Filipe Pedro posted in General Aviation
Hello everyone. I have a question regarding Forms of PMA parts.
There is a Technical Implementation Procedure (TIP) for Airworthiness and environmental Certification, as a bilateral agreement between the FAA and EASA (https://www.faa.gov/aircraft/air_cert/international/bilateral_agreement…)
Section 3.3.4 states the cases in which a FAA PMA part can be accepted by EASA, with the information that needs to be present in the Form 8130-3 (for example, a statement that the part is not a critical component).
I believe this is clear for new parts. However, my question has to do with when those parts are subjected to an inspection, repair or overhaul. I believe that a repair shop that carries out an overhaul, for example, on a component that is a PMA part, can't add to the Form 1 or Form 8130-3 a statement such as "is not a critical component". Only the part's manufacurer can do it.
So, my question is: Are the requirements of the TIP out only applicable for new parts? What should a Form 8130-3 or Form 1 of an inspected/repaired/overhaul PMA part have, in order for us to be able to install it on an aircraft?
Hi Filipe,
I can give you my opinion based on our experience with NAAs, EASA and as auditors:
1. You are right, only the manufacturer can write "This part is not a critical component". This should not show up on an 8130-3/F1 for a service.
2. In those cases, I would argue you would need traceability to the original Form 1/8130 - i.e. you would need to hold a copy of the original document (with that S/N) that holds the statement you require. This is sometimes known as "part (record) history" and is something that is still unclear in the current regulation.
Hopes this helps!
Yes, that makes some sense. But what if you purchased an overhauled unit? Have you had any situation like this? I don't think part suppliers will have that kind of traceability.
EASA created the CA(M)O organizations to shift the responsibility of Cont. Airw. from the NAAs to these. As the regulation keeps evolving, more and more of this shift becomes evident and it is something that is not always well managed by both the organizations and the NAAs (the first have difficulty making decisions on ambiguous subjects, the latter on letting go of secular power).
In your specific case, the responsibility is ultimately yours/CAMO/P145. As an auditor, if the part was particularly relevant (e.g. a fuel pump) I would require the full part history - however, if it was a redundant system (e.g. Comm2/NAV radio) I wouldn't even question the "REPAIRED" F1/8130.
In any case, you can always consult your NAA on the subject.
This question becomes even more relevant with PART-ML. As the owner could be responsible for airworthiness management and request an annual airworthiness review while renewing his airworthiness certificate...
Hi Filipe Pedro,
Design changes under PMA concept are not considered under European rules nor by means of the bilateral.
If there is no design change linked to the PMA part (for instance the PMA part was produced under a license agreement), the part belongs to a design approved in Europe and the particular used part was already installed in a European aircraft, it can be installed if the part was maintained in an European approved maintenance organisation or if the part was maintained in a maintenance organisation located in the US and holding both FAA and EASA approvals. In this later case, the Form 8130-3 to release the part is called ‘Dual’ since the part can be installed in both US and European registered aircraft.
For maintenance provisions in regards to the Bilateral, do not refer to the TIP, but to the MAG instead.
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