country giving safety seminars is: Does a yellow tag satisfy the requirements of a maintenance release?

You must first understand that there's no legal definition of a yellow tag. Regardless of the fact that there are logbooks out there that are full of them, the term "yellow tag" isn't mentioned anywhere in FAR Part 43.

Yellow tags were first used by the Army Air Corps back in the early days of World War II. No reason was given why the color yellow was picked to indicate a serviceable component. Most of us would have picked the color green for serviceable and yellow for repairable ? not the other way around.

I suspect, based on my own military experience, that the decision to use yellow for serviceable parts was probably made by an Army supply clerk who ordered a million yellow tags by mistake and had to find a use for them or be shipped to a combat area.

Regardless, after the war, the airlines stayed with the military tradition of using yellow tags as a serviceable item. Following their lead, the rest of general aviation bought in ? and yellow tags became part of aviation terminology and culture.

So what's the problem with using a yellow tag as a maintenance release?

The yellow tag only satisfies half of the requirements for a maintenance release under Part 43, Appendix B, and many repair stations are sending only this document along with a repaired component. On one side of the tag, they identify the part and use single words like "repaired" or "overhauled" that are one-word descriptions of all the work accomplished. On the other side of the tag, they put the maintenance release statement. The work order with all its important information isn't sent and the technician is left holding the bag because he has no idea of what's happened to the component.

The yellow tag doesn't tell you what approved data was used, what Airworthiness Directives (AD) were done, what standards were met, what parts were replaced, what service bulletins or letters were complied with, or what total time was on the propeller or engine. The only thing a yellow tag tells you is that you've got a great big hole in your record keeping.

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The Yellow tag is the maintenance release. It's the repair stations approval for return to service. The work order is the description of the work accomplished. Both are required but only the Yellow tag (or whatever color) has the airworthiness statement. (though that statement can be written anywhere).

As an A&P I can authorize a return to service with my A&P license, a repair station with their license number. I am supposed to list the reference document for the procedures I follow and indicate the maintenance performed. A repair station can have it's own reference data that they invented provided they have FAA approval. ( I can't do that, except via form 337).

A literal "yellow tag" isn't required. I've seen them in many different colors and in different formats. "yellow tag" is just a concept that illustrates a maintenance release.

The article above is pretty good. Here it is in it's entirety

The Yellow Tag
FAA Feedback

Posted: July 8th, 2008 05:26 PM GMT-05:00


A question often asked as I travel around the country giving safety seminars is: Does a yellow tag satisfy the requirements of a maintenance release?

You must first understand that there's no legal definition of a yellow tag. Regardless of the fact that there are logbooks out there that are full of them, the term "yellow tag" isn't mentioned anywhere in FAR Part 43.

Yellow tags were first used by the Army Air Corps back in the early days of World War II. No reason was given why the color yellow was picked to indicate a serviceable component. Most of us would have picked the color green for serviceable and yellow for repairable ? not the other way around.

I suspect, based on my own military experience, that the decision to use yellow for serviceable parts was probably made by an Army supply clerk who ordered a million yellow tags by mistake and had to find a use for them or be shipped to a combat area.

Regardless, after the war, the airlines stayed with the military tradition of using yellow tags as a serviceable item. Following their lead, the rest of general aviation bought in ? and yellow tags became part of aviation terminology and culture.

So what's the problem with using a yellow tag as a maintenance release?

The yellow tag only satisfies half of the requirements for a maintenance release under Part 43, Appendix B, and many repair stations are sending only this document along with a repaired component. On one side of the tag, they identify the part and use single words like "repaired" or "overhauled" that are one-word descriptions of all the work accomplished. On the other side of the tag, they put the maintenance release statement. The work order with all its important information isn't sent and the technician is left holding the bag because he has no idea of what's happened to the component.

The yellow tag doesn't tell you what approved data was used, what Airworthiness Directives (AD) were done, what standards were met, what parts were replaced, what service bulletins or letters were complied with, or what total time was on the propeller or engine. The only thing a yellow tag tells you is that you've got a great big hole in your record keeping.

The "yellow tag ? only" repair stations defend their position by hiding behind the maintenance release statement that says "all pertinent details are on file at the repair station under a work order number______." That's great, but if the repair station goes out of business, the records may no longer be available. And even if it's still in business, a repair station is only required to keep their records for a period of two years! Some repair stations "lose" their records after two years to avoid liability issues.

