I believe the answer is NO. Same as one cannot install a used part with an 8130-3 onto an EASA-reg.
This has caught out some people who got their engines overhauled in the USA, by a shop which didn’t have EASA145 and thus could not generate an EASA-1 form, and who were unable to install the engine (their own engine!) on their G-reg aircraft. The solution for using such a shop was to get an FAA DAR to generate an Export CofA for the engine. This used to cost about $300. (Same for a propeller, incidentally). But I heard that the Export CofA form no longer exists… another story.
Back to my question: For an N-reg, an A&P does have the authority to inspect a component and declare it airworthy. This is obviously easy with a metal bracket, but what about a propeller or even an engine? Doesn’t he have to dismantle such parts?
And what evidence does the A&P need of where the part came from?
Does an EASA-1 form carry any weight in such a case?
Assuming it’s not an instrument, turbocharged engine or etc that requires repair station paperwork, an A&P can install the part on an N-register plane by reviewing background, and inspecting the part to his own satisfaction. There is no requirement for documentation to back up his determination, and a logbook entry by the A&P makes it legal.
For example, an A&P friend has a hangar filled with parts, propellers etc and uses them on his own plane as he sees fit… and occasionally on mine too. Sometimes he needs a climb prop, sometimes a cruise prop…
An engine of vague origin that was sitting on the shelf for a decade or two got installed on another friends plane for a few months while his engine was being overhauled. It’s back on the shelf now.
The exaggerated regulatory authority that some think exists with respect to certified aircraft does not actually exist for N-registered light aircraft. What prevents issues is (1) fault tolerant design, particularly at the lighter end of the aircraft spectrum and (2) people looking out for themselves, and recognizing that they can’t do dumb things and get away with it, particularly with heavier more complex aircraft.
My shop was satisfied with the 8130 issued by Honeywell, after the check-up of the used TAS I bought.
They told me it had the same value as a EASA form 1 dual release.
(my plane is F-reg).
However, an 8130-3 from Honeywell would have the EASA 145 approval number on it, because Honeywell is an EASA145 company as well. So that would be as good as an 8130-3.
Is there an “EASA 1 dual release” form?
We did this when the Commander elevator spar issue grounded us. We were lucky enough to be loaned an elevator from a G reg aeroplane. This was issued with a Form 1, which I guess was good enough reason to believe the part was ok, and was subsequently fitted to our aeroplane (N reg).
At the time, I was worried about not finding the Form 1.
The person from Apple Heli answered in those terms:
“I had asked them to issue a Form 1, but they have issued it with an FAA 8130-3. However, it will be acceptable as it has EASA Dual Release. This is very common when US companies certify parts.”
However Peter must be right about the Honeywell EASA approval.
Unfortunately, I gave the certificate to the shop at the time and didn’t keep a copy for sharing.
Regards.
Peter wrote:
For an N-reg, an A&P does have the authority to inspect a component and declare it airworthy.
Not only would the A&P be declaring the component airworthy, but the aircraft that he bolted it on as well !
On a slightly different angle :
I am SHOCKED by the number of EASA shops that wrench on FAA registered planes despite that no A&P is either on the staff or even within shouting distance …
Owner/operators MUST UNDERSTAND that the second a non FAA certified mechanic and/or shop so much as changes a screw, that aircraft is now considered UN-AIRWORTHY until a FAA certified A&P either signs off the work in question, OR signs off the next Annual or 100H Inspection.
It seems that the general consensus here in Europe is that the shops can do all the routine maintenance they want (sans FAA certification) with exception to 100 hour and Annual Inspections – WRONG !
Michael wrote:
It seems that the general consensus here in Europe is that the shops can do all the routine maintenance they want (sans FAA certification) with exception to 100 hour and Annual Inspections – WRONG !
Not wrong. They all have have their FAA IA who signs off on the work. Even under FAA, you can have a monkey do the service as long as somebody with the right credentials signs off on it. Under FAA, it is very common for every mechanic working on airplanes to have an A&P. Under EASA this is very uncommon, I’d say 80% of the airplane mechanics are car mechanics (or tractor mechanics, that is actually the better qualification). You only need one guy in the office to produce the paper and the shed where the tractor mechanics work needs to be declared Part 145 premises.
