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Revalidation of used parts e.g. removed from other aircraft

Can you please post references?

Administrator
Shoreham EGKA, United Kingdom

Can you please tell me why accuse this UK EASA company with the PMA fuel pump, while this wouldn’t be correct under FAA either?

Can you please explain why you find that you can choose your suppliers under FAA, and why you believe others under EASA can not?

Peter wrote:

Can you please post references?

According to 21.A.307(c) parts and appliances without an EASA Form 1 can be considered
acceptable for installation by the owner of the aircraft only when they are:
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.
And when the owner has verified compliance with the above 4 conditions and has accepted
responsibility for this compliance.

JP-Avionics
EHMZ

The one line “identified for installation in the specific aircraft” renders this almost worthless, because it limits the vendor choice to aviation parts distributors, and they can supply a Form 1. But they charge typically 3x more than the same part would cost from the OEM.

Aircraft grounding cases I know off without even going back through 15 years of emails include

  • a landing gear pump (€1000 versus €300 from Parker)
  • flap relay (€300 and on a very long lead time versus €20 from Mitsubishi in Japan)
  • a tachometer (€1000 versus €300 removed working from another aircraft)
  • a Floscan 201B fuel flow sensor (€1000 with a Form 1, versus €100 from Floscan)
  • a starter relay (€300 versus €30 from a Valeo car parts distributor)
  • squat switch (€1000 versus €300 from Crouzet)

Where does it say a Form 1 is required, in each above case?

Note that I am not saying that if you were N-reg and placed your plane in the hands of the same UK based company (the one which says it needs an EASA-1 form for the above) they would not insist on an 8130-3 form, but would be doing so equally incorrectly.

On the fuel pump, the guy should have a comeback on the previous maintenance companies – the one which signed the plane off last, and the one which installed it before that (if different). Or, find out who signed it off as a minor or major mod and didn’t document it (I had that issue myself with Air Touring). Whether this is possible politically is another matter (usually it isn’t, because you can pursue only so many people in this small community before you run out of options).

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

a starter relay

I just installed Skytec FAA-PMA relay with a 8130-3 in an EASA reg. Part cost 80€

Peter wrote:

a tachometer (€1000 versus €300 removed working from another aircraft)

Replacement of tachometer is covered under EASA CS-STAN. A wide range of tachometer is available. You can have a NEW TSO tach with 8130 for ~ 350€ and install it on an EASA reg aircraft.

Peter wrote:

a landing gear pump (€1000 versus €300 from Parker)

I think I have found a replacement pump, directly from Parker, for about GBP 450+VAT (if they think you are a trade user) or GBP 750+VAT (if they think you aren’t ). These are cheap hydraulic pumps, used all over the place. I think the P/N 108BIC19ALL4V2912 is the exactly same model as Socata use. I will buy one and see… What you must not do is disclose the aircraft application when ordering; Parker are very switched on and will block the sale. They claim that they are not allowed to sell to the aviation market but in reality they have an agreement with Socata, and others… They have told me that the above P/N is very rare and they have sold only one, and it went into a light aircraft, so it probably is the right P/N

This is from your website. Your comparing a bogus part, with different P/N to the one that is required. This would require a modification. I can understand an EASA company wouldn’t touch it, and an FAA company either. @Michael I guess this is a no-go for FAA as well, or can you install this if you find it eligible? If so, what is the use of PMA parts for example?

Peter wrote:

flap relay (€300 and on a very long lead time versus €20 from Mitsubishi in Japan)

I have a quantity of the HG2-DC24V, for sale (no 8130-3 etc). These are the original relays which have the higher grade cadmium plated contacts which were banned in Europe… US$60.00 each plus delivery which by airmail would be $20 to most places.

Can not comment, could be standard part, if so it wouldn’t require an EASA Form 1. An approved modification would be a possible solution here as well. Yours could be bogus parts as well. I do know at least two companies which have these relays on stock / original Socata.

Peter wrote:

a tachometer (€1000 versus €300 removed working from another aircraft)

What is the difference here? Could be installed in other FAA aircraft when removed from FAA aircraft, could be installed in on EASA aircraft if removed from other EASA aircraft. Could go from FAA to EASA with additional paperwerk or from EASA to FAA with additional paperwork.

