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Installation of parts and appliances released without an EASA Form 1 or equivalent

The latest reference on which parts must have an EASA-1 form to be installed on an EASA-reg?

There is a wide variation in the field on the implementation.

I see cases where a firm will refuse to touch even an “avgas” wing sticker (or something similarly trivial) without an EASA-1. But a lot seems to depend on whether the part was sourced by the company, or supplied by the aircraft owner. They tend to be tighter in the latter case.

Is there a clear reference for this, listing the item categories? I get asked quite often by pilots whose planes are grounded, sometimes for many weeks, because some part is available but without an EASA-1.

Administrator
Shoreham EGKA, United Kingdom

I wonder why nobody has responded to this one?

I can however well imagine the answer is not trivial, because there are different categories of parts.

Administrator
Shoreham EGKA, United Kingdom

Peter, as far as I understand it, there’s no real list of parts but just a certain list of criteria which, as long as the said part meets the restrictions below (currently only for ELA1, ELA2 should follow shortly) then the owner can install a part as long as he notes the work in the logbook and accepts responsibility for this installation

21.A.307 (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.

EDL*, Germany

OK; thanks Steve.

It turns out that extract was discussed here previously. Some very interesting discussions! At the time it wasn’t a current regulation.

here
here
here

The first two are pretty amazing.

So this reg is current, and usable under 2000kg?

So what, to take one example, prevents a maintenance company from accepting, without a Form 1

  • TB20 flap relays, provably sourced from Matsushita
  • a starter relay, provably sourced from Valeo
  • a ground power relay, provably sourced from Stancor (via Mouser USA)
  • various filters, sourced from the French manufacturer (under false pretences obviously since most won’t sell to Socata customers )

I could make a long list here – all refused by CAMOs in Europe.

In each case, the part is exactly identical to the Socata part.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

So this reg is current, and usable under 2000kg?

yes, here is the document on the EASA Website

EDL*, Germany

Here

NPA TOR

Sounds interesting?

The requirement for an EASA-1 form is a huge restrictive practice on the Part M scene. In FAA-land the 8130-3 is usually not required, not least because an A&P has the authority to inspect a part (new or used) and declare it airworthy – in most cases of airframe parts.
.

Administrator
Shoreham EGKA, United Kingdom

Do I hear the sound of the bottom falling out of the market for non-structural aviation fasteners?

LKBU (near Prague), Czech Republic

I wonder which fasteners are really non structural? All rivets in the skin are structural.

It is already the position that while one tends to get an EASA-1 form for almost everything if bought from traditional aviation sources such as Airpart, Adams or Saywells (in the UK), stuff bought from others often doesn’t come with it, stuff bought from Aircraft Spruce USA (or Sandelving, their German agent) doesn’t, unless you pay a whacking surcharge for an 8130-3 (which is not allowed for an overhauled part to go on an EASA-reg anyway) and I don’t think most people bother too much.

Even the four screws which hold the altimeter in place are supposed to be traceable but in practice this is mostly ignored in GA. Well, the bag of 1000 probably came with a form

So I wonder what this really means? Fasteners are mostly cheap anyway. Even €0.10 o-rings at €20 each are not a big enough fish to fry, in the wider picture.

Releasing without an EASA-1 is basically sourcing OEM parts. Everybody in the business (who isn’t making a margin on the parts) would like to do that, and everybody who is making a margin is trying to stop them.

Being able to source major parts from OEM sources e.g. electric fuel pumps or landing gear pumps would be wonderful. I can’t see this happening because of e.g. stuff here. The aviation business blocks the bypass route by applying a sticker to the parts they buy in and resell, having either removed the original label or stuck the new label on top, which has a different P/N, and that makes it a “different part” from the OEM one So now the prospective installer has to prove it is the same part, which he usually cannot easily do.

And the “critical part” classification takes care of most of the pricey bits

The industry wants to maintain this because a 25% trade discount on a $1000 part is a lot better than a 25% trade discount on the same part bought OEM at $200, and parts sales – which are crucial to the maintenance industry which needs this 25% or so margin – are practically the only revenue source for companies like Socata and their piston line, and most of the others except Cirrus which still sells some quantity of new planes. But even Cirrus would suffer badly if OEM sourcing was widely adopted, and even in the USA almost all A&Ps won’t touch OEM parts no matter what CofC is enclosed.

Administrator
Shoreham EGKA, United Kingdom

It is a bit difficult too see what exactly this NPA will mean in practice since part-M is generally very difficult to read. The intention is certainly good — the question is if it goes far enough.

From glancing through the NPA, one consequence seems to be that when an industry standard part is used on an aircraft and today you have to buy it through an company which is approved to produce an EASA form 1 for it (e.g. the aircraft manufacturer), if the proposal is adopted you could buy it directly from the manufacturer. You have to show evidence that the part is equivalent, but the evidence required depends on the “criticality level” of the part — which is determined by the type certificate holder.

The proposal has a flaw which I believe will be the cause of great confusion if not changed. There are four “criticality levels”: CL I, CL II, CL III and CL IV, with CL I being the most critical. However, the NPA refers to the numbers when comparing levels, so CL I is a called a “lower” criticality level that CL II, even though CL I components are more critical!

Last Edited by Airborne_Again at 15 Dec 08:43
ESKC (Uppsala/Sundbro), Sweden

Peter wrote:

(which is not allowed for an overhauled part to go on an EASA-reg anyway)

This has been said many times before and is incorrect. An FAA 8130-3 for a used/overhauled/repaired/inspected part is perfectly acceptable on an EASA aircraft provided that its a ‘Dual-release 8130-3’ issued by an FAA repair station that also holds EASA approval – such as Southeast Aerosapce and many many more.

In the case of fasteners, O rings and such similar standard parts, these do not require an EASA Form 1 if they are manufactured to an internationally recognised specification (NAS, MS, AN etc) and only require a C of C traceable to the original manufacturer.

Avionics geek.
Fairoaks. EGTF
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