When do I need a dual release on FAA Form 8130-3 under EU/US bilateral agreement?
Under the terms of the EU/US bilateral agreement (BASA) (see here), a DUAL release is required for acceptance of USED engine/components from an US based repair station.
NOTE: a single EASA release on Form 8130-3 with only “Other regulation specified in block 12” ticked in block 14a is also acceptable for USED engine/components. This is to cover the case where component maintenance includes the installation of a used (sub)component released on an EASA Form 1 with ‘single release’ only, and therefore where the assembly is not eligible for US-registered aircraft.
CAUTION: DUAL release is not acceptable for ‘rebuilt’ engine/components because EASA recognises the term ‘rebuilt’ only as a manufacturing/production release (not a maintenance release) and only for engine.
Can I import a rebuilt engine and associated components from US?
Under the terms of the EU/US bilateral agreement (BASA) (see here), you can import an engine with a ‘rebuilt’ status in block 11, only when it has been released by the original engine manufacturer on a Form 8130-3 using the blocks 13a. to 13e. (left side).
Please note that Form 8130-3 with ‘rebuilt’ status are not acceptable for components other than engine (regardless whether it has been released on left or right side) therefore the components accompanying the rebuilt engine should either be released REPAIRED/OVERHAULED… (right side) or NEW (left side).
What does it mean ‘a release document issued by an organisation under the terms of a bilateral agreement signed by the European Union’ referred in AMC1 M.A.501(a)(1)/AMC1 145.A.42(a)(i)/AMC1 ML.A.501(a)(ii)?
AMC1 M.A.501(a)(1)/AMC1 145.A.42(a)(i)/AMC1 ML.A.501(a)(ii) refers to a release document issued by an organisation under the terms of any existing bilateral agreement signed by the European Union. Currently such agreements are signed with:
- USA
- Canada
- Brazil
- Japan (limited to design and production)
- China (limited to design and production)
- United Kingdom (limited to design and production)
Note:
For organisations approved under Part-CAO and Part-M Subpart F the situation is different. Credit can be taken for their technical capabilities and their competent authority oversight (FAA and TCCA). This situation is explained in AMC1 CAO.A.070(a) paragraph 2.8 and AMC M.A.613(a) paragraph 2.8.
What kind of release document is considered equivalent to an EASA Form 1 under the terms of the US-EU Bilateral safety agreement? (AMC1 M.A.501(a)(1)/AMC1 145.A.42(a)(i)/AMC1 ML.A.501(a)(ii)/AMC1 CAO.A.070(a))
Acceptance of NEW engine/components (and rebuilt engines) is governed by the Technical Implementation Procedure (TIP). The general principle is to accept such engine/components when released new on FAA Form 8130-3 using the blocks 13a to 13e (left side). Please refer to Section VII (from para 7.7 on) of the TIP for the detailed conditions under which this is acceptable.
Acceptance of USED engine/components from an US based repair station is governed by the Maintenance Annex Guidance (MAG). The general principle is to accept such engine/components when subject to ‘dual release’ on FAA Form 8130-3 (except where the component is not eligible for U.S.-registered aircraft), using the blocks 14a to 14e (right side).
- Block 11 should provide the status of the component (e.g. ‘overhauled’)
- Block 12 should include (or refer to) detailed information on the work performed, the associated approved data (e.g. ‘Overhauled in accordance with CMM 111, Section X, Rev 2, S/B 23 and FAA AD xyz complied with’) as well as the EASA Part-145 statement and approval number.
- Block 14 should at least show “Other regulation specified in block 12” ticked
What are the component release documents acceptable for installing a component (on aircraft or on a higher assembly) and releasing associated maintenance under EASA Part-145 regulation?
The linked reference table provides a table summarising the component release documents (FAA Form 8130-3, TCCA Form One, ANAC Form F-100-01…) acceptable to an EASA Part-145 organisation, depending on where such organisation is located and from which regulatory system the component is coming.