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

Here is a part of a second hand flight control which operates the flaps which was sold to me last week with a Form 1 – I relied on the Form 1 before buying it. I am so glad these bureaucratic bits of paper are there to protect the crack from getting any larger!

United Kingdom

Yeah – somebody with the “145 laser printer” recycled a used part. This is how the business works. You pay the national CAA for the license, and they license you to make a living doing this. Then out of your substantial profits you pay the CAA to license you to do more of it What is not to like?

Except that in the past we have had EASA fanbois here who went berserk at this criticism.

In reality the installer needs to inspect / otherwise check the part, but Europe has created a climate where there is blind reliance on the Form 1. It is the ultimate CYA device. I’ve been literally told that a Form 1 guarantees suitability for a given application e.g. a correct flap relay for a TB20. It is absolutely nothing to do with the application of the item. It is just a traceability document.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

In reality the installer needs to inspect / otherwise check the part, but Europe has created a climate where there is blind reliance on the Form 1. It is the ultimate CYA device. I’ve been literally told that a Form 1 guarantees suitability for a given application e.g. a correct flap relay for a TB20. It is absolutely nothing to do with the application of the item. It is just a traceability document.

Last year we bought an accessory for an aircraft, complete with Form One. When the shop was about to install, a piece of it didn’t fit. We complained to the manufacturer which sent a replacement piece. Then more pieces didn’t fit. In the end it turned out that the complete accessory we got was for a different aircraft model (which required slightly different dimensions) although the p/n on the Form 1 was correct… (I don’t want to “out” the manufacturer as we are otherwise happy with them and this is really a systemic problem. I can say they were very embarrassed.)

ESKC (Uppsala/Sundbro), Sweden

How much the purpose of EASA/CAA-Form1 is different from FAA8103-3? I understood both are 1/ for traceability & identification and 2/ show that a given product fits own design specs

It’s not what make an aircraft fly, it’s just a tagx (bureaucratic tag and tax )

Last Edited by Ibra at 09 Jan 08:44
Paris/Essex, France/UK, United Kingdom

Ibra wrote:

How much the purpose of EASA/CAA-Form1 is different from FAA8103-3?

Originally the FAA 8130-1 was only used to document the airworthiness of a repaired or overhauled part, which is still reflected in the ‘may constitute’ as this is a later addition to the original. The FAA thought CoC or other documentation from new as being ok to document a part was manufactured correctly. Yes, FAA followed the ‘we trust the mechanics’ route of parts being airworthy when tagged correctly (green tag, yellow tag).

EASA Form-One from the beginning was a strict route to have a special legal paper for a serial number of a part, so CoC for the general production documentation ‘there is a procedure these parts are airworthy’ and Form-One for ‘THIS specific part with serial number xyz has been manufactured according to the rules and is airworthy’. Little redundant, but founded on the general lack of trust European countries tend to have against citizens in general.

When flying in the US, I still see the freedom ‘tagged GA’ processes in place and only when entering the bureaucrazy European cave theater the strictly Form-One based hydrocephalus ;-).

Germany

Both EASA-1 and 8130-3 are tracebility documents, only.

The route to printing one off is similar: only a 145 company can do it, although in Europe there is a route whereby anybody can “rent” a 145 company’s approval to generate these forms (I have got one such example recently).

Apart from the 145 approval going only to a “company”, there is a different philosophy in US GA v. Euro GA: in the US, authority is vested in individuals (e.g. A&P) whereas in Europe it is vested in approved organisations (e.g. Part 21). There is a general distrust of individuals in Europe. The drawback of the Euro route is that if there is a cockup, the buck never stops with any person. Famously, one ISO9000 company’s quality manager, upon me teling them they delivered a product which was a load of crap, told me that since my business is not ISO9000, I am not even approved to buy from them

In the US, the 8130-3 is not usually needed in part 91 ops (an A&P has alone for the authority to inspect a part and declare it airworthy or not) although the general level of literacy of an A&P is no higher than that of an EASA66, so they love paperwork equally In the US, a “tag” is not needed legally but makes acceptance easier. But an STC which is totally not needed also makes acceptance easier – it’s today’s world

A great pity this EASA concession (thread topic) is not apparently usable anymore. Very few were able to use it (mainly for political / business protection reasons) but some did. And it would have made it very hard to prosecute a private pilot who procured some item “off the books”.

Administrator
Shoreham EGKA, United Kingdom

Note the use of the phrase “may be used” in the FAA description of Form 8130 as opposed to “must be used”. Also “promote identification” versus “provide”. This is intentional.

As per my earlier posts in this thread I have never been asked by any FAA A&P mechanic for paperwork when supplying a part for him to install. I have mentioned to a couple of them that the parts have had a Form 1 (those parts having come from Europe) and no 8130, more or less just to make conversation, and the response in every case has been “I don’t need or want either, it’s irrelevant”. Like anybody, A&Ps don’t necessarily like having their proper authority brought into question.

You are however supposed to have an 8130 to install items that by regulation must be serviced by a repair station, not an A&P, which mainly means instruments and propellers.

Last Edited by Silvaire at 09 Jan 15:48

Peter wrote:

The route to printing one off is similar: only a 145 company can do it, although in Europe there is a route whereby anybody can “rent” a 145 company’s approval to generate these forms (I have got one such example recently).

Not exactly: in the EU, a Part-CAO company (and Part-M Subpart F in the past) can also issue a Form 1. We do it all the time.

LKBU (near Prague), Czech Republic

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.

Is there any news on this?

Someone has just asked me about the TB20 landing gear squat switches. These are readily identifiable as Crouzet sealed limit switches but obviously you won’t get the Molex-type connector on the end which Socata use.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

Is there any news on this?

No. The EASA commenting website says that they are still processing the comments on the “Proposed Certification Memorandum”.

ESKC (Uppsala/Sundbro), Sweden
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