FAA A&P mechanics IME fully understand that an 8130 is not required for parts.
Sadly, my fairly extensive experience of the UK scene is that this is almost totally unknown here. Most N-reg aircraft maintenance here is done by companies (not individual freelance A&Ps) – this I believe is simply because most owners of “better quality” hardware simply drop the plane off at Dealer X with a “blank signed cheque on the seat” – and the companies make more money on the supply of parts purchased from “official aviation sources” which means 8130-3 or EASA-1 forms. One particular company which I have been extremely familiar with personally was doing this exclusively, basically treating N-reg as EASA-reg and implementing every line in the airframe manufacturer MM at each maintenance occassion.
On a different angle, airframe manufacturers have long ago developed a system which makes “OEM sourcing” tricky – by allocating special part numbers to as many parts as possible, and/or getting the manufacturer to come to an “arrangement” to make a slightly different version of the part (often, just a different P/N on the sticker – see e.g. here) for the airframe manufacturer, so a truly identical part is not available via a commercial channel. Socata have taken this method to an art form.
An exactly identical method is used by manufacturers of all kinds of retail items to make it harder for someone to walk into a shop and try on say an item of clothing and then purchase the identical item from say Amazon: they produce slightly different lines for online sales, so someone wishing to pull the standard consumer trick will not be able to buy online with enough confidence that he will get the same item. It doesn’t always work; I have a ski jacket bought for €350 from a German online shop which is exactly identical to one seen in a UK shop for £760 and in a shop in Zermatt (yeah – Zermatt has to be “done” even just once per life, to skid down the slope with the Matterhorn in front of you and to see the shops displaying just four Patek Phillipe watches in the window, CHF20,000 each 
) for CHF1699.
That said, this EASA initiative is obviously to be welcomed. It will benefit pro-active owners, especially when Part M Light and ELA2 come in, and if a suitable hangar and a suitably pragmatic freelance engineer are available.
Peter wrote:
and the companies make more money on the supply of parts purchased from “official aviation sources” which means 8130-3 or EASA-1 forms
If the company is working under an FAA repair station granted on the back of its EASA Part 145, then it is obliged to use released parts with the right paperwork, as this is stipulated in the US/EU bilateral agreements (TIP/MAG 6)
That’s interesting, though not surprising.
If the FAR 145 Repair Station has its approval done from the US directly (which apparently is very difficult to get nowadays) would this restriction still apply?
FAA repair stations issue 8130s for the work they must mandatorily do, and in exchange they can do things like have unqualified personnel do the work… However, by regulation they supply a very limited inventory of parts compared with all those on a plane, and they aren’t often otherwise involved in light plane maintenance. For everything else except parts supplied by a repair station, 8130s are irrelevant to the installing A&P.
I once said to my A&P that a particular part had been supplied by a EASA Form 1 but not an 8130 (yes, I was tweaking him ) His answer was as predicted “Yeah, whatever, toss it”
My club has just bought a piece of used avionics from the US. It comes with a 8130-3 (NON dual release). We had some difficulty with the EASA form 1 but eventually our CAMO said that he could arrange for an EASA form 1 based on the 8130-3. Now, however, my avionics shop says that we don’t need an EASA form 1 even though it is not a new component. They referred to the following regulations:
GM1 ML.A.501 Classification and installation
Components accepted by the owner in accordance with 21.A.307(c) of Part 21, or standard parts are eligible for installation without an EASA form 1.
21.A.307 Release of parts and appliances for installation
A part or appliance shall be eligible for installation in a type-certificated product when it is in a condition for safe operation, and it is:
(a) accompanied by an authorised release certificate (EASA Form 1), certifying that the item was manufactured in conformity to approved design data and is marked in accordance with Subpart Q; or
(b) a standard part; or
(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
Apparently an 8130-3 is fine for the purpose of (c)2 and (c)4! That was news to me.
If that is so, it is a part which needs neither form, so the willingness to accept the 8130-3 is superfluous.
But yes I thought this was for new parts only. @wigglyamp may well know more.
I did a search for some exact text from the above quoted regulation and it digs out a number of previous discussions around this exact topic.
The regulation itself is quite old.
It’s weird, reading these. They are kind of “elephant in the room” discussions, with people dancing around the topic and nobody working in the business wanting to clearly state “yes you can”. Various people speculated that this could undermine the maintenance business, by e.g. allowing people to buy parts from the US. No reply to this one for example.
One chap who works at EASA pretty well said this is what it says.
I suspect the biggest challenge must be to get one’s CAMO (or whatever) to accept that this regulation says what it says. I have long lost count of cases where they simply refused to read something. From time to time I get involved helping somebody to find some TB20 part and probably 100% of them get stuck with their CAMO demanding an EASA-1.
One could merge these threads under a new title like “When EASA-1 form is not required and why does nobody in the business want to discuss it”
Peter wrote:
nobody working in the business wanting to clearly state “yes you can”
Well, clearly my avionics shop did and they did so in a mail to my CAMO. We’ll see what happens. We have a rather pragmatic CAMO.
Peter wrote:
If that is so, it is a part which needs neither form, so the willingness to accept the 8130-3 is superfluous.
Yes, but having an 8130-3 makes it feel better for us as an owner to accept the responsibility according to (c)5 above. Also I guess that in some cases it makes it easier to demonstrate compliance with (c)2 and (c)4.
I’m not sure what (c)4 means…?
clearly my avionics shop did
They probably won’t come here and post it
having an 8130-3 makes it feel better for us as an owner to accept the responsibility
Responsibility for exactly what? The only risk I see is that the part is counterfeit, which is obviously not possible with GA avionics. This “counterfeit protection” (plus, cynically, revenue protection for those who pay license fees to their national CAA, but that is not a reason in the US) is the sole reason for the existence for these forms, because they don’t confer any authorisation for any particular installation. Might be possible with some fastener where in theory somebody could be selling ex ebay chinese ones, but then they will sell them with a fake EASA-1 form… And all this is assuming somebody finds out and starts digging, but there is zero chance of that. If this was a wing attachment bolt which broke and there was a big accident, that would be different.
not sure what (c)4 means…?
I suspect it may mean that the item must be approved for the particular installation, either specifically (e.g. STC, AML) or generally (TSO). This could be a big gotcha. Maybe @bookworm might know what the intended meaning was.
