FAA Feedback: The Yellow Tag

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 theres 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 isnt 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 whats 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 isnt sent and the technician is left holding the bag because he has no idea of whats happened to the component.

The yellow tag doesnt 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 youve 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______. Thats great, but if the repair station goes out of business, the records may no longer be available. And even if its 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:

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FAA Feedback: The Yellow Tag