Peter wrote:

a Floscan 201B fuel flow sensor (€1000 with a Form 1, versus €100 from Floscan)

Floscan sales non aviation and aviation parts. The aviation parts are not 1000 Euro, and not and their resellers either. Why do you need an EASA Form 1 for this? An 8130-3 from floscan would be fine.

You can not just substitude parts. For example, on a Thielert diesel engine you can not install Bosch / Mercedes fuel injectors, these are different and not the parts that are called for. Sure you CAN install them as bogus part.

JP-Avionics
EHMZ

Guillaume wrote:

Replacement of tachometer is covered under EASA CS-STAN. A wide range of tachometer is available. You can have a NEW TSO tach with 8130 for ~ 350€ and install it on an EASA reg aircraft.

Two other excellent examples from Guillaume.

JP-Avionics
EHMZ

Not the same tacho, as the original, however. What you are saying is that there is a €350 tacho which is legal to install.

That gear pump was eventually the same part, but with a different label. So, another can of worms If you run an aviation mfg+parts business, you will of course put different labels on, for exactly this reason (to make OEM identification harder, and to ensure sales of ones with your label).

The same issue with the Crouzet squat switches. The Socata ones have a connector (a cheap AMP one) attached And of course have a different sticker.

So where does this take us?

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

Not the same tacho, as the original, however.

CS-STAN covers that, either replacing it by the same, or an equivalent part

Peter wrote:

That gear pump was eventually the same part, but with a different label. So, another can of worms If you run an aviation mfg+parts business, you will of course put different labels on, for exactly this reason (to make OEM identification harder, and to ensure sales of ones with your label).

You can not prove that, as such under EASA it we be a bogus part. I do think the FAA would have a different opinion on that. Else the whole FAA-PMA doesn’t make sense.

Now this FAA-PMA is a IMHO major difference with EASA, where under EASA you can get stuff approved under minor change for small modification. You can not sell it to USA market as there is no bilateral agreement. While FAA-PMA are accepted under EASA. So it would be great for European aviation industrie if EASA would setup a EASA-PMA system, based on the FAA-PMA system. As that is much more affordeable for smaller items (Flarm, Garrecht traffic systems, Golze WX solutions, our own products etc).

JP-Avionics
EHMZ

You can not prove that

Well, yes and no, and this is a neat trick, don’t you think? Aircraft manufacturer X could buy in some item (which is avalable from the OEM with a CofC) and by sticking a sticker on it with a different P/N they make it a “different part”. Job done. Substitution not permitted under EASA!

So the reason for the stickers is not just to make the OEM parts harder to locate. It makes them illegal to use, if the reg requires the “same” part.

In most cases you can prove it is the same part. This is a popular activity in GA You could even buy both and take them apart. Still, they will be “different” parts, because of the stickers!

It gets even better if you can locate a higher-spec part e.g. a Stancor ground power relay whose N/C contact is a higher rating, to carry the starter motor current which Socata forgot is passing through the N/C contact. Can’t fit that either – not the same sticker.

CS-STAN covers that, either replacing it by the same, or an equivalent part

Yes, a different product. I too established that I can legally replace the 3.125" Swiss made tacho (no longer made… interesting…) with a 2.25" one from EI, under an FAA AML STC. At the time I wanted to move the tacho to the smaller location. But that’s a different discussion. I was talking about replacing the same tacho, with the same one, even same label (!) but without a Form 1.

Administrator
Shoreham EGKA, United Kingdom

Jesse wrote:

No critical parts (no primary structure, no flight controls, no life limits) can be considerd for this, if they meet the other requirements as well. It requires they aircraft owner to take full responsbility for such parts though.

Ok, Jesse, going back to my story. The seats aren’t part of the primary structure, not part of the flight controls, aren’t under any life limits – so why has my Part 145 maintenance unit said that

‘If we haven’t taken them out of the donor aircraft or if they don’t have a Form 1, we are refusing to have them installed / signed off and will refuse your ARC’ .

Now bearing in mind I know they are original Cirrus parts, they fit my plane, they are airworthy, I’m prepared to take responsibility for them – but no, the maintenance director will refuse to sign it off without the correct paperwork.

If you can point me in the right direction of legislation which says that non critical parts don’t need a form 1, I’d be grateful…..

EDL*, Germany
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