SUMMARY:
The Federal Aviation Administration has published Notice N 8900.336 addressing the U.S./EU Maintenance Annex Guidance, Change 5 requirements for the FAA Form 8130-3 from production approval holder.
MAJOR HIGHLIGHTS:
On Sept. 9, 2015, the MAG, Change 5, was signed. Generally, FAA-certificated air agencies holding EASA certification must comply with the requirements of a revision within 90 days of the effective date (implementation date Dec. 8, 2015). Change 5 of the MAG introduced a change to Section B, Appendix 1. The amendment to that section reinforces (and in many cases, established) the requirement that U.S.-based repair stations receive FAA Form 8130-3 for all new parts that will be installed in articles for which a dual release is to be issued.
Since the publication of the MAG (without the opportunity for public comment), the Aircraft Electronics Association, along with a large contingency of aviation associations, petitioned for a delay in the implementation of the guidance to better align with the Oct. 1 change to Part 21 allowing production approval holders to issue FAA Form 8130-3 as the Airworthiness Release Certificate after March 29, 2016. In addition, there are a number of topics that also needed clarity.
As a result, the FAA has issued N 8900.336, which publishes the joint position of the FAA and the EASA that a transition period for the mandatory requirement for the issuance of FAA Form 8130-3 for new parts and required by the MAG, Change 5, will be extended to align with Part 21, Amendment 21-28. Therefore, components released by the PAH, prior to the new implementation date of April 1, 2016, will not be required to be accompanied by FAA Form 8130-3. Only those components released from a PAH's quality system, on or after that date, must be accompanied by FAA Form 8130-3 if intended to be installed on articles subject to the FAA/EASA BASA.
In addition, the parts currently in inventory and appropriately documented with the required information will be grandfathered and remain suitable for installation into EU articles provided the date on the document is prior to April 1, 2016. The documentation for new parts currently in inventory or received prior to April 1, 2016, must, at a minimum, have a document or statement (containing the same technical information as an FAA Form 8130-3) issued by the PAH or supplier with direct ship authority.
AEA COMMENTARY:
Since the publication of the MAG 5, the AEA has received a number of requests for clarification. The association is continuing to work with the FAA and the EASA to assure a better understanding of the requirements. The AEA will publish more information as it becomes available.
FOR MORE INFORMATION:
Contact Ric Peri, AEA vice president of government and industry affairs, by email at ricp@aea.net or by phone at 202-589-1144.