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Replication of a component no longer made, under EASA regs - how?

Let’s say you need a control linkage component, say something like this

and it either isn’t made anymore or the manufacturer wants €10,000 for it.

Is there a legal route for fabricating it?

I imagine it may differ for critical versus noncritical parts, with say a door handle being the latter.

Let’s assume that it is trivial to copy it by visual inspection. So we are not talking about copying an autopilot computer

Under N-reg, the owner manufactured parts concession would cover it, as one approach. Another would be the generic repair manual AC43-13.

Administrator
Shoreham EGKA, United Kingdom

Under EASA, there are essentially three methods to make the part:
1. Production by an EASA Part 21G using the original approved design data. There must be a POA/DOA agreement in place between the design organisation and the production organisation. Doubtful that many OEMs would provide the design data in this case.
2. Fabrication under Part 145 privileges. Still requires approved design data – not able to just copy from an old part, so as above, somewhat difficult if you can’t access the design data.
3. A Part 21J designs and approves an alternative item (just happens to be identical to the original) and then either a Part 21G or a Part 145 make it.

Avionics geek.
Somewhere remote in Devon, UK.

Thanks, wigglyamp. I think you provided a similar answer for that fuel sensor signal conditioner, but I wondered if a simple mechanical item might be easier.

I can’t really see anybody following any of these procedures…

Is there any concession for a non critical part e.g. a door handle?

Or, on a similar tack, replacing say a TB20 door support gas strut (made by Stabilus but made for Socata with a customised end fitting) with a part of an identical spec?

Isn’t there a provision for manufacturing a replacement which contains some (tiny) part of the old item and is thus called a “repair”? That is widely one under the FAA system, and is pretty well universal in the exhaust and engine mount business. I am pretty sure it is widely done for EASA aircraft too.

Administrator
Shoreham EGKA, United Kingdom

What goes on in reality is a different story (I’ve even seen car parts fitted to certified aircraft) but the three methods shown above are the only legitimate ways I’m aware of for dealing with production of replacement parts and having legally traceable paperwork.

Avionics geek.
Somewhere remote in Devon, UK.

For an ELA2 aircraft (aeroplane < 2000 kg) you can make or supply a part yourself under certain conditions:

21.A.307 Release of parts and appliances for installation
A part or appliance shall be eligible for installation in a type-certificated product when it is in a condition for safe operation, and it is:
(a) accompanied by an authorised release certificate (EASA Form 1), certifying that the item was manufactured in conformity to approved design data and is marked in accordance with Subpart Q; or
(b) a standard part; or
(c) in the case of ELA1 or ELA2 aircraft, a part or appliance that is:
1. not life-limited, nor part of the primary structure, nor part of the flight controls;
2. manufactured in conformity to applicable design;
3. marked in accordance with Subpart Q;
4. identified for installation in the specific aircraft;
5. to be installed in an aircraft for which the owner has verified compliance with the conditions 1 through 4 and has accepted responsibility for this compliance

But that wouldn’t work for the control linkage, because of condition (1).

How would 2. (manufactured in conformity to applicable design) be achieved?

Otherwise, I am amazed how posts 2 and 5 can be so different.

Administrator
Shoreham EGKA, United Kingdom

What goes on in reality is a different story (I’ve even seen car parts fitted to certified aircraft) but the three methods shown above are the only legitimate ways I’m aware of for dealing with production of replacement parts and having legally traceable paperwork.

As far as I know (i.e. from mechanically able friends, not checked myself), the whole Robin series is full of French car parts.
Pointed out to me recently, e.g. engines driving flaps come from from Renault side-windows…

So what is the problem with car parts ?
:-)

Last Edited by ch.ess at 08 Aug 14:40
...
EDM_, Germany

ch.ess wrote:

the whole Robin series is full of French car parts

It’s not the only one. I’m almost certain the Auster’s parking brake lever is off a 1930s BSA Scout or similar, and the original dynamo was probably a tractor part. The stick grip on old Slingsby gliders look like they came off a Raleigh bicycle of a similar vintage…

Last Edited by alioth at 08 Aug 15:01
Andreas IOM

Peter wrote:

How would 2. (manufactured in conformity to applicable design) be achieved?

The CM gives more info.

2. Manufactured in conformity with the applicable design
There are basically two ways to establish that a part without an EASA Form 1 but intended
for ELA use conforms with applicable design data.
First, by obtaining a part directly from the original source/Original Equipment Manufacturer
(OEM) (which may be a non-aviation vendor) as identified by part number and/or vendor
code in the product support documentation (such as the Illustrated Parts Catalogue (IPC),
Component Maintenance Manual (CMM) or in a Service Bulletin (SB).)
Secondly, in the case of parts where all of the data necessary for manufacture and
subsequent inspection to determine the quality of the parts is available in the product
support documentation or other data provided by the design approval holder, then such
parts may be produced or fabricated in conformity with the applicable design data.
Note: It is important to realise that the acceptance of parts and appliances without an EASA
Form 1 by no means is a way of making or accepting changes to the applicable
design.
Where the owner is unable to obtain the approved data for the part, then the owner should
consult the design approval holder or an organisation approved in accordance with EASA
Airworthiness regulations as identified in Para 3.3 (1) of this Certification Memorandum.

This is brilliant stuff, bookworm!

It basically means you can use OEM parts on ELA2, provided they are definitely identified as the same part. That makes perfect sense, since the 145 certification on such parts doesn’t achieve anything.

That concession was introduced years ago in the FAA system for electronic components, to avoid the scam of having to buy a 10k 1/4 watt resistor from Honeywell. I don’t think EASA ever had it – till now.

Administrator
Shoreham EGKA, United Kingdom
11 Posts
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