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

I don’t think so…

and indeed I didn’t write that

Your percentages, Snoopy, are probably accurate and this is why we have EuroGA so this stuff can be freely discussed and debunked if appropriate.

However the “industry” is often its own worst enemy. And that’s just the honest ones. Then there are the others who positively do not want their customers to know the process… and if you did find out the correct process and asked them to follow it, you get this sort of thing:

OK Peter
Enough from you, please do not contact me again, look at getting this and any other work done somewhere else
Regards
[name removed but very well known]
Avionics Director

So now you have one less shop you can use, and there aren’t that many to start with. And some seem to be in deep hiding because they have so much work. The above quote is from a shop which did ~5 jobs for me over the years and none were done right.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

and indeed I didn’t write that

Ooops, while I didn’t mean to imply that in any way, shape or form (given that you were quoting somebody else) I can see that my post might give that impression. Sorry for that!

Last Edited by Silvaire at 18 Apr 22:40

Change to 21.A.307

EASA has just published a change to the clause 21.A.307 of Part-21 – the “dynamite clause” regarding installation of components without a Form 1. The old wording has been slightly rearranged and several new points have been introduced. The new point (c) is especially important.

21.A.307 The eligibility of parts and appliances for installation

(a) A part or appliance is eligible for installation in a type-certified product when it is in a condition for safe operation, marked in accordance with Subpart Q and accompanied by an authorised release certificate (EASA Form 1), certifying that the item was manufactured in conformity with approved design data.

(b) By way of derogation from point (a) and provided that the conditions in point (c) are met, the following parts or appliances do not require an EASA Form 1 in order to be eligible for installation in a type-certified product:

(1) a standard part;

(2) in the case of ELA1 or ELA2, a part or appliance that is:

(i) not life limited, nor part of the primary structure, nor part of the flight controls;
(ii) identified for installation in the specific aircraft;
(iii) to be installed in an aircraft whose owner has verified compliance with the applicable conditions in (i) and (ii), and has accepted responsibility for this compliance;

(3) a part or appliance for which the consequences of a non-conformity with its approved design data has a negligible safety effect on the product and which is identified as such by the holder of the design approval in the instructions for continued airworthiness. In order to determine the safety effects of a non-conforming part or appliance, the design approval holder may establish in the instructions for continued airworthiness specific verification activities to be conducted by the installer of the part or appliance on the product;

(4) in the case of the embodiment of a standard change in accordance with point 21.A.90B or a standard repair in accordance with point 21.A.431B, a part or appliance, for which the consequences of a non-conformity with its design data have a negligible safety effect on the product, and which is identified as such in the certification specifications for standard changes and standard repairs issued in accordance with point (a)(2) of point 21.A.90B and point (a)(2) of point 21.A.431B. In order to determine the safety effects of a non-conforming part or appliance, specific verification activities to be conducted by the person that installs the part or appliance on the product may be established in the certification specifications referred to above;

(5) a part or appliance that is exempted from an airworthiness approval in accordance with Commission Regulation (EU) No 965/2012; and

(6) a part or appliance that is an item of a higher assembly identified in points (b)(1) to (b)(5).

(c) Parts and appliances listed in point (b) are eligible for installation in a type-certified product without being accompanied by an EASA Form 1, provided that the installer holds a document issued by the person or organisation that manufactured the part or appliance, which declares the name of the part or appliance, the part number, and the conformity of the part or appliance with its design data, and which contains the issuance date.

LKBU (near Prague), Czech Republic

I heard about this coming. I understand it’s positive for light GA!?

specific verification activities to be conducted by the person that installs the part or appliance on the product may be established in the certification specifications referred to above;

So if the DAH doesn’t offer any verification, does this mean a Pt. 66 installing the part can verify that it has a negligible safety effect?

Any specific example? What about the reference to C-STAN?

Part C) would, in most cases, simply be the data plate containing „Pt. Nr.: 12345, TSO xyz“, right?

Last Edited by Snoopy at 29 Apr 21:34
Airline/Mentor/Safety/Instructor - Pilot
Based Austria | Operating Worldwide

Snoopy, the devil is in the details – I would wait for the new AMC/GM to be issued. Regarding the point (c), not all components are subject to TSO/ETSO – again, let’s wait for the AMC/GM.

Last Edited by Ultranomad at 29 Apr 21:38
LKBU (near Prague), Czech Republic

So a practical question based on these rules – if you have an aircraft that was originally fitted with old automotive gauges that are no longer working properly, could you use this rule to replace them with modern equivalent gauges?

To clarify it’s about replacing 1969 smiths gauges with modern SPA or Stack gauges to fit in the same places and give the same data, but reliably….

Learning & burning
Thruxton, United Kingdom

Is the aircraft with the automotive gauges on a UK CAA C of A, or on a Permit to Fly? (LAA or CAA – EASA Permits now gone in UK)

Maoraigh
EGPE, United Kingdom

Maoraigh wrote:

Is the aircraft with the automotive gauges on a UK CAA C of A, or on a Permit to Fly? (LAA or CAA – EASA Permits now gone in UK)

The aircraft is a Beagle Pup on a UK CAA (formerly EASA) Restricted CofA.

Learning & burning
Thruxton, United Kingdom

if you have an aircraft that was originally fitted with old automotive gauges that are no longer working properly, could you use this rule to replace them with modern equivalent gauges?

Is this under LAA inspector supervision?

That EASA concession applies only to certified aircraft, but it would have been incorporated into UK law on 31 Dec 2020. But having said that I don’t think you can use it for a non-CofA (or non Part 21 if you like) aircraft. But maybe a Beagle Pup is a Part 21 aircraft (what was previously called EASA aircraft).

Administrator
Shoreham EGKA, United Kingdom

Check who issue/can issue your P to F, and ask them. The LAA may now do Beagle Pups.
I thought my Bolkow was on a LAA P to F. There was nothing on the Permit to indicate otherwise.
On 31/12/2020 I received an email saying it had been on an EASA P to F, which would become invalid. I had to download, print, and carry a CAA Letter authorising flying with the invalid P to F until its expiry date.

Maoraigh
EGPE, United Kingdom
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