Industry Gives FAA a Commercial Parts Solution
August 16, 2017
To see all of ARSA’s work on the MAG, visit arsa.org/mag.
On Aug. 8, ARSA and its allies provided the FAA a method to address international issues created by the regulatory definition of “commercial parts.” Led by the association, a coalition of 13 aviation stakeholders – both industry associations and private businesses – submitted a draft notice dealing with commercial and commercial-off-the-shelf (COTS) parts in the context of change 6 to the U.S.-EU Maintenance Annex Guidance (MAG).
Under the United States’ regulatory framework, parts defined as “commercial” by 14 CFR § 21.1(b)(3) do not normally receive FAA Form 8130-3 from a production approval holder (PAH). The same is true for so-called COTS parts, which are not included in the § 21.1(b)(3) definition. This causes problems for manufacturers, distributors and maintenance providers.
Industry representatives raised the issue with the agency in a Feb. 7 letter to the heads of both the Aircraft Certification and Flight Standards Services. In that original request as well as an April follow up, signatories urged the American regulators to sort out the issue with their European counterparts. Absent such action, the group submitted its draft notice based on subsequent discussion with the FAA.
Similar to Notice 8900.380 (which was recently extended by Notice 8900.429, see “Critical Alternative” below), the draft notice on commercial and COTS parts would allow U.S. repair stations to perform a part 43 inspection and issue Form 8130-3 with a right-side signature for new commercial and COTS parts received without an Authorized Release Document (ARD). However, instead of establishing traceability to a PAH (as required by Notice 8900.429), the repair station would be required to establish traceability to an approved design and suitability for installation. This would only apply to commercial and COTS parts.
To read the full submission, which includes the draft notice and the Feb. 7 and April 18 industry letters, click here.
In addition to ARSA, the submission was supported by:
Aerospace Industries Association
Aircraft Electronics Association
Airlines for America
Aviation Suppliers Association
Cargo Airline Association
General Aviation Manufacturers Association
Helicopter Association International
National Air Carrier Association
National Air Transportation Association
The Boeing Company
Gulfstream Aerospace Corporation
MOOG Aircraft Group
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