Dear all, my first post here. I am doing pilot-owner maintenance on my small but certified single engine piston. For that I am seeking some clarification about the recent EASA certification memorandum for installation of parts without EASA form 1. Most conditions are clear. My main question is how to obtain the necessary conformity declaration. The rules say:
21.A.307(c) Parts and appliances listed in point (b) are eligible for installation in a type-certified product without being accompanied by an EASA Form 1, provided that the installer holds a document issued by the person or organisation that manufactured the part or appliance, which declares the name of the part or appliance, the part number, and the conformity of the part or appliance with its design data, and which contains the issuance date.
An example. I would be perfectly okay with a motor cycle battery. AGM batteries are safe for use in any ELA1 aircraft and I would be happy to accept such a part. However there is no battery manufacturer issuing such a document. Would a battery data sheet issued by the manufacturer be sufficient? And what about the issuance date….Maybe I am expecting too much from such a document.
Just for clarity, this is for an ELA1 aircraft that only I fly, only for VFR flights and only during UDP.
Many thanks!
McPike wrote:
21.A.307(c) Parts and appliances listed in point (b) are eligible for installation in a type-certified product without being accompanied by an EASA Form 1, provided that the installer holds a document issued by the person or organisation that manufactured the part or appliance, which declares the name of the part or appliance, the part number, and the conformity of the part or appliance with its design data, and which contains the issuance date.
This provision was introduced with a change to part-21 a year or two ago.
An example. I would be perfectly okay with a motor cycle battery. AGM batteries are safe for use in any ELA1 aircraft and I would be happy to accept such a part. However there is no battery manufacturer issuing such a document. Would a battery data sheet issued by the manufacturer be sufficient? And what about the issuance date….Maybe I am expecting too much from such a document.
That’s a very good question. From extensive past discussions on the matter here, it seems that no one really knows the answer but that it probably is “no”.
@McPike, no, you cannot use this provision to install an unapproved battery because of the requirement in 21.A.307(b)(2)(ii): the part has to be identified for installation in the specific aircraft – that is, mentioned in the instructions for continuing airworthiness (illustrated parts catalog, maintenance manual, etc.) issued by the design approval holder. For details, see CM-21.A-K-001. On the other hand, regarding batteries specifically, I am hoping for some concessions in a future issue of CS-STAN.
In real life, quite a few people fly with unapproved batteries.
the part has to be identified for installation in the specific aircraft
That clause buggers that entire concession, if the “wrong person” is looking at it.
Many thanks for the replies. I see that this topic is already covered in another thread (link by Airborne_Again) and I looked at the previous discussions. Unfortunately the relaxation of the rules for ELA aircraft EASA is trying to achieve is made impractical (or just impossible) by the ICA specification and compliance documentation requirements.
Many thanks!
Yes, @Ultranomad ’s reference is the concession-crippling amendment that @Peter was referring to
