Menu Sign In Contact FAQ
Banner
Welcome to our forums

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

bookworm wrote:

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.

Which is completely obvious. The next Annual or 100 hr Inspection then provides a periodic government-delegated review of the maintenance logbook records for work performed in the preceding year, regardless of by whom, and its conformity to the TC. As always.

The Item (3) necessity for a replacement part sans paperwork to be marked with a part number by manufacturer is a huge constraint. Most parts are not marked at all and the particular codes specified for PMA etc parts weren’t invented when most aircraft were produced.

This is bureaucratic nonsense that has not been necessary for most of the GA world, and it won’t be necessary for most of the GA world in the future. I have for example used 1946 manufactured parts removed from a damaged wing that itself came out of the rafters where it had been resting for 30 years. No problem, normal practice.

Last Edited by Silvaire at 01 Jul 17:49

Many thanks @bookworm for the extra info.

What does this mean

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.

Doesn’t the following clause render the concession worthless for small parts, or any part which carries no markings (the vast majority of GA parts), unless it came in a container carrying the markings?

(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

Administrator
Shoreham EGKA, United Kingdom

Sounds like I was right on b) but I still don’t know what item 3. is supposed to mean. Who applies the “EPA” sticker?

Item b) means that this concession does not approach the FAA one which is that an A&P has the authority to inspect a part (which is not required to have any markings) and declare it airworthy.

I suppose EASA didn’t want the bottom to completely out of the market for most small aircraft parts, extracted from e.g. airframes parted-out outside the 145 environment, notwithstanding that the chance of them being a chinese counterfeit is precisely zero.

Administrator
Shoreham EGKA, United Kingdom

This may help you on EPA

What leads you to believe that “the vast majority of GA parts” are not marked?

I believe no individual aircraft part I’ve ever purchased had markings that conform with items 1-3. Certainly no 50+ year old serviceable, used part. Sometimes a part might satisfy some portion of the requirement, but not conform with items 1-3 as written.

An assembly of parts such as a complete engine with a data plate would seemingly comply, but of course in that case compliance would provide zero assurance for individual engine parts.

Last Edited by Silvaire at 08 Jul 19:26

What leads you to believe that “the vast majority of GA parts” are not marked?

They simply aren’t. Most fasteners for example, other than specialised high tensile products, have either no markings or the markings don’t relate to anything someone could trace. One example which illustrates a particularly high ripoff value part. And let’s face it, the prime value of a concession like this, to the aircraft owner, or to the mechanic who is working for the aircraft owner, is precisely to avoid ripoff priced items like the above.

I know the inside of my plane pretty well, after 18 years of poking about inside during Annuals etc, and most “off the shelf” mechanical parts aren’t marked.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

They simply aren’t. Most fasteners for example, other than specialised high tensile products, have either no markings or the markings don’t relate to anything someone could trace.

Fasteners come under a different provision, standard parts.

LKBU (near Prague), Czech Republic

I suspect Peter may be thinking of such things as metric countersunk screws made with a special sharp Socata-specified head shape to allow their use to retain thin fiberglass fairings

Last Edited by Silvaire at 08 Jul 22:21

Yes that’s one Actually that screw is nothing special – just a well made M4 screw with a sharp lip so it sits flush. I still have a stock of them, available for $3 each and without any paperwork, so there’s an example indeed. Actually those are genuine Socata ones, but I can’t prove that with paperwork.

But how about door handles? They are made by some French “industrial furniture” company, which a French google searching expert could probably locate.

Then we have a whole raft of pricey parts which people have tried to replace with the identical OEM ones e.g. €200 fuel filters.

As I wrote previously, firms like Socata know people try to find OEM versions and probably now also know about this EASA concession, so they have a system where the original part # is concealed and it has a Socata P/N. Crucially, they do a deal with the manufacturer to supply the part with a slightly different OEM P/N so the person searching will not find an exact match. This leaves doubt as to whether it is identical. A classic example is Crouzet microswitches used on the landing gear. You can save thousands just there. Even if it is identical by inspection (perhaps the wires are a different length) the maintenance company asked to install it will likely object. You see the same on Amazon, where manufacturers sell a slightly different P/N on Amazon to what they sell via shops – to prevent people finding something in a shop and – usually while still in the shop – looking it up on Amazon and ordering it there. I know there are apps for exactly this purpose, to defeat that system, but not for GA… So the GA manufacturers have protected their parts business long before EASA did this concession.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

But how about door handles? They are made by some French “industrial furniture” company, which a French google searching expert could probably locate.

Then we have a whole raft of pricey parts which people have tried to replace with the identical OEM ones e.g. €200 fuel filters.

Are you suggesting these are impossible to mark?

Sign in to add your message

Back to Top