Peter wrote:
And as wigglyamp says above this concession is possibly not available to owners who are using a 145 company, working under its 145 authority, to maintain their planes.
This is why some FAA shops chose not to become a “repair station” as that would limit their ability to use / repair certain parts.
That may be, but surely a 145 shop can still work on something using the privileges of an A&P (or someone working under A&P supervision) i.e. not invoke their 145 approval. For 10 years I was hangared in a 145 company which didn’t have a TB20 on their approved list, and they could have done work on it if an A&P was around.
Wigglyamp was referring to the specific case of a “piggyback” FAA145 scheme. We don’t know what happens with a non-piggyback one. I asked the Q above but nobody answered.
So what does this mean in practice?
Eg an old C150… what things could you install or exchange without EASA form 1 or 8130?
Probably quite a lot – if you find a co-operating maintenance company.
Snoopy wrote:
Eg an old C150… what things could you install or exchange without EASA form 1 or 8130?
Anything that meets the following requirements from 21.A.307 (c)
(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.
That list of items 1-4 limits applicability to next to nothing: item 1 eliminates half the plane, and items 2 through 4 are problematic in the real world of used and NOS parts etc.
Item 5 is repeated in lots of EASA regulations and I have no idea what they are trying to say. How exactly would one NOT accept the responsibility to operate within the law when repairing an aircraft?
A friend of mine in Florida recently hit a hidden obstacle and collapsed the nose gear on his certified plane (1 of 8 in the US), breaking a bunch of stuff. The engine and prop were straightforward to rectify, the solution involved mostly money. The rest was different: I was able to source a few parts from 50 year stock in Europe, only EASA paperwork was supplied. I got him some factory drawings so with local help he could make a few other parts (‘owner produced’ and legal), and I shipped him some other used spare parts that I’d got with my plane but which are no longer available new. That’s how you repair planes without paperwork, and he should be flying again this week.
@antonio gave us a great explanation at a recent Zoom meeting we had on this specific topic.
Re 1. I think “life limited” rules out a lot of items e.g. seals but those are mostly cheap anyway. In GA almost nothing of substance has a straight life limit.
Re 2. I think this is just an empty statement because everything is quite obviously manufactured in conformity to some design; if say you pick up a KX165A radio, somebody can hardly argue it wasn’t 
Re 3. I don’t know what Subpart Q says and I have no idea where to find it
Re 4. I think the owner does this “identification”, so it is an empty statement
Re 5. I think this says the owner is responsible, but the owner is always responsible for maintenance anyway regardless of who did the work, so it is an empty statement
Otherwise, this concession is totally useless. For example if 2. means it must come with a CofC, it renders it useless because a CofC for a KX165A is just silly; it can never be generated as a part of a genuine QA process. It is obviously sufficient to say that nobody in china will make a fake KX165A, therefore it must be a real King one, but a seasoned yellow jacket wearing QA man can argue precisely that this KX165A could be a chinese fake and you cannot prove otherwise. And 4. might mean the item has an AML STC or type-specific STC for the aircraft, or has gone in under a TC, which would be OK if you could show that the said KX165A was ever before installed in your aircraft type, which is probably workable especially as a KX165A is obviously OK to install in any aircraft… otherwise this is useless.
Of course a maintenance company can argue all these points, which is probably one reason why practically nobody has ever heard of this concession, after a number of years.
Much or most of what you might replace on a plane is either primary structure or flight controls.
It might be useful to understand the paradigm that is used.
The Design Organisation is responsible for the design of the aircraft as a structured collection of components, and specifies that design in the Type Certificate or STC. It identifies the components with part numbers. The Production Organisation is responsible for the conformance of the components with the applicable design. Normally the Production Organisation would certify this with a Form 1. The maintenance organisation, and ultimately the owner, are entitled to rely on this certificate of conformity — that’s the whole point of certificates. If an incident occurred because the component was not manufactured in conformity with its design, the primary liability would be with the Production Organisation, not the maintenance organisation or owner.
By using 21.A.307(c), the owner is now taking on the role and responsibility of the Production Organisation in ensuring conformity with the applicable design. Note that this is the applicable design, i.e. what the Design Organisation specified in the TC, not just any “design”. If an incident occurred because the component was not manufactured in conformity with its design, the primary liability would be with the owner who was negligent in assuring conformity with its design.
Silvaire wrote:
Much or most of what you might replace on a plane is either primary structure or flight controls.
Primary structure is that structure which carries flight, ground, or pressurization loads, and whose failure would reduce the structural integrity of the airplane. I think that leaves a lot that is not.
Peter wrote:
Re 3. I don’t know what Subpart Q says and I have no idea where to find it
21.A.804 Identification of parts and appliances
(a) Each part or appliance shall be marked permanently and legibly with:
1. a name, trademark, or symbol identifying the manufacturer in a manner identified by the applicable design data; and
2. the part number, as defined in the applicable design data; and
3. the letters EPA for parts or appliances produced in accordance with approved design data not belonging to the type-certificate holder of the related product, except for ETSO articles.
(b) By way of derogation from point (a), if the Agency agrees that a part or appliance is too small or that it is otherwise impractical to mark a part or appliance with any of the information required by point (a), the authorised release document accompanying the part or appliance or its container shall include the information that could not be marked on the part
