Concerning the requirement to retain EASA Form 1 certificates for on-condition components?
The challenge here is that it is potentially possible for release documentation to provide an auditable trail for on condition components – however the regulatory driven need to retain this information is quite limited.
There is no specific requirement to retain the EASA Form 1 of such components unless needed to comply with the requirements set forth in M.A.305 (h)(1), (h)(4), (h)(5) and (h)(6) for determining the continuing airworthiness and configuration of the aircraft.
We are in a better position here in one respect, that it is we are looking at a situation which can in fact be managed by the Operators Part M CAMO organisation. This requires a Lease Holder compliant retention policy to be adopted and implement. Clearly such a policy will be in excess of the EASA driven requirements, but never the less is totally achievable and with the remit of the Part M organisation.
Repair Considerations
When carrying out repairs in accordance with the SRM it is necessary to record in full details the depth and area dimensions of material removed during a blend out repair. This is important information and required to be able to assess in future whether further damage (adjacent or at the same spot) at a later stage would be allowable or not.
In addition, it supports a full audit trail and due diligence for future audits to validate that the damage was within limits.
Concerning acceptance of aeronautical parts.
Reference to (AMC M.A.501(a)5(a) /AMC 145.A.42(a)1(a))
Ref technical implementation procedures for airworthiness and environmental certification between the FAA and EASA – revision 5 September 15, 2015
As for the used products, parts, appliances, maintained by an FAA repair station holding an EASA part-145 approval in accordance with the BASA, the Maintenance Annex Guidance (MAG) Section B – Certification Process for U.S.-Based Repair Stations, Appendix 1, chapter 10 (item (b), explains that the FAA Form 8130-3 should include the EASA Part-145 release to service (typically called “dual release”) certifying statement with the EASA Part-145 Approval Certificate number in block 13, and specify any overhauls, repairs, alterations, Airworthiness Directives, replacement parts, PMA parts and quote the reference and issue/revision of the approved data used.
In Summary: the new component will require the FAA Form 8130-3, the used component will require the FAA Form 8130-3 with “dual release”.
Sofema Aviation Services provides a range of EASA compliant Aviation Regulatory and Vocational training for details please see www.sassofia.com or email office@sassofia.com
