Can you reproduce part data tags?

DenverDave

Filing Flight Plan
Joined
Oct 4, 2018
Messages
27
Display Name

Display name:
Flyer12345
Can an owner, A&P, owner and A&P, etc reproduce a worn data tag that was on a component?

My brake caliper data stickers are quite worn and falling off. I like having bolt torque and part number easily visible for anyone working on it. One caliper is getting cleaned and resealed at annual so it probably won’t have a tag on it if I don’t make a new one.
 
I can’t think of a reason why not. Are brake calipers required to have data plates?
 
I keep a page in the airplane logbook with that info - part numbers and serial numbers. That way if the tag on the part fades or comes off, the info isn’t lost. In a separate binder is service information with the same info, plus hardware spec (bolt type, etc.) and torque. If there is a manufacturer’s service manual or guideline, it’s in the maintenance binder as well.
 
I can’t think of a reason why not. Are brake calipers required to have data plates?

What happens if those calipers have an AD come out, and specifies a certain serial number range? No data tag with serial number means the AD must be complied with if you have no way to prove what serial number it was.

The P/N and S/N are valuable information.
 
It would be impossible for a mechanic to verity the part as correct with an unofficial tag.
 
The P/N and S/N are valuable information.

Yes they are.

So, are they REQUIRED to have a data plate? Certainly not by 45.11. Is there something else, maybe 45.15?

AC 43-213 holds information.

Altering or Restoring Markings. Once a product is in service, maintenance providers routinely remove markings, data plates, etc. and replace them during maintenance and alteration in accordance with acceptable methods, techniques, and practices. Similarly, when markings are obliterated or illegible due to wear or other damage, the FAA permits the identification information to be restored where adequate records, inspections, or other information exists to verify the part’s authenticity. Such management and “restoration” of part markings is conducted under 14 CFR part 43 and other applicable regulations when returning an article to its “original or properly altered condition.” It is not a violation of the marking requirements of part 21 or 45, because the article is being “maintained” not “manufactured.” This has been the case historically even for critical parts subject to an airworthiness limitation (AL). Maintaining continued airworthiness (when an article is maintained and/or altered, and subsequently returned to service) does not include the same regulatory marking requirements as the original manufacturing requirements (when an article must conform to the original design approval holder’s (DAH) approved design for a new product).
 
Yes they are.

So, are they REQUIRED to have a data plate? Certainly not by 45.11. Is there something else, maybe 45.15?

AC 43-213 holds information.

Altering or Restoring Markings. Once a product is in service, maintenance providers routinely remove markings, data plates, etc. and replace them during maintenance and alteration in accordance with acceptable methods, techniques, and practices. Similarly, when markings are obliterated or illegible due to wear or other damage, the FAA permits the identification information to be restored where adequate records, inspections, or other information exists to verify the part’s authenticity. Such management and “restoration” of part markings is conducted under 14 CFR part 43 and other applicable regulations when returning an article to its “original or properly altered condition.” It is not a violation of the marking requirements of part 21 or 45, because the article is being “maintained” not “manufactured.” This has been the case historically even for critical parts subject to an airworthiness limitation (AL). Maintaining continued airworthiness (when an article is maintained and/or altered, and subsequently returned to service) does not include the same regulatory marking requirements as the original manufacturing requirements (when an article must conform to the original design approval holder’s (DAH) approved design for a new product).

Not sure what point you are trying to make, but the OP was talking about a worn data tag and replacing it. I stated my point of the value of the data on the tag to potentially avoid costly maintenance.
 
If the data plate fell off in flight, do you have to discard the part. No.

Otherwise, it's fine as replacement of part data tags is permissible, it appears by an A&P
 
If the data plate fell off in flight, do you have to discard the part.

No. Hopefully whoever installed the part, or performed previous maintenance on it wrote down the P/N and S/N in the log.

If that's the case, then use the log as the reference and produce a tag for the part with a log entry.

However, as in most GA aircraft, if no p/n or s/n can be found for the part that lost the data tag, then if an AD comes along, it will have to be done if the A&P cannot identify a serial number range.

Also, it could complicate parts replacement in that part as well. Some internal parts are made for s/n parts in a specific range.
 
Can an owner, A&P, owner and A&P, etc reproduce a worn data tag that was on a component?
The current guidance is not to replace the original tag but add another tag or marking. It's mentioned in the AC listed above. In addition, the AC states that any removal, restoration, etc. should be performed per Part 43 and documented in the aircraft record. I've also had some limited success in contacting the OEM for assistance with tag restoration. But it can be a hit or miss.
 
Thanks for the replies everyone. I don’t think these calipers have serial numbers, only month/year of production. I’ll have to take another look at my data label mounting area to see if there is room for simply adding without removing others tags.

I made a quick prototype with some errors. It’s on a UL listed label for up to 300F continuous. The piston O-ring is only rated for 275F.
81441ADF-4682-40AA-915C-265F553AC2DE.jpeg
 
I’ll have to take another look at my data label mounting area to see if there is room for simply adding without removing others tags.
Any secondary tag doesn't need to go in the same location. And since it is a supplemental tag you could delete some of that data to shrink the footprint. Depending on the situation I have used self-adhesive metal tape and stamped the pertinent data on it but always left the original in place. Follow up with an entry in the record explaining the tag (plus add the data as well) which falls under several prevent mx categories so you can make the entry and sign it.
 
that's a dang good tag!
Howdja do that??

I used my thermal transfer printer with a polyester label and resin ribbon. Cut to size with a ruler and Swiss Army knife.

If anyone needs a new tag, tire pressure stickers, etc message me and I’d be happy to print it out and put it in the mail. It’s only 203 DPI so smaller text isn’t that sharp.
 
Thanks for the replies everyone. I don’t think these calipers have serial numbers, only month/year of production. I’ll have to take another look at my data label mounting area to see if there is room for simply adding without removing others tags.

I made a quick prototype with some errors. It’s on a UL listed label for up to 300F continuous. The piston O-ring is only rated for 275F.
View attachment 95361

My opinion, especially if replacing the label is to make an entry in the logbook that the label was replaced and verifying all the information on the original label is in the logbook, either from the original installation or in the entry of the label replacement.

Brian
 
Yes you can. The AC listed above gives guidance. I have done it several times on aircraft that were operated on certificates and the parts were life limited components. All documented and accepted by the FAA on inspection.
 
Back
Top