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

Curiously there is a “_temp” in the URL so the intention is to either move it or delete it at some point… I’ve downloaded it (25MB) and can re-host it, if anyone thinks it has value.

I have just watched this video and one needs to be a total specialist in this topic to work out what it is saying. It seems to be the same as the previous versions, discussed here for years, and recently rendered worthless by a change of wording. Has EASA removed that recent change?

Maybe someone can do a summary?

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

Maybe someone can do a summary?

Sure. This change introduces three new exemptions from Form 1 requirements.
21.A.307(b)(3) is of very little significance: it merely allows the TC/STC holder to specify (voluntarily) that such and such parts bear a negligible safety risk and can therefore be installed without a Form 1.
21.A.307(b)(5) allows a similar exemption to be specified in the OPS/NCO/NCC/SPO requirements.
21.A.307(b)(4), however, is very interesting. It allows such exemptions to be specified in CS-STAN (certification specifications for standard changes and standard repairs), and CS-STAN issue 4 already contains quite a few such exemptions. Please refer to the text for full details and eligibility limitations, but here is a brief summary:

  • small lithium batteries in devices (in particular, CE-marked ones have a blanket approval)
  • GNSS receivers and antennas for ADS-B out with SIL=0
  • GNSS receivers and antennas for VFR navigation
  • landing and taxi lights
  • anticollision and position lights for day VFR only
  • visual awareness lights (these are essentially uncertified anticollision lights)
  • cockpit/cabin LED lights
  • LiFePO4 batteries other than starter ones (gliders/motor gliders only)
  • tyres and skids (gliders/motor gliders only)
  • DC-DC converters
  • FLARM equipment
  • other electronic conspicuity equipment not emitting in the air band
  • aircraft trackers
  • pilot awareness devices
  • flexible seals on control surfaces (ELA1 only, i.e. MTOW < 1200 kg)
  • mini-FDR and flight time recorders
  • mounts for portable equipment
  • CO detectors
  • some annunciators
  • engine preheaters
  • powerplant multifunction displays, fuel flow/pressure instruments
  • angle of attack instruments
  • tactile stall warners (stick shakers, etc.)
  • weather uplink receivers
  • structural parts for repairs performed in accordance with FAA AC 43.13-1b (most importantly, materials like sheet metal, plywood, resin, etc.)

For all CS-STAN stuff, the installer should complete an EASA Form 123 and keep it on file, and give a copy to the aircraft owner to keep with aircraft records.

Also, for completeness, I’d like to comment on the old but oft-misunderstood point 21.A.307(b)(2)(ii): “identified for installation in the specific aircraft”. The meaning of this phrase has been explained in the certification memorandum CM-21.A-K-001:
The part or appliance shall be identifed in the ICA published by the design approval holder (e.g. IPC, Maintenance Manual, etc.). Furthermore the aircraft owner has to record the decision to accept the part or appliance without an EASA Form 1 for installation in their aircraft. An example of such record is provided below (Figure 1), which shows that the owner of a specific aircraft (Type and registration) has signed for the acceptance for installation (Specific for each accepted part), and is aware of the responsibilities (Part-21 reference is included).

Last Edited by Ultranomad at 13 Jun 17:17
LKBU (near Prague), Czech Republic

My partly contrarian comment would be that much of that list is disingenuous

They forgot the backpack I carry!

There is a lot of stuff which is pretty well universally accepted as “portable” and thus totally exempt from any regulation (private flying context) – e.g. CO detectors.

Other items are interesting e.g. weather uplink receivers. If not aircraft powered then why even list it? If aircraft powered, then it needs appropriate wiring practices and probably a CB, and the CB will need an EASA-1

What is a DC-DC converter? A cigar lighter plug-in USB charger? Self evidently not needing an EASA-1. A permanent installation of a USB power outlet in the panel?

Too much ambiguity remains, IMHO. Any ambiguity tends to be construed in favour of the party making a living

I think a lot of meaning has been lost in this EASA-1 debate. What is the form really for?? It is a traceability document only. So many parts are self evidently not going to be fake, and so many will be fine even if they are fake. The form has become a maintenance industry revenue support device.

Today I shipped some electronics to a customer in Bahrain. They want a Certificate of [UK] Origin. Guess where this comes from? I purchase it from here, hey ho, hey ho… and bill the customer 100 quid or whatever. EASA-1 is worth as much – for any part which does not have a S/N stamped on it.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

I have just watched this video and one needs to be a total specialist in this topic to work out what it is saying. It seems to be the same as the previous versions, discussed here for years, and recently rendered worthless by a change of wording. Has EASA removed that recent change?

There is an important clarification here (at least for me). The meaning of the phrase that a part “is not conforming to the design” is that something is wrong in its production. Possibly it could also refer to faults in the part after production.

ESKC (Uppsala/Sundbro), Sweden

Peter wrote:

Too much ambiguity remains, IMHO.

I don’t see any ambiguity – particularly not if you read CS-STAN. All the items in the list are taken from CS-STAN.

In any case none of this applies to equipment which is not installed. So a cigar lighter USB charger would never need a Form 1, while a permanently installed power outlet would. (If it was not for CS-STAN.)

ESKC (Uppsala/Sundbro), Sweden

Hello All,

I was reading online that under part ML (owners maintenance) you actually don’t need the EASA form 1 to install avionics (like G5 or autopilot). I am wondering if that is true in the real world? Looking to purchase either new from a US based seller or used on ebay etc.

What would you say?

LPPM / LFBL, Portugal

Not exactly but close: for an ELA1/ELA2 aircraft, an owner can accept responsibility for installation of a part without Form 1 that is neither life-limited, nor part of a primary structure, nor part of the flight controls, and is identified for installation in the aircraft in question. Accordingly, a G5 can be installed if your aircraft is on the AML (approved model list) for the respective STC. An autopilot cannot be installed under this provision, and even if it could, it’s very difficult to verify its proper operation without a dedicated test set, whereas maintenance organisations that have these test sets would normally be able to issue you a Form 1 anyway.
For buying new parts in the US, Form 8130-3 can be used in lieu of Form 1 even without a dual release.

Last Edited by Ultranomad at 26 Sep 16:30
LKBU (near Prague), Czech Republic

But there is a problematic condition:
…provided that the installer holds a document issued by the person or organisation that manufactured the part or appliance, which declares the name of the part or appliance, the part number, and the conformity of the part or appliance with its design data, and which contains the issuance date.

You must talk to your ARC person so you share the same opinion about that condition.

ESSZ, Sweden

Fly310, for avionics, the nameplate should be sufficient to fulfil that requirement.

Last Edited by Ultranomad at 26 Sep 19:25
LKBU (near Prague), Czech Republic

Identical topics merged.

Yes most of the industry boycotts this concession because it is revenue reducing.

Administrator
Shoreham EGKA, United Kingdom
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