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Opinion 07/2019

Instructions for continued airworthiness | Installation of parts and appliances that are released without an EASA Form 1 or equivalent

The objective of this Opinion is to mitigate the risks linked to the uncertainty of the status of the instructions for continued airworthiness (ICA) and, therefore, to avoid leaving room for interpretation in the rules, leading to differences in the use of ICA and causing possible safety risks. 

In order to achieve this, this Opinion proposes to amend Annex I (Part 21) to Commission Regulation (EU) No 748/2012 to clarify that the ICA are part of the type certificate (TC). It also proposes to merge the requirements related to record keeping, manuals and ICA in the various subparts into a single requirement for each of these aspects in Subpart A (new points 21.A.5, 21.A.6 and 21.A.7). 

The proposed amendments are expected to improve the harmonisation of the ICA among the design approval holders (DAHs) in relation to the identification, approval, formatting and availability of the ICA to the end users. 

Another objective of this Opinion is to propose more proportionate and efficient requirements by introducing commensurate manufacturing requirements for new spare parts. The need to require a European Union Aviation Safety Agency (EASA) Form 1 to attest manufacturing in accordance with the approved design data is considered disproportionate for certain parts. 

In order to achieve this, this Opinion proposes to relax the requirement that all parts installed on an aircraft have to be issued with an EASA Form 1 or equivalent when they are installed during maintenance work. Instead, it is proposed that certain parts that do not impact safety could be manufactured outside the Part 21 production environment and do not require an EASA Form 1 to be installed in a product. Similarly, it is proposed that these parts should be exempted from the requirement to be maintained in a maintenance organisation approved in accordance with Commission Regulation (EU) No 1321/2014. 

The proposed amendments are expected to reduce the regulatory burden on maintenance organisations that use these parts during their maintenance work, so they would be able to easily obtain the parts, without decreasing the level of safety.