The FAA and EASA’s most-recent update to the Technical Implementation Procedures issued under the agreement (TIP rev. 7.1) clarified language for acceptability of new modification and replacement parts consumed in maintenance for which an FAA/EASA dual release will be issued. ARSA has released an updated “New Article Inspection Form” template to support compliance by U.S. repair stations holding EASA approval under the U.S./EU bilateral agreement.
Association members should go to arsa.org/publications to request the complete set of “Tools for Members” containing the updated New Article Inspection Form.
Bilateral parts documentation controversy first arose in 2015. That year’s update to the Maintenance Annex Guidance (MAG) issued under the bilateral agreement included the requirement that new parts consumed in maintenance must possess an FAA Form 8130-3 issued by the PAH despite no regulatory authority in part 21 for issuance of the form. ARSA led a coalition of industry groups to first press the FAA for an orderly implementation of that authority under § 21.137(o) and then to provide for new article inspections under part 43.
When the FAA capitulated in 2022 and rescinded the acceptability of that inspection process, ARSA again pressed for working group action to re-establish parts documentation rationality. In a January 2023 letter, ARSA and its allies highlighted the problems resulting from the agencies’ confusion over MAG and TIP requirements:
“The agencies’ misinterpretation has resulted in the inclusion of improper, impractical, and unnecessary parts documentation requirements in the MAG. Repair stations are in an untenable position, squeezed on one side by [EASA] documentation rules for European Union PAH’s and on the other by the FAA’s regulatory system, which does not require an FAA Form 8130-3 for new parts…. As a consequence, new parts from U.S. PAH’s received without a Form 8130-3 are supposedly ineligible for installation in work performed under the MAG by U.S.[-based] repair stations. This has created considerable inefficiencies, undermined the effectiveness of the bilateral relationship, and added to challenges resulting from recent supply chain disruptions,” the letter said.
Paragraph 7.10.4.2 of the TIP now provides that except for critical PMA and life-limited parts which still must be accompanied by FAA Form 8130-3s, all other parts need to be:
… accompanied by documentation that ensures both traceability to the FAA-approved Production Approval Holder (manufacturer) of the part and conformity to its approved design. Such documentation has to be acceptable under the quality system required to comply with U.S. 14 CFR section 43.13 paragraphs (a) and (b), section 145.211(c)(1)(i). FAA Advisory Circular 145-9 provides additional information that can be used as an acceptable means to meet quality system requirements. Examples of this documentation are purchase orders, shipping documents, certificates or statements of conformity, part markings, technical or design data (or a combination thereof).
When documentation is missing, but part marking and/or technical or design data is available, ARSA’s New Article Inspection Form documents an inspection and determination, and provides the regulatory and guidance references supporting the assessment. The form is a component of the association’s Model Repair Station and Quality Manual (RSQM) system and is available for free to members in good standing.
To review the entire TIP rev. 7.1, click here.
For complete background on bilateral parts documentation issues, go to arsa.org/mag.
Association members should go to arsa.org/publications to request the complete set of “Tools for Members” containing the updated New Article Inspection Form.
