MAG Change 5: FAA, EASA Confirm 8130-3 Requirement Extension
April 20, 2016
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.
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