This Notice of Proposed Amendment (NPA) aims to introduce more proportionate and efficient requirements in the airworthiness field, in particular to introduce commensurate manufacturing requirements for new spare parts and appliances. The requirement mandates that parts and appliances to be installed during maintenance need to be accompanied by a European Aviation Safety Agency (EASA) Form 1 to attest manufacturing in accordance with Annex I (Part 21) to Regulation (EU) No 748/2012, which is considered, in certain cases, disproportionate.
The so-called commercial parts are an example of that. Since these parts are often not designed exclusively for aviation use, parts manufacturers are not necessarily interested in achieving manufacturing recognition in accordance with Part 21 manufacturing standards (e.g. production organisation approval (POA)). Not only for commercial parts, but also for other parts and appliances a release certificate other than an EASA Form 1 may also be sufficient to guarantee adequate manufacturing quality.
In order to ease the manufacturing requirements for some of the parts, this NPA proposes to assign a criticality level (CL) for each part based on the safety consequences should the part fail to meet its design standards.
This NPA proposes that only the design holder (for instance, the type certificate holder) can establish the CL for each part, with the default option of assigning the most stringent CL to all parts. In certain cases, the possibility to assign CLs is also given to EASA. This NPA also establishes minimum manufacturing and release certificate requirements based on industry standards depending on the CL assigned to each part. Different marking requirements also apply for each part depending on its assigned CL.
Once the implementing rule and related AMC/GM are in place, by alleviating the effective requirements for the manufacture of parts not being critical, the manufacturing costs would decrease without affecting the safety of the air operations. The requirements proposed by this NPA may very positively impact on general aviation (GA), since often certain parts of the aircraft have not been designed with an aviation intent and not manufactured by a POA.