Here are a few things that you should keep in mind regarding maintenance releases:

* A maintenance release is a document that only a certificated Part 145 repair station can use in lieu of FAA Form 337.
* A maintenance release is used to identify only major repairs to an aviation component(s). They are not to be used to identify minor repairs, or minor or major alterations.
* A maintenance release is a two-part document. The first part is the work order. It must be signed, dated, have a description of the work performed (e.g. service bulletins, ADs, repairs accomplished, etc.) and the approved data used for the major repair. The second part is called the maintenance release statement. It must be signed by an authorized representative of the repair station.
* The maintenance release must have the following information:
o Identification of the airframe, engine, propeller or appliance worked on.
o If an aircraft, it must include: the registration number, make, model, serial number and the area repaired must be listed.
o If an airframe, engine, propeller or appliance it must include: the manufacturer's name, name of the part, and model and serial numbers if any must be listed.
o The following or similarly worded statement must be included: "The aircraft, airframe, aircraft engine, propeller or appliance identified above was repaired and inspected in accordance with the current Regulation of the Federal Aviation Administration and is approved for return to service. Pertinent details of the repair station under Order No. _____Date _____ Signed______ (authorized representative for the repair station). Repair station address and certificate number ________.

? The maintenance release statement and required information don't have to be on a yellow tag. They can be stamped or printed on the repair station work order. Here are a few suggestions for dealing with repair stations that don't provide a thorough maintenance release.

? Make sure the repair station has all the information it needs. When you send in a component for repair/overhaul on your work order request, give the repair station all the required information on the part such as make, model, serial number, total time/cycles, history, etc.

? Formally request a maintenance release as required by FAR Part 43, Appendix B. State very clearly on your work request, "No complete maintenance release ? no payment."

? When you want an engine or propeller overhauled, tell the repair station that you want its maintenance release to show the total time since new and total time since overhaul.

? If the repair station won't comply with the above, ask for a FAA Form 337 for the major repair instead.

? If you have continuing problems trying to get both parts of the maintenance release or the Form 337 from the repair station, notify the Flight Standards District Office in charge of that repair station to assist you.

If you still have problems ? look elsewhere. Loss of a customer base will bring the repair station around to the correct way of doing business.

AmtOnLine
 
Personally, I wouldn't consider their inspection as valid without a yellow tag and a complete work order. If they say the parts are good but aren't willing to provide the proper paperwork because it's "experimental" means they don't stand behind what they say. Of course I'm talking about parts that were manufactured as certified parts, not experimental. I've seen some very bad work done to parts because they're "experimental". My engine parts don't know they're in an experimental airplane, but I certainly know it when they fail.

Kevin Belue
RV-6A
RV-10
 
Many MRO's are getting away from yellow tags completely, and only providing a work order for component repair/inspection/overhaul. Depending on how their repair station manual is written, the completed, signed work order constitutes THE maintenance release. A yellow (serviceable) tag will ALWAYS reference a work order, with the work order being the controlling document.

Liability shouldn't be an issue - for INDIVIDUAL parts. If a part meets its serviceable design / overhaul limits and has passed the inspection process for return to service, then that's that.

As has been previously suggested, I would ask for (demand?) a copy of the SIGNED work order / maintenance release.
 
No, what Bill is saying is there are 2 parts to a maintenance release i.e. description and statement. Just like there are 5 parts to a logbook entry. A tag is just a tag UNLESS it contains the release statement which makes it part of the maintenance release. If the statement is on the W.O. (or elsewhere) you can chuck the tag.
 
As has been previously suggested, I would ask for (demand?) a copy of the SIGNED work order / maintenance release.

Yep, no release/description of work accomplished, NO WAY, NO PAY!

I just went through all this with my ECI kit. I had a pallet full of parts, not a single work order, serviceable tag anywhere. I ASSUME that the parts are all new and conform to some sort of standard. They probably are. You can bet your behind that if any parts go in for repair/overhaul, I will demand a work order with a release statement.
 
AC 43-9C

This document touches on the requirements for aircraft (all aircraft?) maintenance records. As an A&PI have signed the maintenance release block of an 8130-(?) more times than I can count. So as a manufacturer recognized by the FAA, do you have the authority to fill out an 8130 using work order information and sign the maintenance release when installed?
I would at least expect all the work order information necessary to support an A&P decision to release those parts for return to service on a certified (certified experimental) aircraft. Also, can the airframe manufacturer (you) mandate compliance with engine manufactures standards? If you can, can you sell a used engine and install it on a Cessna? If not why not. Experimentals are certified aircraft
Would like to know what other regs or AC's cover this topic.
Andrew
 
