What the 8110-3 is
FAA Form 8110-3, Statement of Compliance with Airworthiness Standards, is the form a Designated Engineering Representative uses to document that specific technical data complies with specific airworthiness requirements. It is the DER's signature on the record: it identifies the data, the regulations it was found compliant with, and whether the DER approved the data or recommended it for FAA approval.
On a typical STC or amended TC there is not one 8110-3 but many, one or more per discipline and per data package, issued as the compliance data matures.
Approve vs. recommend approval
The 8110-3 records one of two actions. When the data falls within the DER's delegated authority, the DER approves it on the FAA's behalf. When it does not, or when the FAA has retained the finding, the DER recommends approval and the FAA makes the final determination.
Which way each item goes should be agreed at planning and written into the certification plan. Surprises here are a common cause of late schedule slips, because data the applicant expected a DER to approve ends up in an FAA review queue.
What is on the form
- The project: applicant, aircraft or product, make and model, and the certification project or STC/TC number.
- The data: document numbers, titles and revision levels for each report, drawing or plan covered.
- The requirements: the specific 14 CFR sections and amendment levels the data was found to comply with.
- The action: approved or recommended for approval, with any limitations.
- The DER: name, designee number, discipline and signature.
Common examples
- Software: approval of the Software Accomplishment Summary and supporting life-cycle data for a DO-178C program, within the DER's software level authority.
- Electrical: approval of an electrical load analysis, wiring diagrams or EWIS compliance data for an installation.
- HIRF and lightning: findings on HIRF and lightning indirect effects test plans and reports against the applicable rules and advisory material.
- Major alterations: approved data supporting a Part 43 major alteration, later referenced on FAA Form 337.
Tips for applicants
- Keep document numbers and revision levels stable before requesting an 8110-3; a revision after signature means a new form.
- Map every compliance checklist line to the 8110-3 that closes it, so nothing is left without a finding at the end.
- Ask your DER early which data they can approve and which they can only recommend, and plan FAA review time for the latter.