The FAA has published AC 20-162A, Airworthiness Approval of Installed Passive Ultra-High-Frequency Radio Frequency Identification (RFID) tags. The AC provides applicants with guidance for installing and using passive RFID tags on aircraft engines, propellers, parts and components. It said the draft AC does not cover RFID tags that communicate using cellular or satellite telephone technology; wireless wide area networks; high power radio transmitters or other types of tracking devices; or RFID tags - either passive or active .

Data from a passive RFID tag, which has no integral power source, can identify or give specific information about the product or equipment onto which it is installed. RFID interrogation typically does not require line-of-sight or contact between an RFID tag and respective readers. These tags have varying data storage capacity and field programmable utility, the FAA said.

The FAA noted that passive RFID part marking “is not an alternative” to meeting the part marking requirements of FAR 45.15 or 45.16. Per the draft AC, the agency considers the tags' data ancillary when placed on a non-critical or non-life-limited part and if they is performing a non-required, non-essential function. If the tags are attached to critical or life-limited parts, then the data must comply with FAR 45.15 or 45.16. Tags must also meet SAE and flammability specifications and should not cause electromagnetic interference, among other requirements.

While the FAA is laying the ground rules for use of these tags, the business aviation maintenance community doesn’t seem to be in any hurry to implement the concept.

Dave Latimer, vice president of regulatory compliance for Haeco Americas, told AIN, “We never applied RFID technology on parts. About eight years ago we experimented with using RFIDs to track safeties attached to oxygen generators, life rafts and slide actuators in an effort to ensure the maintenance safeties were removed before releasing an aircraft to service. We attached an RFID tag to our safety pins and as a final inspection technique we walked the aircraft with a reader to ensure all the safety pins were removed before releasing the aircraft. We found it didn’t provide 100 percent read rates, which defeated the purpose of a final inspection to ensure all safeties were removed. We abandoned the program about five years ago and returned to a manual verification system.”

Jason Dickstein, general counsel of the Aviation Suppliers Association, was part of a group that was working on electronic documentation standards for RFIDs about a decade ago. “We talked about embedding part information and making the RFID robust enough to embed maintenance information, too, but it never went much further. To make it happen you have to see a benefit, and you have to be able to afford the significant investment it would take to develop it. At least for now, the cost/benefit ratio doesn’t seem to support development.”