Yellow tags

[jrh]

I've been searching for a while, and even Google hasn't given me the answer to this one...

When is a yellow tag needed for an aircraft part, and how does one go about getting a yellow tag for a part?

I'm asking because the master solenoid went out in my Cessna 140 yesterday.

Cessna, in all their overpriced glory, charges $432 for a new solenoid.

I asked my mechanic about getting a used solenoid and he said I could, but for him to be able to install it, it would need to come with a yellow tag.

I started Googling to learn more about the yellow tag process and the only thing I could find was a book called "Aircraft Ownership" by Ron Wanttaja who says yellow tags should be issued by the new mechanic who is installing the used part in the new plane.

This seems to contradict what my mechanic said, because he made it sound like the part needed to come with a yellow tag already issued, issued by the mechanic who pulled the part out of the salvaged plane.

To add more to my confusion, another mechanic friend of mine told me to just do the work myself, yellow tag or not. Unbolt the old solenoid, bolt in the new (used) one, and nobody would know the difference.

I contacted my type club and a guy offered to sell me a used master solenoid for $35. That sounds like a pretty good deal, but I don't think it comes with a yellow tag.

So, what should I do? I want to keep things safe, legal, and affordable. Hopefully the three aren't mutually exclusive in this case.

[Berkut]

I've been working in the airline world for a while, so someone please correct me if any of this has changed lately.

Originally Posted by jrh

When is a yellow tag needed for an aircraft part, and how does one go about getting a yellow tag for a part?

Basically, a yellow tag is someone's way of saying, "I will vouch for this part's airworthiness." For your part 91 Cessna 140 purposes, you will probably only get a yellow tag back with a part that you've sent off to a repair station.

I asked my mechanic about getting a used solenoid and he said I could, but for him to be able to install it, it would need to come with a yellow tag.

There is no reg preventing him from installing a salvage solenoid. However, if the part does not come with a yellow tag, he will be the one taking responsibility for its airworthiness. He might be choosing not to for liability reasons.

This seems to contradict what my mechanic said, because he made it sound like the part needed to come with a yellow tag already issued, issued by the mechanic who pulled the part out of the salvaged plane.

He is free to choose to not install a part without a yellow tag; You are free to choose to go to another mechanic.

To add more to my confusion, another mechanic friend of mine told me to just do the work myself, yellow tag or not. Unbolt the old solenoid, bolt in the new (used) one, and nobody would know the difference.

Don't do that.

I contacted my type club and a guy offered to sell me a used master solenoid for $35. That sounds like a pretty good deal, but I don't think it comes with a yellow tag.

That does sound like a good deal. You are not required to have a yellow tag.

So, what should I do? I want to keep things safe, legal, and affordable. Hopefully the three aren't mutually exclusive in this case.

I believe the safe, legal, and affordable thing to do would be to have a mechanic install the salvage solenoid, or have one supervise and sign off on you doing it yourself. If you can't convince your mechanic to install the salvage part, you will either have to find a yellow-tagged part or another mechanic.

[jrh]

Thanks for your quick reply! I've got a couple new questions now...

Originally Posted by Berkut

You are not required to have a yellow tag.

I'm not required to have a yellow tag to buy a part, or I'm not required to have a yellow tag, period?

What I mean is, is there a way to install a salvaged part, record it in the maintenance logbook, yet not have a yellow tag?

Originally Posted by Berkut

I believe the safe, legal, and affordable thing to do would be to have a mechanic install the salvage solenoid, or have one supervise and sign off on you doing it yourself.

Ok, so is the yellow tag certifying the *part* is airworthy, or *part and installation* is airworthy?

The reason I'm asking is, let's say I get this salvage part and the mechanic I'm using doesn't want to issue a yellow tag for it. Could I take it to another mechanic, have them put it on a test bed, verify it works correctly, issue a yellow tag, then take the part back to my original mechanic and have him install it? I might need to do it this way simply because I can't fly the plane to another airport without a master solenoid, but my mechanic is the only mechanic at my home airport.

