The Australian Civil Aviation Safety Authority recently issued guidance on utilization of components removed or salvaged from another aircraft. The bulletin offers up recommendations for making continue-in-service determinations. Under Australian regulations, that determination does not require issuance of a maintenance release, provided of course that no maintenance is required to make the article serviceable.
The privilege to conduct such an assessment was recently questioned in the U.S. In 2015, the Aeronautical Repair Station Association requested clarification on whether the continue-in-service determination constitutes an “inspection,” therefore requiring a maintenance release. Issues arose when repair stations were rated to perform work on the top assembly, but not for each individual sub-article. In its response, the FAA agreed that a rating for the “top assembly” signifies qualification to maintain all “sub-articles.” The agency concluded that “repair stations can implement procedures to perform inspections, tests and other maintenance in compliance with Part 43 on sub-articles and place them in stock for future use.”
European Aviation Safety Agency (EASA) regulations provide for the performance of maintenance and installation of recovered parts without issuing return-to-service documentation so long as the repair station has the appropriate procedures in place. Under European regulations, “when an organization maintains a component for its own use, an EASA Form 1 may not be necessary depending upon the organization’s internal release procedures defined in the exposition.”
The Australian bulletin reinforces the privilege for organizations holding a Civil Aviation Safety Authority certificate and falls in line with the majority of international authorities that support the practice so long as appropriate procedures are in place.