MAG Change 6 — Some Gains but a Long Way to Go
Editor’s Note: To see all of ARSA’s work on the MAG, visit arsa.org/mag.
On June 1, the FAA and EASA released Change 6 to the U.S.-EU Maintenance Annex Guidance (MAG CHG 6). MAG CHG 6 includes some amendments sought by ARSA and its industry partners relating to the need for Form 8130-3 for new parts subject to the MAG (i.e., those installed in dual release repairs). Regarding this issue, MAG CHG 6:
(1) Includes a fabricated parts exception from the Form 8130-3/EASA Form 1 requirement.
(2) Removes the term “OEM” and “PC holder” from MAG CHG 5, replacing them with the more appropriate “production approval holder” (PAH).
(3) Removes the requirement that a component must be referenced in the type certificate holder’s Illustrated Parts Catalogue for it to be acceptable for installation.
MAG CHG 6 does not affect the Oct. 1, 2016 implementation date when Form 8130-3 must accompany new parts released by a PAH. Unfortunately, MAG CHG 6 restated the following note included in the agencies’ April 14 letter to ARSA and Notice 8900.360:
NOTE: New parts that were received into inventory prior to Oct. 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. These parts in inventory, documented with the required information, will be grandfathered and remain suitable for installation into EU articles, provided the certification/release date of these parts is prior to Oct. 1, 2016. (emphasis added)
ARSA and its industry partners will continue to seek changes to the note, which imposes unreasonable restrictions on the use of some airworthy inventory (e.g., new airline surplus parts received without PAH documentation) in dual release repairs. In addition, the industry group is working closely with the Aircraft Certification Service to speed up the implementation of sec. 21.137(o) allowing PAHs to issue Form 8130-3 as an Authorized Release Document and clarify Order 8130.21H relating to the use of Form 8130-3 for export.
To view change 6, click here.
For additional updates relating to the MAG, visit arsa.org/mag.
For more on the effort to effectively implement 21.137(o), visit arsa.org/production-certificates