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Revalidation of used parts e.g. removed from other aircraft

Maybe a strange question, but in my younger days, I used to improve my car by (e.g.) exchanging the cloth interior with the leather interior from a car that had been written off.

Now let’s assume there’s a plane that suffered from a heavy landing somewhere which is beyond economical repair but has a nice leather upholstery which looks significantly better than the current seats in my plane – how is the best way to go about having these seats (all original) validated in order to install them without any issues at annual? Any ideas?

When the aircraft is dismanteld by a Part 145 organisation, they can, if they have a procedure for this, remove and inspect the part, and issue an EASA Form 1 for the used parts. To be able to use this, the parts should be removed and tested by a Part 145 organisation and kept under their control the whole time from removal, storage upto issuing the Form 1.

You should check the P/N’s to be correct for your aircraft as well.

JP-Avionics
EHMZ

With a G-reg, it depends on who you talk to. I spoke to an owner of a EASA145 + FAA145 company about this. He said the parts could be removed from another G-reg provided it had a valid CofA at the time and simply transferred with a logbook entry (no 145 company involvement). I asked him: what about if the donor aircraft has been crashed? Obviously the CofA is not valid post-crash He just laughed and said it had to have a valid CofA before the crash. But stuff like NDT would be (obviously) needed on some items.

So, yeah, there are different views within the industry. In the UK it seems normal to transfer parts from a [crashed or not] G-reg to a G-reg. The EASA-1 form is needed for traceability, so if the donor aircraft is not “around”, most companies will not touch the part unless it has the form.

On an N-reg, AIUI, an A&P has the authority to inspect the parts and declare them airworthy, again subject to the donor aircraft being “around”. If you are parting out a crashed aircraft and want to freely sell the parts, you will probably need to tag them as “serviceable when removed” to sell them easily. Especially if selling them on Ebay (as I have often done, though not from a crashed plane ).

A couple of relevant threads here and here

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

On an N-reg, AIUI, an A&P has the authority to inspect the parts and declare them airworthy, again subject to the donor aircraft being “around"

All you need for an N-registered plane is a logbook entry from an A&P saying “removed widget PN 12345, installed used serviceable widget”. What aircraft they came from is not a part of that logbook entry and no other paperwork or certification is required. It’s done every day, some certified types cannot be maintained any other way, and nobody I know in the US would understand the meaning of “revalidation” in this context.

Last Edited by Silvaire at 27 Dec 08:09

Peter wrote:

So, yeah, there are different views within the industry.

That might be from post EASA, or within the same company. This is clearly laid out in EASA regulations. If the same company removes a part, and reinstalls it on another you don’t need an EASA Form 1. If someone else, or another company wants to install something, then it needs and EASA Form 1. With time limit parts (magneto’s / engine etc) you would also need the history of this part. Pre EASA, at least in the Netherlands, as servicebilty label was sufficient.

So yes, here is a difference between EASA / FAA. I think this will also change in future for lighter aircraft, to become similair like FAA. Though I expect for items as magneto’s and engines that they would keep EASA Form 1.

Silvaire wrote:

I know in the US would understand the meaning of “revalidation” in this context.

EASA + FAA licensed companies can only issue single release (pure) EASA Form 1. A dual release is not allowed in these cases. So an EASA+FAA company can not always issue a dual release.

FAA + EASA can not always give an dual release either. For example when they do maintance with parts which are FAA acceptable but not acceptable to EASA, then they can release that product only with an 8130. Not with a dual release 8130.

JP-Avionics
EHMZ

Peter said: “With a G-reg, it depends on who you talk to.”

If it’s an EASA aircraft, then MA613 applies to all countries, so please don’t single out the UK again as being the bad apple! It’s apparent that many people across Europe either don’t know or fail to follow the rules, but they are available for everyone to read.
You can buy second-hand parts on the open market that come with an FAA 8130-3 from US companies and they are delivered in un-cleaned as-removed condition, so certainly haven’t been subject to detailed inspection or undergone tests to determine serviceabilty, yet a DAR has signed the release certificate. If this wasn’t happening then the problem of bogus parts wouldn’t exist, particularly in the helicopter market.

Under Part M, there are specific procedures to apply if the recovered parts which are to be declared serviceable are being removed from an aircraft involved in an accident/incident (heavy landing etc) to ensure there is no hidden damage due to excessive stress, shock loads and such like. If I was buying seats the I would want to be sure of their history so they don,t fail if I have an accident.

