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

Peter wrote:

Funnily enough the one time I found it very hard to get a part from my plane was during the D3000 magneto problems (most but not all parts in these are made under PMA and when Bendix dropped the product line a lot of parts were hard to get) and the only contact who had a particular part was a certain UK FAA+EASA 145 company “with a reputation”. I got them to overhaul the mag (a spare one, fortunately) but when I asked them for a copy of the work pack they went into a really obvious stonewalling/whitewashing mode.

It is the FAA form which is sufficient. They have to have the work package for auditing. Most forms for parts will stay in their system, and not all forms are included at the actual printed work order, a reference to them is sufficient.

Peter wrote:

I reported this to the CAA who weren’t interested… It became pretty obvious that at least one “new” item was a secondhand one and the 8130-3 was just a copy of another one.

Why weren’t they interested? They might be doing everything according regulations. For example, remember this post a while ago, on an American FAA+EASA overhaul company which made their own procedures. There are lots of these, especially on FAA, which also skip some items which manufacturers consider mandatory. So they would do what they think is ok, and got that procedure approved. This is where these huge price differences will show up. You can not compare overhauls if you don’t know according what procedure they are carried out.
It would be possible that using their approval they could legally reuse parts, which can not be reused when using the manufacturer overhaul instructions.

JP-Avionics
EHMZ

will ground your plane because your Part M company will not release to service until they get that exact part with an EASA-1 form.
Peter, I think your forum is great, but you put on so much incorrect information related to EASA, mechnics and companies, “proving” that the FAA system is better. With the power you have as forum leader, you put every EASA company in a bad daylight. That is not fair.

It’s a fair point that as an admin/mod I need to be more careful what I say, but I have loads of stories received privately which are exactly what I said.

The problem is that I cannot quote them! I sometimes refer to something, in oblique terms so as to not cause the person trouble…

This is a big problem in GA. Lots of stuff cannot be discussed openly because of some “private reason”. Usually it is a dealer relationship preservation issue, or an aircraft value preservation due to a planned sale.

And one thing which really immensely pi*sses me off is when somebody emails me a story or stories (about their plane, or something more general) and some weeks or months or years later criticises me viciously for posting something on that topic. It could be a story about a maintenance company… or something more general.

You would not believe what I get to hear, by email. Grounded planes due to a part with no paperwork? Common as muck! One guy’s plane was grounded for months because a relay was not available with an EASA-1 form. He had some, source proven, mfg paperwork, and 100% deffo not counterfeit, but his company would not touch them.

I don’t write bullsh*it knowingly. (I also try hard to not write something disingenuous or missing vital / relevant info; plenty of that gets written already, especially in one-liner posts). But as I say I often cannot support what I say with a specific example because of what somebody told me confidentially.

The alternative to having me is a mod who is hidden, but you will get only a pervert to do that job, unpaid. We have had various mod-related discussions before e.g. here. One approach is to have covert mods (participating pilots with covert mod privileges) which is how one big (non UK) site does it, and you do need somebody to keep an eye on a site regularly in case of outright illegal stuff being posted, but that method is obviously dishonest because modding takes place without accountability (big sites have to do that but we are not big enough). However, if you want to run a site which creates an illusion of free speech (an important issue in some European countries whose recent history makes this a hot topic; no coincidence that two people who angrily left did so over demands for unrestricted “free speech” and both come from the same place) then that is what you have to do (let people have a good fight, etc). I am always happy to discuss mod policy etc and you will find many past threads but there are no easy solutions. I know you Jesse did not talk about mod policy (rather about mod participation) but the two are connected.

Why weren’t they interested?

IMHO because they are very careful to not shut down companies, because a 145 company with various approvals might be paying them ~ 20k/year in fees.

In the UK there have been many cases of this, some quite blatent.

It is the result of the fee system. In the FAA world you don’t have this conflict of interest. Funnily enough it was the FAA who shut down that UK company’s 145 prop operation (fake paperwork involved, building props out of condemned parts).

Administrator
Shoreham EGKA, United Kingdom

Jesse wrote:

While I think you could do this on some parts, I am quite sure you can not do this on prop, instruments (altimeter?) or radio’s for example. @Michael, could you comment on this one?

