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FAA Confirms Parts Documentation Privileges But Problems Remain

Editor’s Note: To see all of ARSA’s work on the MAG, visit arsa.org/mag.

Update: On Aug. 31, the FAA issued a revised Notice 8900.380 that clarified the language in paragraph 5.b(1) and (2) to confirm a repair station’s privilege of performing an inspection on any new part received without the documentation required by the MAG. The privilege applies regardless of whether the new part was received before, on or after Oct. 1, 2016. The agency retained the original issue date and Notice number; the revised document is available on the agency’s FSIMS web site at the link below:

http://arsa.org/wp-content/uploads/2016/08/n8900_380_20160831.pdf 

August 29, 2016

On Aug. 29, the FAA, in coordination with the European Aviation Safety Agency (EASA), issued Flight Standards Notice 8900.380 to Aviation Safety Inspectors (ASIs) with oversight responsibility for U.S. repair stations that hold EASA Part-145 certificates. The notice addresses two outstanding issues involving Change 6 to the FAA-EASA Maintenance Annex Guidance (MAG CHG 6).

First, the notice confirms that a repair station may inspect and approve for return to service any new part within its ratings that does not meet the MAG CHG 6 documentation provisions. This codifies a verbal agreement reached on June 17, 2016 at the Maintenance Management Team (MMT) meeting in Washington, D.C. with the FAA, EASA, other national aviation agencies (NAAs) and industry representatives. It confirms such inspections are to be handled like other maintenance activities; Notice 8900.380 describes the agencies’ expectations. (ARSA is developing a procedure that its members may use to accomplish these inspections.)

Second, the notice confirms that the implementation (i.e., compliance) date for the new parts documentation provisions of MAG CHG 6 is Oct. 1, 2016. Some ASIs have been requesting changes to EASA Supplements by Sept. 1, 2016 (90 days after MAG CHG 6 was effective or issued). Therefore, the Notice confirms the Oct. 1, 2016 implementation date for the parts documentation provisions.

“This is a fine step,” said Sarah MacLeod, ARSA’s executive director, noting that the FAA’s confirmation of a repair station’s right to approve a part for return to service is on a long list of the association’s victories related to the MAG’s requirements.  ARSA has worked tirelessly to “smooth” implementation of the MAG’s parts documentation requirements since September 2015. The association’s leadership has mitigated far costlier burdens on production approval holders (PAHs) and repair stations that must comply with these new requirements after Oct. 1.”

However, the effort to reverse course on this misguided policy is not over; the industry is awaiting further clarification regarding what parts will be ‘grandfathered” in accordance with the NOTE in MAG CHG 6. ARSA has asked EASA to adopt the reasonable definition of ‘grandfathered inventory.’

“All parts released by the PAH before Oct. 1 with the correct documentation should be grandfathered, period. To limit grandfathered parts only to those in a repair station’s inventory on September 30 instead of focusing on documentation received from the PAH is a wasteful step not only for the agencies but also every maintenance certificate holder, supplier, and customer,” MacLeod said.



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