Join ARSA Ask ARSA Pay ARSA

MAG Change 5: FAA, EASA Confirm 8130-3 Requirement Extension

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

On April 20, ARSA received a letter dated April 14 from the FAA and EASA confirming the postponement of the “new” parts documentation requirement imposed on U.S.-based production approval holders by change 5 to the U.S.-EU Maintenance Annex Guidance. The letter arrived after an April 1 email from the FAA to its aviation safety inspectors originally announced the extension (see “No Joke” below).

The letter recounted months of action by a coalition of aviation groups led by ARSA and noted the provision’s effective date was originally delayed four months to accommodate the needs of U.S. PAHs. Having earned the original extension from Dec. 8, 2015 to April 1, 2016, the association joined a chorus of aviation stakeholders in persuading both agencies that industry circumstances demanded another postponement.

“[In March 2016], at the occasion of ARSA’s Annual Repair Station Symposium,” the letter noted, highlighting the broad engagement by the maintenance community on the issue, “[Managing Director and General Counsel Marshall S. Filler] informed us that the actual implementation of the provisions/privileges contained in Title 14, Code of Federal Regulations § 21.137(o) was taking much longer than expected and that the extended deadline of April 1, 2016 was not allowing most of the PAHs to get the required approval under § 21.137(o) by their supervising Manufacturing Inspection District Offices (MlDOs).”

In addition to the concerted efforts put forth by the 13 trade associations represented on the original Oct. 7, 2015 letter (see “Aviation Coalition Requests Orderly Transition Period” below), both agencies received repeated requests from industry members for more time to institute the privileges of § 21.137(o). While the entire aviation community should be relieved to have another extension, much work remains to fully implement the privileges of § 21.137(o).

To read the full letter, click here.



More from ARSA

Correct STC Oversight Problems

STC holders should take advantage of summertime opportunities to highlight FAA oversight issues to government auditors. Congress’ May 2024 reauthorization of the FAA, required the Department of Transportation’s Office of Inspector…Read More

Substitute Teaching

On May 30, ARSA Vice President of Operations Brett Levanto visited with three classes of sixth grade students at Bush Hill Elementary School in Alexandria, Virginia. Levanto was making good…Read More

Mourning with a Colleague

On May 22, a Cessna Citation 550 crashed in San Diego, California. On May 25, the San Diego Medical Examiner confirmed that among the aircraft’s passengers was Kendall Fortner, the…Read More

AMT Day – Celebrate Charlie

Charles Taylor, the Wright Brothers’ mechanic and father of aviation maintenance, was born on May 24, 1868. Now – 157 years later – we celebrate him through continued commitment to…Read More

A Future Better than Yachting in the Caribbean – 2025 Scholarship Winner Daniel Lucerne

Meet ARSA’s 2025 Scholarship winner Daniel “Danny” Lucerne of the Atlanta campus of Aviation Institute of Maintenance. Lucerne’s interest in aviation was stoked while yachting (as crew) in the Caribbean.…Read More
ARSA