An FAA A&P cannot intervene (work on) Instruments or Props .

FAA A&P/IA
LFPN

That’s news to me (about props)… but he does need a training qualification to work on them. I personally know one such.

Instruments… sure. Normally instrument work is done under a 145 roof. Maybe there are exceptions but I don’t know of them.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

That’s news to me (about props)… but he does need a training qualification to work on them. I personally know one such.

An A&P can only remove and replace props and dress blades, that’s it.

AC20-37e is the relevant regulatory data source :

An FAA-certificated mechanic with at least a powerplant rating can accomplish all

other propeller maintenance and minor repair by using the practices and techniques specified by
this advisory circular (AC) and in the propeller manufacturer’s service data. Some maintenance
and minor repairs in this category are the removal of minor nicks, scratches, small areas of
surface corrosion, painting, and minor deicer boot repairs. Because of the complexity of
propeller damage and because damage tends to be hidden or not obvious to untrained
maintenance personnel, we recommend that propeller damage be referred to experienced repair
personnel whenever doubt exists regarding a condition that has been observed. We further
recommend that owners/operators follow the manufacturer’s maintenance and overhaul program.

Last Edited by Michael at 29 Dec 10:29
FAA A&P/IA
LFPN

Peter makes a fare point about the inflexibility of some European maintenance companies but the motivation is usually lack of detailed knowlage of the workings of EASA and / or pure overwork of people who have far to much to do and no time to do it ( at a labour rate that is 25% of what car dealers are charging ).

It also has to be remembered that the FAA system is mature, EASA is quite new and some like me have still a foot in both camps with Annex 2 aircraft maintained under the old national system.

While this in no way justifies the shortcomings of those operating the system badly it is the reason.

I specifically believe that the widely-practiced requirement for an EASA-1 form may be an over-interpretation of “convenient” regs.

For far more years than I have been flying, the UK CAA accepted any suitable evidence of traceability for normal parts (not engines or props). It didn’t have to be a Form 1 (JAA or EASA). Not many people knew that! But it was there in black and white – here.

The requirement (if it really exists totally and universally for all certified GA and for every component) for a Form 1 really transforms the picture on aircraft ownership and elevates the costs – because so often you are over a barrel.

And it’s going to get harder. For example while Socata parts are still no problem in the vast majority of cases, I am seeing increasing examples where something is on a very long lead time. The items themselves exist OK but getting them with a Form 1 is a right bastard.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

And it’s going to get harder. For example while Socata parts are still no problem in the vast majority of cases, I am seeing increasing examples where something is on a very long lead time. The items themselves exist OK but getting them with a Form 1 is a right bastard.

Again why being negative on EASA? EASA also has certain regulations to accept certain parts without EASA Form 1.

The lead time from Socata will be the same for N reg and EASA reg. If the part is unavailable, you can apply for a modification. You could do this under both FAA and EASA.

Come-on, this EASA negativity really doesn’t make sense….. Your happy to be flying N-Reg, which is perfectly fine, though flying EASA doesn’t make things MUCH different…. Again, when you pointed out another bad UK company stating that will not allow an non eligible fuel pump, has nothing to do with that UK company. If it was your friendly A&P/IA he should do the same on your aircraft.

Please stop damaging European aviation industry with comments that are just not true.

Last Edited by Jesse at 29 Dec 11:38
JP-Avionics
EHMZ

Which parts don’t need a form 1 or other documentation?

The point about N is the choice of suppliers.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

Which parts don’t need a form 1 or other documentation?

No critical parts (no primary structure, no flight controls, no life limits) can be considerd for this, if they meet the other requirements as well. It requires they aircraft owner to take full responsbility for such parts though.

Peter wrote:

The point about N is the choice of suppliers.

Ok, so you can only buy from A&C, WigglyAmp or me, when you are flying on EASA Reg? Offcourse not! Under EASA you can buy some parts in common with FAA registered. Then you have some parts which are FAA only, and then you have some parts which are EASA only. Again, their isn’t such a big difference.

JP-Avionics
EHMZ
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