Or, would it be any less liability / more likely for the mechanic to sign off on the logbook if I install the part myself (without a yellow tag) and have him inspect my work? This way the mechanic wouldn't even have to touch the part. Or would his signature be the same as him saying he did the work himself and takes all responsibility for it?

[Berkut]

Originally Posted by jrh

I'm not required to have a yellow tag to buy a part, or I'm not required to have a yellow tag, period?

You are not required to have a yellow tag, period.

What I mean is, is there a way to install a salvaged part, record it in the maintenance logbook, yet not have a yellow tag?

Yes. The salvage part can be installed without any yellow tag involvement whatsoever. This isn't some special case; the default assumption would be that it doesn't have a yellow tag. It came off a junk airplane, after all.

Ok, so is the yellow tag certifying the *part* is airworthy, or *part and installation* is airworthy?

Just the part.

The reason I'm asking is, let's say I get this salvage part and the mechanic I'm using doesn't want to issue a yellow tag for it.

He couldn't even if he wanted to.

Could I take it to another mechanic, have them put it on a test bed, verify it works correctly, issue a yellow tag, then take the part back to my original mechanic and have him install it? I might need to do it this way simply because I can't fly the plane to another airport without a master solenoid, but my mechanic is the only mechanic at my home airport.

No, the tag has to be issued by a certified repair station. Repair stations have the tools, data, and approval to inspect a component and yellow tag it. I don't know if there are any repair stations that work with master solenoids; I guess there are. I work 121 so I don't keep up with such things. Personally, I think the idea of sending off a salvaged $35 solenoid to a repair station to be yellow tagged is ridiculous. He should just install the damn thing already.

Or, would it be any less liability / more likely for the mechanic to sign off on the logbook if I install the part myself (without a yellow tag) and have him inspect my work? This way the mechanic wouldn't even have to touch the part. Or would his signature be the same as him saying he did the work himself and takes all responsibility for it?

No, it's not really any less liability for him.

From a regulatory standpoint, there is nothing wrong with him simply installing your salvage solenoid with no yellow tag, signing it off, and sending you on your way. Has he said why he requires a yellow tag? Is it for his own personal CYA purposes, or does he mistakenly think that it's somehow a requirement?

I'm halfway tempted to advise you to go ahead and install it yourself, but I'm a 121 inspector and can't really roll like that.

[JHines]

Originally Posted by jrh

<SNIP>

I'm asking because the master solenoid went out in my Cessna 140 yesterday.

Cessna, in all their overpriced glory, charges $432 for a new solenoid.

[off-topic]
Ah, the joys of certified aircraft ownership - which is why my next plane will be an experimental.
[/off-topic]

[Berkut]

Originally Posted by JHines

[off-topic]
Ah, the joys of certified aircraft ownership - which is why my next plane will be an experimental.
[/off-topic]

I worked at an auto parts store before I went to college. I sold a lot of experimental airplane parts.

[t-cart]

Originally Posted by Berkut

You are not required to have a yellow tag, period.Yes. The salvage part can be installed without any yellow tag involvement whatsoever. This isn't some special case; the default assumption would be that it doesn't have a yellow tag. It came off a junk airplane, after all.Just the part.He couldn't even if he wanted to.No, the tag has to be issued by a certified repair station. Repair stations have the tools, data, and approval to inspect a component and yellow tag it. I don't know if there are any repair stations that work with master solenoids; I guess there are. I work 121 so I don't keep up with such things. Personally, I think the idea of sending off a salvaged $35 solenoid to a repair station to be yellow tagged is ridiculous. He should just install the damn thing already.No, it's not really any less liability for him.

From a regulatory standpoint, there is nothing wrong with him simply installing your salvage solenoid with no yellow tag, signing it off, and sending you on your way. Has he said why he requires a yellow tag? Is it for his own personal CYA purposes, or does he mistakenly think that it's somehow a requirement?

I'm halfway tempted to advise you to go ahead and install it yourself, but I'm a 121 inspector and can't really roll like that.

Berkut speaketh the truth. FLY SAFE T.C.

[sefro]

Just think of it this way A yellow tag just means that a repair station has found that part to be worthy for return to service. Its just a paper trail to keep every thing strait.
Seth

[jrh]

A-ha! I understand now. I didn't realize yellow tags must come from a repair station. I thought any old mechanic could issue one.

