Steve6443 wrote:
Am I right in saying the only way I can legally fit them to my plane is by getting him to refit those seats to his plane, get him to fly to a Part 145 organisation, have them remove them, inspect them and issue the Form 1?
It is not the only possibility, but a possible situation. EASA requires that these parts are removed, stored, inspected and issued an EASA Form 1 while being in a controlled environment.
Another possibility would be to have an Part 145 shop, which has a C rating for seats, and has capability for these seats to inspect them and issue a EASA Form 1.
Steve6443 wrote:
He takes said original seats out and fits the new seats himself to his plane.
It is important too understand that an EASA Form 1 doesn’t make a part eligible for installation. If the P/N is different (which seems logical if it are different seats) it is important to check if his new seats are allowed to be installed in his aircraft, and his old seats in your aircraft. It might require an minor change if these are not listed in the parts catalog for these S/N. It can also be questioned if this modification would fall under owner maintenance.
wigglyamp wrote:
The most important part of this is that the recipient of the recovered parts has confidence that the parts are from a genuine source, the parts have no hidden damage because of previous crash history etc and hopefully the required paperwork correctly reflects the condition.
I would agree. Pre EASA, when I did more mechnical work as well, I once received an nose gear fork. This second hand part did look nice. On close inspection I found a small part in which the paint seemed to have a different finish. I didn’t trusted it so stripped the paint of. This difference in finish was due to filler. This filler was used to hide the damage from a previouse gear fork collapse. There are sick people around.
A while ago I also saw a spar that was “repaired” by “someone” using filler. Again very sick people who do this kinds of things IMHO.
Not a change that any EASA shop would give an EASA Form 1 for these parts. So I think this a good structure.
a possible situation. EASA requires that these parts are removed, stored, inspected and issued an EASA Form 1 while being in a controlled environment.
So, if I want to sell dodgy parts to somebody, I can fit them to my plane, fly it to a 145 company, get them removed… etc 
If I can think of that in a few seconds, I am sure somebody is already doing it
Peter wrote:
So, if I want to sell dodgy parts to somebody, I can fit them to my plane, fly it to a 145 company, get them removed… etc
Sure, they should be inspected however.
As indicated before, if someone is willing commit fraud, no regulations are going to stop that. In general it works well.
Have seen “homemade” 8130 and EASA Form 1’s as well. This is one of the reasons why Part 145 have approved suppliers / contracters, and why at many of them you have to pay a fee if you bring your own equipment. For me the reason would be due too loss of margin on parts and to compensate for much more (paper)work. Often it is found with incorrect paperwork or incomplete.
More often than not, when I source used parts they come from some very large box on a shelf in a friend`s hangar…. Where they`ve been sitting for 20 or 30 years since he obtained them from another guy who removed them from a plane 15 years before that… I restore them as/ if required, install them, he (an A&P) supervises and signs the logs. No 8130 is supplied or required – its not necessary for a N-registered plane in private service.
Yes; I think in most cases it will be (or should be) blindingly obvious that the source is potentially suspect.
If you google on any aviation P/N you get a ton of hits, with virtually all of them being parts brokers who don’t have the item in stock and probably never have. They simply generated a website which a search engine visible database containing every possible aviation part. So e.g. for Brand X they probably borrowed the ATP CD and did OCR on it and stuffed the whole list into their database, in the hope that one day some desperate customer with that aircraft will pay the earth for the said part, which they can obtain from “somewhere”. They have a bunch of people in their office who phone around a circle of usual contacts. In this climate it is dead easy to insert dodgy parts into the system. The parts broker will never try to verify a fake form. Greed (or desperation) always works
For example google on this completely random part from the TB20 IPC: Z00.N7067170011. All the hits are parts brokers. It happens to be a terminal block made by some obscure (possibly nonexistent today) French company which, if damaged, will ground your plane because your Part M company will not release to service until they get that exact part with an EASA-1 form.
In Silvaire’s system the chances of something dodgy pending up in that box is close to zero.
Funnily enough the one time I found it very hard to get a part from my plane was during the D3000 magneto problems (most but not all parts in these are made under PMA and when Bendix dropped the product line a lot of parts were hard to get) and the only contact who had a particular part was a certain UK FAA+EASA 145 company “with a reputation”. I got them to overhaul the mag (a spare one, fortunately) but when I asked them for a copy of the work pack they went into a really obvious stonewalling/whitewashing mode. I reported this to the CAA who weren’t interested… It became pretty obvious that at least one “new” item was a secondhand one and the 8130-3 was just a copy of another one.
So, I have one data point (having dealt with a crooked company but caught them out by applying a standard procedure) and Jesse has the opposite data point (having dealt with another crooked company but caught them out by being suspicious). I think we can agree that the system is only as good as the paperwork and peoples’ willingness or ability to not accept the paperwork at face value.
wigglyamp wrote:
You can buy second-hand parts on the open market that come with an FAA 8130-3 from US companies and they are delivered in un-cleaned as-removed condition, so certainly haven’t been subject to detailed inspection or undergone tests to determine serviceabilty, yet a DAR has signed the release certificate.
