Please note that Proposed Certification Memorandum EASA CM-21.A-K-001 issue 2 ‘Installation of new parts and appliances without an EASA Form 1’ ‘Proposed Certification Memorandum EASA CM-21.A-K-001 issue 2 ’Installation of new parts and appliances without an EASA Form 1’’ is now open for consultation on the EASA website.
To place comments, please use the automated Comment-Response Tool (CRT) available at http://hub.easa.europa.eu/crt/.
The deadline for submission of comments is 09 Nov 2022.
I’ve read through it once and it seems they say very little in the way of clarifying 21.A.307(c) which is the troublesome new part. So I’m going to write a response about that.
Excellent.
How much more confusing can it become?
From 18 May 2022, a new requirement 21.A.307 becomes applicable (refer to Regulation (EU) 2021/699). This means that certain new parts do not require an EASA Form 1 for installation during maintenance. What are the implications of these regulatory changes, especially for General Aviation? Are ‘standard parts’ and ‘owner-accepted-parts (former 21.A.307(c)-parts’) impacted?
Answer
In essence, two new categories of new parts will be permitted to be installed during maintenance of European registered aircraft without the parts being accompanied with an EASA Form 1, but with an alternative document instead:
parts with negligible safety effect as identified by the holder of the design approval (according to 21.A.307(b)3);
parts with negligible safety effect as identified by EASA in CS-STAN for standard changes/repairs (according to 21.A.307(b)4)
This will permit fabrication of the above parts by organisations which are not approved as productions organisations (POA), which was considered too stringent for the manufacturing of parts having negligible safety impact in case of non-conformities. Note that already for years, and after the new regulatory change will become applicable, ‘standard parts’ (parts i.a.w. 21.A.307(b)1) and ‘owner-accepted-parts’ (parts i.a.w. 21.A.307(b)2) are not required to be accompanied with an EASA Form 1 when they fulfil certain conditions.
The industry boycotts this revenue-reducing option anyway, based on many reports I’ve had around Europe.
It can be very handy to smart people in the right situation 
Peter wrote:
The industry boycotts this revenue-reducing option anyway, based on many reports I’ve had around Europe.
Fortunately, that’s not what we have seen. We have used the 21.A.307 option several times. (Before the change. Now the maintenance companies say that the paperwork requirements caused by 21.A.307(c) makes it practically impossible. I do believe that wasn’t EASA’s intention, so it would be good if they could clarify what that paragraph really means.)
parts with negligible safety effect as identified by the holder of the design approval (according to 21.A.307(b)3);
parts with negligible safety effect as identified by EASA in CS-STAN for standard changes/repairs (according to 21.A.307(b)4)
That is just about basically nothing at all. Even a door handle is quite important.
Also the holder of the design approval has conflicting objectives:
and this is probably 99% of the aircraft maintenance business, especially as most owners buy stuff recommended by their maint shopYou don’t need a PhD to work out which way this pans out.
This has just arrived on email
Subject: EASA CRT: Extension of consultation period of Proposed Certification Memorandum EASA CM-21.A-K-001 issue 2 ‘Installation of new parts and appliances without an EASA Form 1’ ‘Proposed Certification Memorandum EASA CM-21.A-K-001 issue 2 ’Installation of new parts and appliances without an EASA Form 1’’
From: <[email protected]>
Date: Mon, 31 Oct 2022 08:43:04 +0000
I don’t know where to find the stuff though; no URL is contained in these notifications. Maybe someone can find it and advise if anything significant has changed.
Hmmm, funny is that this seems to be the same thing as above
https://hub.easa.europa.eu/crt/docs then “you have to find it”, right-click on it and “view document”.
It is the second one right now, but will undoubtedly be buried under new ones soon…
There is a somewhat hidden search interface… Click on the “funnel” icon next to “Title” and then a field appears, type “EASA CM-21.A-K-001” or “without an EASA Form 1”, then click the green checkmark (enter key will not work).
Peter wrote:
According to this post this concession is no longer really usable.
I have a feeling that maintenance organisations are overthinking what the new 21.A.307(c) really says. Our shops that now say that it is unusable didn’t have any issues with the old one so I don’t think they object for commercial reasons.
I hope that the comments on the “Proposed Certification Memorandum” leads to clarifications on how 21.A.307(c) should be interpreted.