8130

The 8130 shows who is responsible for what work. The repair person or shop can't determine if the part is suitable for a particular installation and the installer needs to know what was done to the part. An examle is a hollow crank that gets a particular inspection for pitting, but no AD sign off because the shop does'nt know if the crank is going for a constant speed or not. The S.B. that the AD requires is on the work order, and the A&P signs of the AD as previosly complied with on Work Order #xx, but only if its required for that installation. Talk of yellow tags only confuses the issue for me in that I can not find any legal definition.
Andrew
 
Experimentals are certified aircraft
Andrew

I think here is where some of us (myself included) confuse the issue. Experiments are "certified" (experimental) but not "certificated". That is, there is no Type Certificate. All maintenance, repairs and alterations must conform to the manufacturer's type certificate when the aircraft has a Type Certificate. Because an experimental has no type certificate, there is no requirement for such conformity. We can (and should) demand the same quality and quantity of work if we are paying the same price. Looks to me like there is no maintenance requirement at all for an experimental with the exception of transponder and condition inspections.

This is all new to me and I am trying to educate myself as much as I can. All my A&P experience in the past is on Type Certificated aircraft. I am "all ears" to any corrections to my understanding.
 
Maybe I'm just waking up slow Tony, but I thought it was the other way around.

"Certificated" means that the aircraft has an airworthiness certificate, of any kind (including "Experimental"). "Certified" means that it meets some set of standards such as a Type Certificate. I think I saw that discussion in the past few weeks - very subtle language difference.

Paul
 
FAR Part 1

Tried to find definitions for ceritfied and certificated in Part 1, no joy. Those word are used in the definition catagory and class. My experiance with the regulations would suggest there is a way from here (I want my experimental stuff signed off) to there (a difinitive yes or no per whatever). I'm having a hard time finding it. Any Feds, ex Feds or other regulatory types out there?
Andew
 
Maybe I'm just waking up slow Tony, but I thought it was the other way around.

"Certificated" means that the aircraft has an airworthiness certificate, of any kind (including "Experimental"). "Certified" means that it meets some set of standards such as a Type Certificate. I think I saw that discussion in the past few weeks - very subtle language difference.

Paul

You might be right. You might be wrong, that's why it's so hard to wrap your head around this. I think its how we use the terms.

I may be wrong on this for sure. I am just now getting ready to fly my plane and starting to think about experimental airworthiness.

It's always been my understanding the an Experimental Airworthiness Certificate is FAA authorization to fly an aircraft that does not have a Type Certificate as opposed to a Standard Airworthiness Certificate for aircraft that do have a Type Certificate.

I really want to get this straight, forgive me if I have added to any confusion.
 
Paul has it right!

At least that's how I understand it from our DAR seminars.

CERTIFICATEd means it has been issued a certificate.
Certified means it meets a known standard.

Van Stumpner (AFS 640) can correct me if I'm wrong.
 
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At least that's how I understand it from our DAR seminars.

CERTIFICATEd means it has been issued a certificate.
Certified means it meets a known standard.

Van Stumpner (AFS 640) can correct me if I'm wrong.

I'll buy that. I stand corrected.
 
Here is a lnik to a NTSB review of an FAA action against an A&P who installed a "yellow tagged" part that was not serviceable and the work order said so. The short version is it was mis-tagged.

https://ntsb.gov/alj/o_n_o/docs/AVIATION/4810.PDF

Whether the part is tagged, or not, only the work order provides a complete view of the part.

That's VERY interesting. They indicate in the document that the "yellow tag" has come to signify in the
industry a serviceable part, when the work order sent with it
clearly indicated the contrary
.

They chose not to sanction the A&P. Now I can see why the use of the "yellow tag" is going away. It sure was necessary at UAL where I spent all my time.

This is all been very educational.
 
Update

Just have had kind of a daunting experience. I had an FAA certified shop check some parts on a LYCO O-360. They agreed up front to issue the "yellow tag" aka FAA form 8130-3 if the crank, cam, and rods passed Magnaflux and Zyglo inspections.

Went to pick up the parts, and there was no yellow tag even though the invoice said it had passed.

Explanation: "We don't issue a tag for experimental engines."

Can anyone tell me if this is true, that shops don't have to do this for experimentals? ... and why wouldn't they?

Before I call the FAA on this, maybe some of the smart folks on this forum can help me???

Shop relented, yellow tag 8130 in hand, thanks to use of arguments from this forum. Upshot was that makes no diff if the intent is to put in an experimental anyway. They passed the part, told me it was airworthy so could have then sold it to anyone to put in production aircraft, or anything.

BTW, they never saw the dataplate that said experimental, just what I (foolishly it turned out) told them.

Reason prevailed. Lessons learned...

Thanks all,

Jack
 
And rememebr - when you need to buy a replacement Nippondenso alternator at Autozone...it's for a Dune buggy.....;)