How did you install a Commercial Off-The-Shelf (COTS) equipment without EASA form-1? How do you arrange Part-145 side actually?
Answer
Note: The following information refers to the applicable rules, as amended with Commission Delegated Regulation (EU) 2021/699 and Commission Implementing Regulation (EU) 2021/700, which introduced more possibilities for installation of new parts. Due to the implementation period granted with these rules, the referenced paragraphs below will only be applicable as from 18 May 2022. Refer to these rules for the applicability dates.
The main idea is that to install new parts (by organisations approved i.a.w. Part-145, Part M-F or Part-CAO or by the individuals permitted to do maintenance in accordance with Commission Regulation (EU) No 1321/2014), the new part has to be accompanied with an EASA Form 1. However, M.A.502, 145.A.42 and ML.A.502 of Commission Regulation (EU) 1321/2014 permit certain alleviations by referring to 21.A.307 of Commission Regulation (EU) 748/2012. In particular, point (b) of 21.A.307 permits the installation of:
- 21.A.307 (b)(2) - Certain parts in ELA1 and ELA2 aircraft under the responsibility of the aircraft owner. (These parts were already permitted for installation prior to adoption of Commission Delegated Regulation EU) 2021/699 under the old reference 21.A.307(c))
- 21.A.307(b)(3) and (b)(4) – certain parts that the design approval holder (e.g. TC holder) or EASA in CS-STAN have determined as fulfilling certain conditions and are accompanied with an equivalent document that contains certain relevant information. A video explaining in detail why and how Part 21 was changed is available on the 2021/699 rule page under “Related content”.
Some of the COTs equipment may benefit from the above alleviations. Refer to the relevant text of the rule for full details, including the specific conditions to be fulfilled by 21.A.307 (b) parts, the need for the parts to be in a satisfactory condition, required info in the equivalent document, and parts marking.
In addition to the above, standard parts and consumables are exempted from the need to be accompanied with an EASA Form 1. Also, international safety agreements signed between the EU and a third country may alleviate the need of an EASA Form1 by recognising as equivalent a certificate issued under the third country rules. Refer to the relevant bilateral agreements and related implementation guides for full details.
Refer to Commission Regulation (EU) No 1321/2014 for the maintenance of parts referred in 21.A.307(b).