I bought the $35 salvaged part. I haven't talked to my mechanic since Wednesday morning when I first had the trouble. I'll talk to him again and find out his reasoning for not wanting to install it. Maybe I can talk him in to it.

If he doesn't want to install it, I'll do whatever it takes to find another mechanic who can do it. No way am I dropping $435 on a part if I don't absolutely have to!

[USMCmech]

Originally Posted by jrh

I bought the $35 salvaged part. I haven't talked to my mechanic since Wednesday morning when I first had the trouble. I'll talk to him again and find out his reasoning for not wanting to install it. Maybe I can talk him in to it.

If he doesn't want to install it, I'll do whatever it takes to find another mechanic who can do it. No way am I dropping $435 on a part if I don't absolutely have to!

If he dosen't want to install it, ask him if he will supervise you installing it. That way you will be taking the liabilty, not him.

[jrh]

A little update...

I spoke to the manager of my shop this morning and he confirmed they couldn't install any parts without yellow tags. He said it was because their shop is an official repair station and I guess that designation is more stringent in what they can or can't do. I don't really understand it all. Apparently as a repair station they have to have traceability for everything they do, whereas a regular mechanic shop has more freedom?

But it's no big deal. I found a friend of a friend of a friend who is an A&P in my area who can come install the salvaged part for me.

I'm also glad to know this before my annual comes due. I think I'll be taking my plane to another shop for the annual so if I find I need to replace anything during the annual, it won't be a big deal to use salvaged parts.

I've been really happy with the knowledge and professionalism of the shop I've been dealing with, but I can see now why it's always late model corporate aircraft filling their hangar, not old piston singles that typically need work like this done.

[t-cart]

Yea,that usually isnt a good sign for a small (antique)plane owner . Those shops make their living,and high overhead,on the corporate stuff. I bet you can go out in the boonies and find an old mechanic,that will do you a quality annual and not overcharge you just to cover the overhead. I made a deal with the local A&P/A&I to do my annual on the Apache for some dual time . Good luck with your plane. A 140 is a great little plane,Only thing that would make it better(in my HUMBLE opinion,would be stick controls.) FLY SAFE T.C.

[sefro]

The reason they wont install it for you is because they will get in alot of trouble without the yellow tag if they are a repair station. This is all because of the problem of people putting on life limited parts which the limit of that part has been met or exceeded if on aircraft. So what the "yellow tag" does is create a paper trail or lets the repair station know the origin of the part and has documentation of it so that it does not exceed the life limit.

§ 43.10 Disposition of life-limited aircraft parts.

Life-limited part means any part for which a mandatory replacement limit is specified in the type design, the Instructions for Continued Airworthiness, or the maintenance manual.

Life status means the accumulated cycles, hours, or any other mandatory replacement limit of a life-limited part.

(c) Disposition of parts removed from type-certificated products. Except as provided in paragraph (b) of this section, after April 15, 2002 each person who removes a life-limited part from a type-certificated product must ensure that the part is controlled using one of the methods in this paragraph. The method must deter the installation of the part after it has reached its life limit. Acceptable methods include:
(1) Record keeping system. The part may be controlled using a record keeping system that substantiates the part number, serial number, and current life status of the part. Each time the part is removed from a type certificated product, the record must be updated with the current life status. This system may include electronic, paper, or other means of record keeping.
(2) Tag or record attached to part. A tag or other record may be attached to the part. The tag or record must include the part number, serial number, and current life status of the part. Each time the part is removed from a type certificated product, either a new tag or record must be created, or the existing tag or record must be updated with the current life status.

So the catch here is that if the person that took the salvaged part off the aircraft did not tag it.. which if they arent in a repair station, they wont. then the part cannot be installed at a repair station because there is no paper trail. But your everyday mechanic can do the repair because he operates under slightly different rules than your repair station.
Does that make sense?
Seth

[jrh]

Originally Posted by sefro

So the catch here is that if the person that took the salvaged part off the aircraft did not tag it.. which if they arent in a repair station, they wont. then the part cannot be installed at a repair station because there is no paper trail. But your everyday mechanic can do the repair because he operates under slightly different rules than your repair station.
Does that make sense?

