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Installation of parts and appliances released without an EASA Form 1 or equivalent

It is "believed" that an 8130-3 is OK for a new part, and an EASA-1 form is OK for both new and used (e.g. overhauled).

Can anybody find the actual reference for the above?

It is rare for regs to specify a specific document style as mandatory.

Administrator
Shoreham EGKA, United Kingdom

Peter

As your question implies, the regulations in this space are complex and often require the weaving together of clauses from different documents.

A summary of my interpretation is:

  1. All parts fitted to an EASA reg aircraft need a Form 1 (M.A. 501) (but see final para)
  2. M.A. 501 provides for "a Form 1 or equivalent". The associated AMC includes the definition of "or equivalent" as being a release document where there is a bilateral arrangement. The most common is an 8130-3 but there is nothing mandatory about it e.g. it could be a TCCA 24-0078 from Canada.
  3. The above holds good for new components.
  4. For maintained components, M.A. 502 also applies. M.A. 502 states that components shall only be maintained by an EASA-approved organisation. There are many EASA-approved maintenance organisations in e.g. the US who can therefore issue a Form 1 themselves - colloquially known as a "dual release".
  5. There are also lots of smaller FAA-approved maintenance organisations who do not have EASA approval. EASA realised that their services are critical to keeping the European fleet airworthy and legislation was produced in 2010 to permit their use. It is pretty clunky legislation, but I have used it personally. The legislation essentially lays out the process to permit the EASA maintenance firm to produce a Form 1.
  6. Just as you thought it was all becoming clear, along comes regulation 748/2012. This provides for parts to be fitted to an ELA1 or ELA2 aircraft without a Form 1. The process is that the aircraft owner may release the part to service. There are some sensible limits e.g. not engines, not wing spars etc. In June 2013, a Certification Memorandum was issued to assist a maintenance firm with the interpretation of 748/2012.

I am certain there are some holes in my interpretation and would welcome any corrections

Alan

I think there are two types of aircraft components:

  1. Lifetime-limited components which are in the official docs of the aircraft with serial number, date of installation, due date etc. Make sure your paperwork is 100% correct on those and store the Form 1 until the end of your days. Failure to produce those forms on an aircraft inspection might cost you that part in new.

  2. Everything else that is just in the aircraft. Nobody will be able to say whether part XYZ originally had serial number 10 and now ask why it suddenly has serial number 100 in the aircraft. Of course I would never do it (because my real purpose in life is to be 100% compliant with all EASA regs) but one might prefer to order such parts from places where you get them for much less without 8130/Form 1 and just install them.

Luckily the list for category 2 is much larger.

Alan - a great post; thank you. And welcome to EuroGA

M.A. 501 provides for "a Form 1 or equivalent". The associated AMC includes the definition of "or equivalent" as being a release document where there is a bilateral arrangement. The most common is an 8130-3 but there is nothing mandatory about it e.g. it could be a TCCA 24-0078 from Canada.

Is there a list of documents for which there is a bilateral agreement?

Otherwise, it would be easy to show that some CofC is as good as an 8130-3 for example. All that an 8130-3 shows, for a serially numbered part, is that the part is genuine. For a non-numbered part it doesn't mean anything of course, which is good or bad depending on whether you are the seller or the user!

The legislation essentially lays out the process to permit the EASA maintenance firm to produce a Form 1.

Do you mean this by any chance?

It is really really interesting.

Not for some trivia like an o-ring (which at €20 might be a ripoff against the real price of €2 but who really cares, on an Annual service?) but for something much bigger like a €10k fuel pump, etc.

Lifetime-limited components which are in the official docs of the aircraft with serial number, date of installation, due date etc. Make sure your paperwork is 100% correct on those and store the Form 1 until the end of your days. Failure to produce those forms on an aircraft inspection might cost you that part in new.

Yes, but many life limited components don't have a serial number. So the only evidence of them having been changed is a logbook entry saying so, hopefully backed up by an EASA-1 form or an 8130-3 or whatever (see above). There is no way to check the part was actually changed.

For example all mandatory-change items inside a magneto are not numbered.

For an "inventive" maintenance company, they could re-reference the same documents (which came with one part) on many aircraft, and the only way they would get caught would be if 2 or more owners met up and compared their work packs, or if the CAA did an audit. That is probably why the firms that do this kind of thing don't like to give you the work pack.

Administrator
Shoreham EGKA, United Kingdom

Is there a list of documents for which there is a bilateral agreement?

A bilateral agreement is with an agency. For almost all our purposes, the FAA is sufficient.

An EASA Form 1 is a "release to service" document, so any equivalent must also be so. An 8130-3 is also a release to service document, but a CofC is not.

Do you mean this by any chance?

I haven't looked at the linked document, but I'm certain it is the same.

For anyone on the EASA register and sub 2t, the Certification Memorandum is well worth reading. You can find it here

[edited for quote formatting; use no tabs or spaces before the > character which starts a quote]

The linked document is something which somebody typed up and gave me. I don't remember who it was.

From the EASA doc, I do like this bit

3.4. HOW TO TREAT PARTS AND APPLIANCES WITHOUT AN EASA FORM 1
Ultimately it is the owner of the aircraft within the ELA1 or ELA2 criteria who takes the responsibility to accept a part or appliance within the given criteria for installation on his/her aircraft.

Gosh that is almost like America. The pilot is responsible for not killing himself. Surely that can't work!

Administrator
Shoreham EGKA, United Kingdom

What is the latest on this topic?

It doesn’t bother N-reg owners (well unless they have an anally retarded A&P ) because for most smaller parts an A&P has the authority to declare a part as airworthy upon being satisfied of its origin, etc, but EASA-reg people have a more complicated situation.

Maybe below 1200kg (ELA1) it is different? Some years ago I wrote this article which documented what most people didn’t know back then.

Administrator
Shoreham EGKA, United Kingdom

The latest reference on which parts must have an EASA-1 form to be installed on an EASA-reg?

There is a wide variation in the field on the implementation.

I see cases where a firm will refuse to touch even an “avgas” wing sticker (or something similarly trivial) without an EASA-1. But a lot seems to depend on whether the part was sourced by the company, or supplied by the aircraft owner. They tend to be tighter in the latter case.

Is there a clear reference for this, listing the item categories? I get asked quite often by pilots whose planes are grounded, sometimes for many weeks, because some part is available but without an EASA-1.

Administrator
Shoreham EGKA, United Kingdom

I wonder why nobody has responded to this one?

I can however well imagine the answer is not trivial, because there are different categories of parts.

Administrator
Shoreham EGKA, United Kingdom

Peter, as far as I understand it, there’s no real list of parts but just a certain list of criteria which, as long as the said part meets the restrictions below (currently only for ELA1, ELA2 should follow shortly) then the owner can install a part as long as he notes the work in the logbook and accepts responsibility for this installation

21.A.307 (c) in the case of ELA1 or ELA2 aircraft, a part or appliance that is:

1. not life-limited, nor part of the primary structure, nor part of the flight controls;
2. manufactured in conformity to applicable design;
3. marked in accordance with Subpart Q;
4. identified for installation in the specific aircraft;
5. to be installed in an aircraft for which the owner has verified compliance with the conditions 1 through 4 and has accepted responsibility for this compliance.

EDL*, Germany
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