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

I came across this EASA FAQ 136280. It is probably the same thing as posted further back, and is current as of today.

This concession is now almost completely worthless. My emphasis:

Clearly somebody had a hand in sabotaging this, because probably 99% of aircraft parts don’t have a number “engraved” on them! And anybody involved in aviation will know that this wording will have precisely that effect.

Big advantage here of being N-reg – even though most European maintenance companies still demand an 8130-3 (because they are clueless) so you also need a “smart” A&P.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

even though most European maintenance companies still demand an 8130-3 (because they are clueless)

That’s a bit of a broad and untrue statement Peter.

If the company is an EASA (or UK CAA) Part 145 with FAA repair station, they are bound by the rules in the US-EU/CAA bi-lateral safety agreements.
From section 7:

Avionics geek.
Somewhere remote in Devon, UK.

Bilateral treaties have nothing to do with an FAA A&P mechanic sourcing and/or installing parts on N-register aircraft, regardless of where he’s physically located.

No parts other than instruments, propellers that have been immediately beforehand serviced by an FAA repair station (because those particular components can’t be serviced legally by an A&P) require any paperwork to be installed on an N-register plane. Otherwise, meaning in 99% of cases including for example overhauled engines, new instruments and airframe parts, the installing A&P mechanic inspects the parts and his logbook entry documents installing a new part or e.g. a “used serviceable” part. Typically he would reference the part number. And that’s it.

Last Edited by Silvaire at 10 Apr 18:47

Silvaire wrote:

Bilateral treaties have nothing to do with an FAA A&P mechanic sourcing and/or installing parts on N-register aircraft, regardless of where he’s physically located.

Very true. That’s why my response to Peter’s comments about ‘European Companies’ specifically stated if the company was an EASA or CAA Part 145 holding an FAA repair station approval.

Avionics geek.
Somewhere remote in Devon, UK.

A repair station is required for almost nothing on privately operated N-registered aircraft.

Also, if an A&P mechanic is working at a repair station and installs parts (from anywhere) that have not been serviced by the repair station, he just signs the logbook as an A&P.

There is no particular reason why the owner of an N-registered aircraft needs to be interested in the exceptional limitations of a non-FAA-licensed facility working under treaty when he can otherwise have an A&P mechanic install the parts in the normal way, minus any requirement for paperwork.

Last Edited by Silvaire at 10 Apr 19:13

@wigglyamp if you participated more on EuroGA, I (and others) would have fewer opportunities to post incorrect or incomplete information. It would be a win-win scenario Knowing what you know, I often reference you but you rarely turn up, so it’s a pity that you do so largely when the industry gets some unfavourable commentary.

As posted above, most GA maintenance is not done by 145 companies. These are needed, on N, only for the 2-yearly transponder check, and prop work.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

As posted above, most GA maintenance is not done by 145 companies. These are needed, on N, only for the 2-yearly transponder check, and prop work.

And instrument overhauls. But little else.

Interesting point. I send any avionics off to the US where a 145 (Repair Station) does it.

But if one sends the said instrument to a company in Europe which is not FAA 145, and issues an EASA-1 form, is that acceptable? I think it is.

Then what do you do when after the company here has sat on the instrument for 6 months “waiting for parts” and then tells you that they can no longer issue a Form 1 (because, but they won’t explain it thus, their “Form 1 laser printer borrowing arrangement” has been terminated by the owner of the said laser printer)… Oh dammit I am being critical of the European GA industry and the practice of some 145 companies renting out their Form 1 printing authorisation; I really must stop doing this

Getting back to the earlier topic, the words “engraved on…” must have come from somebody who knew exactly that this will sabotage this concession. Somebody who knew nothing about planes would not have used those words, and somebody who knew a lot about planes would have used exactly those words to kill this off. Quite sad really. Who wouldn’t want to be a fly on the wall at EASA?

Administrator
Shoreham EGKA, United Kingdom

Silvaire wrote:

A repair station is required for almost nothing on privately operated N-registered aircraft.

That might well be the case, but from my experience running an EASA Part 145, lots of N-reg owners do in fact use repair stations for their maintenance.

Silvaire wrote:

Also, if an A&P mechanic is working at a repair station and installs parts (from anywhere) that have not been serviced by the repair station, he just signs the logbook as an A&P.

In an EASA or CAA Part 145 holding an FAA Repair Station approval, the FAA A&P is not a recognised certification. All certifying staff use their company approval issued on the back of their Part 66 licence. There is no option therefore to accept a part without the release documentation.

Avionics geek.
Somewhere remote in Devon, UK.

In an EASA or CAA Part 145 holding an FAA Repair Station approval, the FAA A&P is not a recognised certification

We may have wires slightly crossed but the above is not wholly correct. It depends on the scope of the FAA 145. Say the FAA 145 doesn’t have a TB20 on their list, but there happens to be an A&P working there, and you bring your TB20 in, it will be that A&P who will perform the work and sign it off.

How it works in an EASA 145 (without the said TB20 approval) and an EASA66 guy working there, I have an idea but no actual experience.

Administrator
Shoreham EGKA, United Kingdom
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