The part was never changed, the mechanic never did the work, etc.
In general yes but in this case there is lots of paperwork the part is broken so even more paperwork is needed to prove it is fixed.
bq. Unfortunately that will not work for my part as it is a landing gear part :-(
Why not?
It is about a full nose gear assembly so I would have to argue it is “not life limited, nor part of the primary structure, nor part of the flight controls”. Ok it is not life limited that works, nose gear is not part of the flight controls, but maybe part of “ground controls” because it is part of the steering? And finally is the landing gear in general part of the primary structure?
Sebastian_G wrote:
And finally is the landing gear in general part of the primary structure?
I would argue no and my supporting data is that the Cessna RGs have a nasty nose gear collapse issue which has been known for long and has caused hundreds of nose gear collapses and yet the fix is only an SB and not an AD. If the nose gear was part of the primary structure, it would be an AD.
A full nose gear assembly is part of the primary structure. “Primary structure” is one of those few things that does have a clear definition and one that is common to EASA and the FAA: Primary Structure is structure that carries flight, ground, or pressurisation loads.
My recommendation would be to use the other route I proposed. You will need to build an understanding of the AMC associated with M.A. 613(a). Essentially the process is:
For used parts an 8130-3 is not good enough, one will need a “dual release”-form, right?
Is the dual release just a special wording or does the issuing shop need some form of EASA approval?
G
A dual-release 8130-3 has the EASA approval number (for the supplier which generated the form) in Box 13.
It is thus equivalent to an EASA-1 form.
This concept is mostly used for stuff made by some big US firms who got themselves EASA 145 approvals so they can sell more easily in the European market.
Most smaller US firms are not EASA approved.
For used parts an 8130-3 is not good enough
True for EASA-reg, but not for an N-reg.
As an aside, I wonder to what extent an 8130-3 or EASA-1 form or a dual-release 8130-3 is really required. Last time I looked into this, all that was needed was evidence of traceability, so there were other options. But few people in the business would tell you that because the parts with the forms cost more so everybody upstream makes more money.
Peter wrote:
A dual-release 8130-3 has the EASA approval number (for the supplier which generated the form) in Box 13.It is thus equivalent to an EASA-1 form.
This concept is mostly used for stuff made by some big US firms who got themselves EASA 145 approvals so they can sell more easily in the European market.
Most smaller US firms are not EASA approved.
Not completely correct.
For FAA aircraft, new parts with an EASA Form 1 are acceptable
For EASA aircraft, new parts with an EASA Form 1 OR an FAA Form 8130-3 are acceptable. For new parts their is no need for a dual release.
For used components on an EASA aircraft the part should be with an EASA Form 1 or an FAA-8130-3 WITH dual release. This dual release is only to be issued by companies who have both an EASA and FAA Part 145 AND are located in either EU or USA. For example an Canadian company which hold FAA and EASA Part 145 shouldnot issue an dual release.
I don’t think I said anything different
I never realised however an 8130-3 can come from anywhere but the USA.
Jesse wrote:
For FAA aircraft, new parts with an EASA Form 1 are acceptable
For privately operated FAA light aircraft, neither an 8130 or EASA Form 1 is required, for either new or used parts.
Peter wrote:
This concept is mostly used for stuff made by some big US firms who got themselves EASA 145 approvals so they can sell more easily in the European market.
This is the part that is incorrect, because it is not applicable to new parts.
Peter wrote:
I never realised however an 8130-3 can come from anywhere but the USA.
You can have an FAA add-on on an EASA Part 145, or an EASA add-on on a FAA Part 145 (for dual release). A company could also have two individual approvals.
For example, an EASA Part 145 can not issue a dual release for repairs done with parts which are only acceptable to FAA. For example alternator couplers for gear driven alternators can be overhauled. This become a part of the alternator. An alternator done by an EASA Part 145 must meet the EASA requirements, therefore the coupler can only be used if it comes with an FAA 8130-3 dual release or an EASA Form 1. A regular FAA-8130-3 will not be good.
When that same company had a seperate full Part FAA Part 145, this coupler would be acceptable, and they would be able to issue an 8130-3.
This is the part that is incorrect, because it is not applicable to new parts.
I am trying to get my head around this bit.
For example Pen Yan (a US engine overhauler) will do a dual release 8130-3, so a G-reg owner can get his engine overhauled there.
Similarly Garmin will do a dual release 8130-3, so a G-reg owner can install their boxes (new or overhauled).
Barrett Precision, a top US overhauler, can do only a simple 8130-3 so is of no use for a G-reg. Unless you get an FAA DAR to do an Export CofA (8140 form) which used to cost about $300, but this system ended a few years ago and I don’t know what replaced it*
* I read that the UK CAA will accept a plain 8130-3 in some such cases, and I know for a fact of a case involving a TB20 overhaul in another then-JAA country where this was accepted.