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Implication of ELA1 for ownership

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Administrator
Shoreham EGKA, United Kingdom

Is there any more background to this other than a PowerPoint presentation? Thank you!

always learning
LO__, Austria

Digging up this old thread, I believe above is the first time the “dynamite clause” had come to light.

It then got forgotten – probably because almost nobody was able to get it past their maintenance company

Basically it means that you can buy parts from e.g. Ebay, for installation in a certified EASA aircraft.

Administrator
Shoreham EGKA, United Kingdom

It may be interesting to have a website where airframe p/n can be looked up and matched to alternative parts, in a ‘community’ sort of effort. .

These exist but aren’t properly concentrated.

For example I have some bits here – mostly specific to the TB20.

The Socata owners’ site also contains a partial database of small parts like seals but the site owner rigged it so it cannot be dumped whole; you have to search for one at a time by keywords. My guess is that he doesn’t want to upset Socata (he also runs the TBM owners’ site).

I don’t know if the Beech, Cessna, Cirrus etc communities have done this sort of thing.

Buying at trade and selling at retail is an important source of income and this is now being jeopardized.

Indeed, and it leads to owners supplying the maintenance shop with free issue parts which the shop obviously dislikes totally.

Administrator
Shoreham EGKA, United Kingdom

I suspect a liberal interruption of the parts would be reasonable given the intention of the act. Howsoever, what will the dealers ‘genuinely’ think about this? Do they REALLY want 10% margin on a €200 part vs €1500 part. I suspect not. Buying at trade and selling at retail is an important source of income and this is now being jeopardized.

It may be interesting to have a website where airframe p/n can be looked up and matched to alternative parts, in a ‘community’ sort of effort. .

Lifed parts are listed in the TCDS. There will not be very many for the GA fleet in ELA1 or 2.

There is no mention of “critical parts” in the legislation relating to this discussion

Aart

It is already in effect since 3 Aug 2012. Link

In my view (which as always could be wrong) your service centre maybe partly right on the serial number point, but I bet for the wrong reason. Advise leaving them well alone!

More seriously, EASA maintenance is in my opinion badly written, especially given the target audience being a mechanic in a hangar, leading to an overly onerous interpretation.

I don’t see anything that requires a CofC

I agree, but I would expect that to be implicit otherwise you have (in theory) no way of supporting your view that it isn’t a fake part. (The fact that a CofC is not worth more than the laser printer toner is one of many aviation charades).

There is also a long standing tradition to get a “release” (a CofC) for stuff like avionics wire, which almost nobody would bother trying to buy with a Form 1.

UK law is very much of the form “if it doesn’t say you can’t, you can”

It has to be that way everywhere, otherwise life would grind to a halt pretty fast

They already are allowed to use parts without Form-1 as long as the parts do not have a serial number.

That is imaginative (and wholly pragmatic because parts without a S/N can be changed anytime and so long as it isn’t a lifed part nobody can tell if the work was not recorded) but how is that view supported? In certification terms the lack of a S/N means nothing. Instead you have a batch number which appears on the original 8130-3 or EASA-1 and this is carried through to every job sheet on which the part is used. So really the lack of a S/N merely facilitates work which is supposed to be recorded but in reality is being done off the books

In the presentation I see a picture of hoses for instance that qualify, I’d say that this is a critical part.

So would I. That’s even more amazing – a huge saving is possible there, but to be fair anybody bothering to dig out the P/N can immediately save 50% on metric (ISO thread) hoses by buying them from an Eaton dealer like Saywells and they will give you an EASA-1 anyway.

The industry will try to frustrate this e.g. within the Eaton world the only firm which does the metric fittings is Aeroquip in (you’ve guessed it) France and when they see a hose order like that they will try to piss you off by sticking a 16 week lead time on it. So you need to plan ahead and if possible sweeten the job by buying several for your mates.

Last Edited by Peter at 10 Jun 19:14
Administrator
Shoreham EGKA, United Kingdom

Quick reply from my service center:
1. They look forward to this rule to come into effect, but seeing is believing..
2. They already are allowed to use parts without Form-1 as long as the parts do not have a serial number.

Private field, Mallorca, Spain

My view, yet to be put to the test, is that this legislation also allows the owner to authorise the fitment of used parts and also US-overhauled parts, both without Form 1.

The original NPA is worth seeking out as I believe it represents the intention of this ruling. There was some interesting stuff about copying and making minor parts like brackets. Some of the preamble spoke about needing to relax control over certain areas, so I expect that issues of burden of proof will be unlikely.

Peter – I don’t see anything that requires a CofC

(As an aside, UK law is very much of the form “if it doesn’t say you can’t, you can”)

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