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EASA Reconsiders Part-Tagging For Repairs Subject To EU-U.S. Bilateral

Industry is particularly embattled by the regulation’s applicability to commercial parts, often produced for nonaviation use in the U.S.

The European Aviation Safety Agency (EASA) released a long-awaited notice of proposed amendment (NPA) that would relieve parts documentation requirements imposed on EASA-certificated, U.S.-based repair stations through the U.S.-EU bilateral agreement’s Maintenance Annex Guidance (MAG).

The MAG essentially requires an EASA Form 1 equivalent (i.e., an FAA Form 8130-3) for new parts, creating what industry deems an impossible situation since production approval holders (PAH) are not required to provide the document under FAA regulations. Previous efforts to persuade the European authority to recognize equivalent evidence of airworthiness fell flat.

Industry is particularly embattled by the regulation’s applicability to commercial parts—which are often produced and sold for nonaviation use in the U.S., and therefore sans the required 8130-3—further exacerbating an already tenuous situation.

In August 2016, the FAA published Notice 8900.380, providing an alternative path to compliance if the required documentation cannot be obtained from the PAH. The notice confirmed a repair station’s privilege to inspect and approve a new part for return to service when it is not accompanied by Form 8130-3, so long as the repair station establishes traceability. The notice’s one-year expiration date was extended to August 2018 while the authorities endeavor to get the language incorporated into MAG Change 7.

EASA officials previously had indicated support for eliminating the condition for most parts, while retaining the need to establish traceability to the PAH. That intent comes to fruition in the NPA, which acknowledges that “requiring an EASA Form 1 for all aircraft parts [e.g., parts not designed exclusively for aviation] might be too onerous and unnecessary.”

The NPA addresses commercial and “other” parts where alternative documentation is sufficient to “guarantee adequate manufacturing quality.” Under the proposal, manufacturers or EASA would assign a risk-based criticality, Level 1-4, for each part, which would in turn dictate documentation requirements.

While the proposal—if adopted—would provide some relief for companies struggling to comply with the international agreement, respite will not come easily or quickly. Five years have passed since the action was initiated via published “terms of reference.” The target date for submitting an opinion to the European Commission for consideration is the fourth quarter of 2018. Issuance of the regulation, along with related acceptable means of compliance and guidance material, is expected by 2020.

Comments to the NPA are due March 14.

David Pimborough/Adobestock

Suppliers of new-parts struggle to move current inventory that lacks an 8130-3.

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