.The FAA doesn’t mandate parts traceability for installation in certified aircraft? And parts must not conform to acceptable or approved standards and designs?
As I and others have posted many many times, an FAA A&P has the authority (for Part 91) to inspect a part and determine airworthiness.
This means that in most cases you avoid the European Form 1 runaround / moneymaking machinery. In fact no paperwork at all is needed in most cases. The result is a saving of 2x to 10x on parts costs. Of course this goes together with a freelance mechanic who prefers customer-supplied parts otherwise (if he’s fairly successful) he will soon get pushed into the mandatory VAT registration area. A maintenance company greatly prefers to supply parts because they make some 25% just by ordering them.
And, to bring this on topic, this has even more value in countries where, shall we say, you have less of an “ecosystem”. I would expect the “ecosystem” in Italy to be less than stellar – evident from my business dealings with Italian firms which is a story over a beer or two 
The plus side is that DHL etc do deliver there 
The difference seems to be the FAA trusts the professionals working in the field, in particular the A&P mechanic.
The EASA distrusts the professional people, but trusts the documentation (large amounts of paper) – which can be, and is, compromised, of course.
Yes; that is the European way everywhere. Same in business: ROHS, REACH, WEEE, ISOxxxxxxx, you name it, moneymaking/marketing BS everywhere. And half the pages in a typical trade magazine are taken by compliance services companies. Mind you, the US is just as capable when there is enough political pressure and too few people with a brain are around to ask the right questions: the Conflict Minerals Act
The difference seems to be the FAA trusts the professionals working in the field, in particular the A&P mechanic.
The EASA distrusts the professional people, but trusts the documentation (large amounts of paper) – which can be, and is, compromised, of course.
It may work for maintaining large fleets of large commercial aviation, it is a buerocratic nightmare for small GA.
The FAA doesn’t mandate parts traceability for installation in certified aircraft?
Nope, not for privately operated aircraft.
There are some exceptions, for example when the part needs to be overhauled by a repair station, and cannot be overhauled by an A&P mechanic. The mechanic therefore needs a 8130 to install it. This would include propellers and instruments, although if it’s a part on which no work has been done, I don’t believe there is an issue.
And parts must not conform to acceptable or approved standards and designs?
The part for a certified aircraft has to be in conformance with the TC, STCs or any field approval that may apply, but in general no paper trail is required for Part 91. Conformance is not the same thing as paperwork. The A&P mechanic installing the part informs himself about where the part came from and if he is satisfied with its conformance his logbook entry documenting the work and part number makes it a legal installation. This is equally true if I buy e.g. a used flap from my friend in Florida who has been storing it since he bought a crashed plane in 1988 and harvested it for parts.
This has been working OK for 100 years or so.
No Form 1 style paperwork (or any paperwork) required for parts, whether new or used, and regardless of who/where they come from.
This sounds like one could buy a Boeing yoke on Ebay and install it in a Piper.The FAA doesn’t mandate parts traceability for installation in certified aircraft? And parts must not conform to acceptable or approved standards and designs?
It is debatable where Italy ranks in the world, but N-reg is definitely the way to go in poor / 3rd World countries.
The downside is that those countries also tend to ban long term parking of foreign regs.
The main aircraft maintenance reasons to be N-register and operating under FAR Part 91 are:
No requirement for a maintenance plan document, meaning no requirement to generate that document or update it as you adapt to changing knowledge or circumstances in maintaining your property.
No Form 1 style paperwork (or any paperwork) required for parts, whether new or used, and regardless of who/where they come from.
Annual inspection documentation that consists only of a mechanic’s logbook entry in the airframe and engine logs, and the propeller log if there is one (not required for FP prop). No forms submitted to anybody at any time in relation to periodic inspections.
Engine and propeller maintenance on condition from new and indefinitely onward. No change at any hours or years SMOH, and no additional documentation or additional inspection protocol regardless of hours or years SMOH.
All FAA mechanics are independently government licensed. Whether they work for a company or independently has zero effect on their authority or approved scope of effort. Any mechanic’s invoices (if they exist) are a commercial issue, not a FAA regulatory issue. No work orders or business paperwork/formality are required (by FAA) unless it suits the mechanic and customer for their own reasons. Nothing is paid to FAA or anybody else except the guy doing the work.
There are others but those would be plenty enough for me.
Maybe there are many employed FAA AP/IA as well?
Very few I have seen.
And an FAA 145 company does not need employees with A&P / IA qualifications; the work is signed off under the 145 authority. But probably a fair number inside these, still.
There are good reasons for being N-reg, for decades now, and it was not just the IR. It is no less favourable now to be on N but few would go that way now.
of all the FAA A&Ps I know of here in CHE, all are EASA 66 certified, and all are freelancers for both fields.
Interesting. Here quite a few are dual (my A&P/IA included) but they don’t like working on G-regs due to hassles with based maintenance companies (politics again).
What it is like in Italy is of course what matters in this case. I suspect, due to the very thin certified GA scene there, the situation will vary sharply with the location.
Peter wrote:
It is very strongly true in Europe
As a measure, of all the FAA A&Ps I know of here in CHE, all are EASA 66 certified, and all are freelancers for both fields. Not to forget that whilst most fields have a maintenance shop, not all technicians working there are licensed.
It is very strongly true in Europe
Maybe. Maybe there are many employed FAA AP/IA as well?
aart wrote:
Except for countries where airworthiness is self-declared AIUI.
That might be possible for homebuilts and UL’s but surely not for normal category Annex I aircraft such as a Piper Cub?
