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

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

local copy

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.
Somewhere remote in Devon, UK.

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.

Yes, sorry, I was not clear enough. However, a dual-release 8130-3 is an EASA-1 form in every way AFAIK. The issuer is an EASA145 company (as well an as FAA145 company, to issue the 8130-3).

Not many parts from Aircraft Spruce will be dual-release. In fact I wonder: if you buy say a Honeywell part from Spruce USA, do you get a dual-release 8130 with it?

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.

That’s very useful to know, thanks. However these are not major-cost items.

I have been around this one before in the Socata group. The way to actually save some money is to buy in bulk and resell within a “club”. So for example the fuel cap o-rings (which are quite important to replace regularly, due to rain ingress while parked) which are say €20 from Socata but can be bought from some o-ring manufacturer for €1, would be worth buying in bulk, say 100. Soooo, here are some issues:

  • They are made by the usual French aerospace company which sells mostly to French customers and which expertly tells any enquiries for anything supplied to Socata to f_off Le Bozec who are hard to deal with, and Trelleborg are completely clueless (possibly due to a total lack of incentive to p1ss off their OEM customers) when it comes to tracing parts
  • One can find a similar part but “M25988/1-338” is not the same as “N7423015002” which is the first block for anybody who doesn’t want to fit it
  • A possession of a previously bought wrapper from Socata showing both above numbers on it (this is the usual way of tracing OEM parts) is not good enough evidence
  • Most people won’t change it themselves because “it is illegal”
  • Most engineers won’t touch a part thus obtained (even in the USA)
  • I am now liable for the part but more importantly I can’t supply a CofC; I can only supply a photocopy of the original paperwork which of course is meaningless for a non serially or batch numbered part (but hey that sums up all of aviation parts apart from the bigger items ) so an engineer won’t touch it even if he believes it is legal

One guy bought some Matsushita landing gear relays from me. AFAIK he wasted a few hundred quid, because his engineer would not touch them. I told him in advance there was no EASA paperwork. They were 100.000% provably genuine…

Much bigger savings are to be made on other French parts e.g. fuel filters at €200-300 each (mandatory lifed under Part M, every 2 years IIRC, even though it looks absolutely perfect after any number of years). Again, easy enough to trace. LE BOZEC 402A12-5 / SOFRANCE SA CH0751103502N00 and like a number of these French companies, taken over by a US company but you won’t get lucky with that one either if you want any paperwork showing an identical P/N because once they see the Socata P/N they will stonewall.

It would be really interesting to know what this NPA might achieve. If one could buy “provably” same-spec items even if the P/N differs, that would be revolutionary. I just don’t believe that will be allowed.

I suppose we should all comment, but how? If one says that the problem is that the maintenance business doesn’t want this to change, that’s not going to look good

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

Not many parts from Aircraft Spruce will be dual-release. In fact I wonder: if you buy say a Honeywell part from Spruce USA, do you get a dual-release 8130 with it?

For “new” parts, single release 8130 is acceptable for part installation on EASA aircraft. Dual release are only required for used/overhauled/repaired/inspected part.

Indeed, so for example this part could not be installed on an EASA aircraft currently unless it comes with a dual release 8130-3:

Whether EASA is likely to address this aspect I have no idea.

Administrator
Shoreham EGKA, United Kingdom
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