I know that a lot of those visiting IA arrangements in Europe do not necessarily entail a visit. That’s the dirty little secret of N-reg in Europe…
PS: If I fly to the US with my EASA-reg and I need a new battery (my maintenance program does not allow me as owner to replace the battery for whatever reason). Would I be thankful to the FAA repair station that just did it, without caring about release to service blabla? Yes, I would.
For what my view is worth, I agree with you Michael, but this bit
Not only would the A&P be declaring the component airworthy, but the aircraft that he bolted it on as well !
is a bit more complicated, wouldn’t you say?
For a start, it must depend on whether the non-conformity was readily detectable when working within the scope of what the A&P was doing on that particular job. So if e.g. the A&P was changing an engine, a missing air filter element would have been, ahem, fairly detectable. But should he notice an ELT battery which is out of time? IMHO, no. The IA signing off the Annual is going to go down for that one!
Otherwise, every A&P in the universe would have been busted for ever. There is not a single aircraft flying, not even a single one departing LHR or LGW today, that is 100% airworthy.
You only need one guy in the office to produce the paper and the shed where the tractor mechanics work needs to be declared Part 145 premises.
That works only if the FAA145 approval includes the specific aircraft type. Usually it doesn’t, because it’s too much bother. Most European FAA145 companies do GA Annuals via the IA signoff route. The 145 shop I was hangared at for 13 years never had a TB20 on its 145 approval. Had I used them for maintenance (which I didn’t, for obvious “over the barrel” reasons) they would have got a freelance IA in for it.
I know that a lot of those visiting IA arrangements in Europe do not necessarily entail a visit. That’s the dirty little secret of N-reg in Europe…
You can do dirty work on any reg. But I personally know an IA who has been busted for life for doing that. (He is still an A&P and EASA66 and Part M). And anybody doing it frequently will eventually get busted because all it takes is for the plane to be sold and for the buyer to find something which was obviously nonconforming at the signoff date. The buyer has a 100% incentive to drop everybody in the world in the sh*t at that point, because he is angry, wants revenge, and has nothing to lose. When I was going G to N some paperwork discrepancies were found by the DAR (a GPS antenna installed without paperwork) and you should see how quickly the FAA145 company which did it was on the road and down there.
So my experience, N-reg for 10 years, is the opposite of what you report from Germany. Most IAs are very nervous and run a mile if they smell something dodgy. Especially if they are freelancing from a day job which pays their mortgage.
The other angle here is that if an IA sees an aircraft for the first time, why is he seeing it for the first time? It could be for a genuine reason or it could be because the previous one would not sign something off? Same with EASA to N-reg transfers… you will get a lot of wreckage which the owner thinks (having been reading pilot forums 
) can go N-reg easily…
Personally, if I was going to do dirty work I would do it on the G-reg because the CAA never does ramp checks, and even known-bad companies don’t get busted.
Would I be thankful to the FAA repair station that just did it, without caring about release to service blabla? Yes, I would.
Of course But that’s not the same thing as doing stuff that is traceable and likely to land some person in the ****
Peter
I don’t know what the regs says but can tell my own experience.
The shop that maintained my aircraft (N reg) advised me that there is a need for a new control cable to the elevator and asked me to source it (as the aircraft is not supported anymore). I have searched any known source but could not find any that will come with 8130. The reason is authorizations and that in the US any AP can produce a cable and install it on any aircraft, however, I found a shop in Germany that could produced a cable and provide EASA documents (EASA equivalent of the 8130-3) , the shop rejected it saying that they can’t use it on N reg aircraft. Therefore I believe that the answer to your question is that a used part also can’t be fitted. Saying this, once I read somewhere that if you are stuck at the back and beyond in a place with no FAA certified mechanics and parts the FAA will allow local licensed engineers and parts.
