Adding Inventory Tags to Parts
by Jon Andresen
If an existing item is properly labeled (TSO#, Part #, Serial #, Date of Mfgr, etc) and already certified, does adding an additional inventory tag attached to the item (either bar coded or RFID tag) require that the item be re-certified?
ANSWER: For those of you unfamiliar with the acronym RFID, it stands for Radio Frequency Identification.
If you attach an inventory tag (paper tag or bar code) to a part then no re-certification is necessary. The inventory tag can make reference to the certification tag. Caution: Make sure that the certification statement on the original tag is not repeated on the inventory tag. This would be considered re-tagging and is illegal.
An example of this would be a repair station performing an incoming inspection, putting the original tag in a file, then placing their serviceable tag on the part. They can only make a statement that an incoming inspection was performed, not a certifying statement that the part was overhauled or repaired as indicated on the original document. A status block indicating that it is overhaul, repaired, etc. is acceptable.
Does a RFID tag (that will be attached to an item in the cabin where magazines, napkins, etc. are also located) need to be completely certified as if it were an airplane part?
ANSWER: Good Question. The term “Radio Frequency” obviously concerns the authorities, and they want to make sure that the RFID tag has no effect on the systems of the aircraft.
If you haven’t read AC 20-162 - AIRWORTHINESS APPROVAL AND OPERATIONAL ALLOWANCE OF RFID SYSTEMS you can download a copy by clicking here. It has some good information on this subject.
It appears to me that at a minimum, a safety assessment statement would be required to indicate the RFID tag was a passive tag and meets the requirements as defined in AC AC 23 or 25.1309-1 (depending on the size of the aircraft you are referring to.)
AC's 23.1309-1 and 25.1309-1 provide guidance on how to comply with FAR's 23.1309 and 25.1309.
You can download those two AC's below:
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