FAA has extended authority for distributors to tag parts with paperwork that European authorities now require for us in shops with both FAA and EASA approvals, easing a major headache for the parts-distribution community.
Extending the program, which gives limited designated airworthiness representative authority to distributors, was not FAA's first choice. The agency hoped to sit down with EASA and work out a compromise that would ease the requirements, which came into force last year and caused far more trouble than the agencies anticipated.
The issue requires certain parts to include documentation, such as an 8130-3 airworthiness approval tag, before they can be accepted at the 1,400 repair stations that carry dual FAA and EASA certifications. No such requirement exists in U.S. regulations, so most parts manufacturers don't do it. EASA, which requires documentation in its production-approval rules, wanted similar language added in the guidance used to define the U.S.-European Union bilateral aviation safety agreement, and last year got its wish.
The parts-distributor community, led by the Aviation Suppliers Association (ASA), immediately saw problems. The biggest: inventories held by distributors—millions of dollars in perfectly good parts—were immediately put at risk. Granting distributors temporary authority to tag their parts was FAA's solution.
The program still only applies to parts in inventories before Nov. 1, 2016. While that leaves a curious hole, it covers millions of dollars in parts that distributors have not been able to tag in the one year since the program went into effect.
The extension, through September 2018, comes with a bit of additional oversight—something FAA said had to be part of any future program, temporary or permanent. Among the safeguards: representatives from FAA's Delegation and Organizational Procedures Branch will make site visits to selected distributors "to conduct onsite direct observation."