Last Edited by wigglyamp at 27 Dec 10:37
Avionics geek.
Fairoaks. EGTF

You can buy second-hand parts on the open market that come with an FAA 8130-3 from US companies and they are delivered in un-cleaned as-removed condition, so certainly haven’t been subject to detailed inspection or undergone tests to determine serviceabilty, yet a DAR has signed the release certificate. If this wasn’t happening then the problem of bogus parts wouldn’t exist, particularly in the helicopter market.

I think it is quite a stretch to say that an uncleaned part with an 8130-3 is a fake/forged part. A fake/forged part will be spotless, with a spotless 8130-3 or EASA-1 form.

Let’s face it, the documentation is often unverifiable… a while ago I bought some parts from a top UK 145 distributor including a £3 P-clip and when examining the sheaf of oil-stained documents accompanying it, it turned out to have been made in 1968 and had worked its way around the stores of several long-defunct airlines! Enquiries revealed this practice is commonplace and results from the tight certification regime under which nobody has the authority to question the status of an item which has the right paperwork. In avionics particularly, the situation is compounded by a common disreputable practice: most manufacturers will fight till death to avoid replacing an instrument returned to them with a defect which does not show up in their prescribed bench tests – regardless of how much evidence of the fault (photographic, engineer/witness statements, etc) is presented to them. One incident which wigglyamp might recall involved Honeywell not accepting a KC225 computer with an intermittently duff display (and perfect paperwork from Honeywell’s overhaul a few years previously) despite me having photographic evidence of the problem. Due to the high value of the item I pushed very hard and a contact at Honeywell HQ in Prague did enable it to be repaired but that was my “friend capital” spent and he never talked to me again…

Also documentation is utterly meaningless for any part which doesn’t have a serial number I could type up some interesting examples, rather close to home (a UK mag overhaul). Like an 8130-3 which was just a photocopy of one for another part of the same type… a form for a spring or such is a complete charade. And this sort of charade is almost impossible to audit… the only way would be to visit the vendor and check that the sum total of the quantities on the various forms they sent out matches the quantity on the form which accompanied the batch they bought in, but how do you do this for slow moving stock which never reached zero over many years yet had many in and out transactions?

Also the vast majority of aircraft parts don’t need cleaning in order to be inspected. The ones which need cleaning would be e.g. ones possibly damaged in a crash (etc) i.e. NDTd.

Obviously I will again be accused of being negative about the certification system here.

Ultimately the issue is vesting trust in organisations and organisational approvals. This in turn generates a system where paperwork=good means part=good. Same as ISO9000….

Administrator
Shoreham EGKA, United Kingdom

The most important part of this is that the recipient of the recovered parts has confidence that the parts are from a genuine source, the parts have no hidden damage because of previous crash history etc and hopefully the required paperwork correctly reflects the condition.

Avionics geek.
Fairoaks. EGTF

wigglyamp wrote:

It’s apparent that many people across Europe either don’t know or fail to follow the rules, but they are available for everyone to read.

That is true, but part-M is easily the most obfuscated set of rules I have ever seen. It is like it has deliberately been written to be difficult to understand.

ESKC (Uppsala/Sundbro), Sweden

As if that wasn’t a big enough can of worms, the situation as I am facing it:

A fellow Cirrus pilot doesn’t like his current leather seats – don’t ask me why, he just doesn’t. I on the other hand hate my original tatty cloth / leather seats. My friend sees a crashed G3 Cirrus, has the seats removed from them and buys them complete with Form 1. He takes said original seats out and fits the new seats himself to his plane. His original, uncrashed and airworthy seats are now up for sale.

Am I right in saying the only way I can legally fit them to my plane is by getting him to refit those seats to his plane, get him to fly to a Part 145 organisation, have them remove them, inspect them and issue the Form 1?

To clarify: The aircraft from which I could get the seats IS still airworthy, EASA registered and has never been crashed. The serial numbers match. And as I said, his aircraft now sports G3 seats. Where the numbers don’t match but he has the form 1….. ;)

Next time, I think I’ll just strip the interior from a Ghia and put into a lowly Cortina Mk IV L, lot less hassle ;-)

Last Edited by Steve6443 at 27 Dec 17:28
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