Really ? I have NEVER witnessed such.
On the other hand, I have seen MANY worthless “Yellow Tags” signed off by A&Ps then sold on . These must NOT be confused with Form 8130 that can ONLY be issued by a FAA Certified REpair Station that has an Approved Process for servicing said part or assy.
I vaguely remember a US based FAA DAR telling about some Form 8130 variant that is legally required for used parts to be exported commercially outside the US. He made his living filling out such forms and taking a cut from the sale. I assumed that is why there is so much talk about 8130s in Europe. Maybe somebody more knowledgable than me can comment – to my memory my only exposure to 8130s is when receiving overhauled instruments or whatever from a Repair Station.
Silvaire – The FAA forms used for parts are 8130-3s there are no other variants. They are indeed in some instances signed off by a DAR .
More info from AviationPros
FAA Form 8130-3, Airworthiness Approval Tag, identifies a part or group of parts for export approval and conformity determination from production approval holders. It also serves as approval for return to service after maintenance or alteration by an authorized Part 145 Repair Station, or a U.S. Air Carrier having an approved Continuous Airworthiness Maintenance Program under Part 135.
As you can see from this definition, the form has two distinct purposes:
1. It is used to approve or certify that new and used parts meet conformity requirements from the “Original” Airworthiness side of the FAA.
2. To certify approval for return to service following maintenance from the “Recurrent” Airworthiness side of the FAA.
Functions of Form 8130-3
Since the early 1990’s when the form was revised to meet both these purposes, there has been some confusion about who is authorized to use the form and what the form actually signifies when it is received. The purpose of this article is to clarify the two distinct functions of FAA Form 8130-3 and identify what you should look for to determine its intended use.
A US DAR signs a 8130-4 form – an Export Certificate of Airworthiness.
Historically this was required here in the UK for “Class 1” parts – engines and props. These had to come with either a JAR-1 or later EASA-1, or an Export CofA.
However the FAA stopped the Export CofA system for parts a few years ago. Some mention here and here (the last one needs updating but not as much as some in Europe like to think ) As a result, the European CAAs had to accept a normal 8130-3 for these parts also. I know of one case of an engine…
I am not sure when a DAR would sign an 8130-3. Any examples?
Practically speaking it is a lot easier to sell stuff on US Ebay if it comes with an 8130-3 form. IAE at Cranfield used to issue these for not a lot – say £50 for a radio – but it is years since I last used them.
wigglyamp wrote:
If it’s an EASA aircraft, then MA613 applies to all countries, so please don’t single out the UK again as being the bad apple!
I fully agree with this.
Peter wrote:
will ground your plane because your Part M company will not release to service until they get that exact part with an EASA-1 form.
Peter, I think your forum is great, but you put on so much incorrect information related to EASA, mechnics and companies, “proving” that the FAA system is better. With the power you have as forum leader, you put every EASA company in a bad daylight. That is not fair.
In the case above your aircraft would not be grounded, not on N reg (even if you can not find the part at all) and not on EASA reg. On either system a modification will be sugested, approved, installed and you would be back flying.
Peter wrote:
In Silvaire’s system the chances of something dodgy pending up in that box is close to zero.
Every company has such a box. The issue is that often items get tossed in due to upgrades. After laying in the box for years, nobody nows acurate history or if the item is still functional after years of impropper storage (rust?) Especially with the terms as suggested by Silvair, from 15-30 years.
Peter wrote:
In this climate it is dead easy to insert dodgy parts into the system. The parts broker will never try to verify a fake form. Greed (or desperation) always works
This is one of the reasons why, most companies including me, charge a fee if you are bringing in your own parts. If these are from a supplier which is not on the approved supplier list, more detailed inspection is required. This is one of the functions of the approved supplier list. Also eligibility has to be checked, which a lot of people don’t seem to check. (See shame that Part 145 company (I this case actually CAMO instead of Part 145) that recognises a not eligible part to be installed without correct paperwork). It is not fair to blame companies for this. Again this would be an issue on FAA as well. The difference between FAA and EASA is much smaller then always suggest.
Silvaire wrote:
I restore them as/ if required, install them, he (an A&P) supervises and signs the logs.
While I think you could do this on some parts, I am quite sure you can not do this on prop, instruments (altimeter?) or radio’s for example. @Michael, could you comment on this one?
Again, if someone is willing to commit fraud (I have seen fake 8130’s and Form 1’s), no regulations can make a difference. I am sure people commit fraud on both FAA and EASA. On EASA 145 companies there is a lot of oversight and strict auditing. These companies risk loosing their approval if they would commit fraud.
Fraud I have seen is from persons without either FAA or EASA oversight.
