Peter wrote:
a US based avionics merchant getting a European firm to generate an EASA-1, when you can’t get an 8130-3 done for less than 4 digits, is a neat trick
Why, would it be under FAA so more expensive? Are you talking Part 145 (maintenance) or Part 21 (new manufactured)? I don’t think that this is true. For example for this Sandel, any company with correct rating (FAA or EASA) and the correct manual could perform this work.
Peter wrote:
when the EASA-1 is FAA-accepted in place of the 8130-3
Only for new parts (Part 21), or when this EASA Form 1 is a dual release, which requires the Part 145 organisation to hold an EASA Part 145 and FAA Part 145. An EASA Part 145 company without FAA validation can not generate a dual release. A dual release statement is required.
In your example there is a dual release statement in block 12.
Peter wrote:
Few people will read what the EASA-1 actually says.
While this could be a valid statement, it doesn’t make any difference.
Peter wrote:
the bench test in Europe is IMHO highly unlikely to test all physical interfaces, never mind testing relevant areas of the functionality to check out various modules inside the unit
That is an invalid statement. A bench test in Europe is the same as the a bench test in USA when carried out according the same manual. In your example the bench test was performed (according the EASA Form 1) in accordance with the applicable Sandel maitenance manual.
Sandel in this approved maintenance manual will determine what has to be done. What interfaces are tested is not upto the maintenance organisation. They just have to follow their instructions. If they required to test certain Arinc 429 labels for example, the maintenance organisation will generate these labels, and see the required outcome.
As such it doesn’t matter if you have an FAA 8130-3 which says inspected/test according this manual from Sandel or any other American aviation shop, or an EASA shop. They will all perform the same work.
Peter wrote:
a Yellow Tag is worth whatever is written on it – same as an EASA-1 form It may say “working when removed” which is probably the same as an EASA-1 saying “working on the bench”.
Please stop with posting these incorrect statement on EASA. I spend a lot of time, to educate you, and other readers on this forum, on the differences and equalaties. So do others involved in maintenance. These statements degrade the value of your other excellent forum. You harm our European aviation industry with these kind of comments.
Peter wrote:
traceability is only achieved after the EASA-1 (or the 8130-3) was generated, and is valid only for serial numbered items.
What I was getting at is
Few people will read what the EASA-1 actually says.
It may say “working when removed” which is probably the same as an EASA-1 saying “working on the bench”.Peter wrote:
The EASA-1 form is just traceability after it was typed-up.
That is only for non serialised parts (for which a EASA Form 1 or 8130-3 is a bit of strange, suchs as with the P clips you refered to).
For serialized items you need (some) history. Often, though not always this could be history back to birth. Especially for engine components etc. However for radio’s this would also be possible, when the 8130-3 from new (years ago) is still available as well.
Apart from that, there is no difference beteen an 8130-3 saying inspected / tested accoring to this manual or an EASA Form 1 which says inspected / tested according the same manual.
Peter wrote:
pretty obviously an EASA-1 saying “we bench tested it” is just a Yellow Tag saying “worked when looked at”.
Ok we learned from Michael that the yellow tag doesn’t have any value. The EASA Form 1 does. A bench test is more detailed than an on aircraft test. And the on aircraft test is more then worked when looked at.
During a test worked when looked at:
You might perform an operational check, or see that it powers up and use build in test functions to see if it functions. You can only test features that are installed
During a ramp test or on aircraft test:
You perform the test when looked at using test equipment. This would also give you the possibility to measure receiver sensitivity for example, and also performing testing to see that failure detection works. Example could be flag circuits. You would measure transmitter frequencies and modulation. You can only test features that are installed.
During a bench test:
You typically test power supply voltages, signal levels, simulate all kinds of incomming signals (RF, analog / digital (ARINC429 / RS-232)), pulse width, analyze signal outputs etc.
So with this EHSI you would be generating and analysing ARINC signals as well during a bench test. You wouldn’t do that during ramp test. In this case the work has been done is a bench test. So it is important to understand what work has been done, as both could have an EASA Form 1 (or 8130-3) stating inspected / tested. Both would be legal, though the work accomplished is different.
The same is true for overhauls. As indicated before there are other approved overhaul procedures. So one overhaul of one company could have many replacement parts, while the overhaul at another company re-uses good parts, which generally lowers the price of overhaul. This is perfectly legal on both EASA and FAA, though the customer doesn’t get the same product even though both come with an form stating overhauled.
Gentleman, for the record: Please banish the term “Yellow tag” as it means absolutely nothing and thus can have several different meaning to several different people.
In FAA parlance, it’s a Form 8130-3 or it is not, period.
I know, which is why I have two of them, plus the SG102 AHRS. Very high grade stuff.
If it says it was removed serviceable from an aircraft, it is basically the same as a yellow tag with tracebility
Where does the traceability derive from? This belongs into the other thread but the 145 company (FAA or EASA) doesn’t know whether it is a genuine part. OK; one could not build a fake SN3500 but pretty obviously an EASA-1 saying “we bench tested it” is just a Yellow Tag saying “worked when looked at”.
But a Yellow Tag is not an 8130-3
The EASA-1 form is just traceability after it was typed-up. Whereas an 8130-3 from Sandel means they put it through their factory test, etc. But an 8130-3 from Sandel is going to cost you 4 figures, due to the work they will do to bring it to current spec… But the EASA-1 form is accepted to FAA equally to an 8130-3.
We installed 93 SN3500s just a few years ago in Grob 115s for the RAF. We recently certified an installation and supplied them for the British Army Gazelle helicopter fleet using the NVG version, coupled to a Garmin GTN and GTS. These units may be less popular in GA but certainly have a viable market in military platforms,
Peter wrote:
So….. what does such a Form 1 mean, really?
It depend on what it says. If it says it was removed serviceable from an aircraft, it is basically the same as a yellow tag with tracebility. It always will say according what procedure or manual the work has been accomplished. In this case the work was done according the final test procedure of the Sandel Maintenance manual.
With overhaul, for example, it says which overhaul was done, according manufacturer, or using alternative (approved) procedures. This is why you sometimes see big differences in OH pricing. So for an electric pump the OH could be cleaning + lubricating + testing according an approved procedure, or cleaning, renewing bearings, renew rotor + testing according manufacturer instructions.
This is the same or very similair for FAA and EASA.
So….. what does such a Form 1 mean, really?
It appears to say “working on the bench” because they could not possibly have tested every possible feature documented in the IM. Probably not even tested every possible interface. You would need quite a rig for such a test. A complicated ARINC429 test harness.
The SN3500 is not a product that’s been popular in GA for years. One UK dealer sold his demo unit and stand a few years ago. Nobody installs them now in piston GA.
Peter wrote:
OK; thanks all. Sandel told me that an 8130-3 cannot be issued by anybody but them, for new or used.
One can even issue an EASA Form 1, when it is tested before removal accoring MPS / e.g. no bench test / manufacturer manuals.
Many Part 145 shops have a procedure to do this as EASA has a provision for this.
OK; thanks all. Sandel told me that an 8130-3 cannot be issued by anybody but them, for new or used.