Yes, makes total sense. Thanks for referencing the reg!

As a funny follow up to this story, I'm not going to install the salvaged part after all.

I was doing some more research on the Cessna 120/140 type club's web site and found an article in their reference library specifically detailing repairs to the master solenoid.

The article referenced an article from another Cessna type club's newsletter, that referenced an official Cessna service bulletin, that details how the cheap ($40), new style (post-1966) battery contactor can be legally used in all older (pre-1966) Cessna single engine aircraft if installed according to certain specifications.

Apparently I'm not the only owner who had sticker-shock at the price of the old style master solenoids!

So I called the repair station back right away and told them about what I'd found. They looked up the service bulletin, agreed that they could legally install a new contactor, and said they had all the parts in stock.

I'm still spending about $90 in parts ($40 for the solenoid, and $50 for a diode that has to be wired in during the installation), compared to my $35 salvaged solenoid, but to me the price difference is well worth getting brand new parts that ought to last for as long as I own the plane, rather than another solenoid from 1946 that has who knows how many thousands of hours already on it.

Moral of the story--aircraft owners ought to get involved in their type clubs! All kinds of useful support can be found.

[sefro]

Thats great that everything worked out.
Seth

[Stonefly]

Originally Posted by USMCmech

If he dosen't want to install it, ask him if he will supervise you installing it. That way you will be taking the liabilty, not him.

What?

According to 91.417:

(1) Records of the maintenance, preventive maintenance, and alteration and records of the 100-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include—
(i) A description (or reference to data acceptable to the Administrator) of the work performed; and
(ii) The date of completion of the work performed; and
(iii) The signature, and certificate number of the person approving the aircraft for return to service

As a non-mechanic, he can't approve the aircraft for return to service. He can do the work, the appropriately rated mechanic can supervise, but it is the mechanic who has to return it to service, therefore assuming the liability. Installing a contactor does not fall under preventive maintenance.

Stonefly

[USMCmech]

12/12/2007

N007RJ

TT 2300 hours


R&R master solenoid with salvage part #876543 IAW Cessna 140 maintece instructions.

JRH pilot, CPL 1234567



Work performed under my supervision. Aircraft approved for return to service.

Bob Mechanic A&P 7654321

Meets the letter of the law, and clearly indicates that useing the salvage part was the owners idea.



The FAA dosen't care that the part dosn't have a yellow tag, since it was an origional part, and is presumably in serviceable condition. What many mechanics are concered about is their liability in a personal injury lawsuit.

[Stonefly]

Originally Posted by USMCmech

12/12/2007

N007RJ

TT 2300 hours


R&R master solenoid with salvage part #876543 IAW Cessna 140 maintece instructions.

JRH pilot, CPL 1234567



Work performed under my supervision. Aircraft approved for return to service.

Bob Mechanic A&P 7654321

Meets the letter of the law, and clearly indicates that useing the salvage part was the owners idea.



The FAA dosen't care that the part dosn't have a yellow tag, since it was an origional part, and is presumably in serviceable condition. What many mechanics are concered about is their liability in a personal injury lawsuit.

From AC 20-62D Eligibility, Quality, and Identification of Aeronautical Replacement Parts:

14. SUMMARY.

The approval for return to service after maintenance of aircraft, engines, propellers,
appliances, and materials and parts thereof, is the responsibility of the person who performs the maintenance
and who signs the record for approval for return to service. The owner/operator (as noted in paragraph
6b) is responsible for the continued airworthiness of the aircraft. To ensure continued safety in civil aviation,
it is essential that appropriate data is used when inspecting, testing, and determining the acceptability of
all parts and materials. Particular caution should be exercised when the origin of parts, materials, and appliances
cannot be established or when their origin is in doubt.

(emphasis added)

As the mechanic supervising the work, "Bob" is accepting responsibility for the work performed and that the part is itself airworthy. As the part does not have a yellow tag, that only means that someone else at a CRS is not vouching for the part. That puts the onus squarely on the mechanic returning the aircraft to service.

Stonefly