Mid-Month Member Asked: The U.S.-EU MAG and Parts Documentation
To see all of ARSA’s work on the MAG, visit arsa.org/mag.
This special edition of “a member asked” – a popular component of each hotline member newsletter – is provided as a service to ARSA members eagerly awaiting word from the FAA and EASA on documentation requirements for new parts already in inventory ahead of the effective date of the “new” 8130-3 requirement.
Q: What is the status of efforts to have the FAA and EASA change the statement below, which the agencies first sent to ARSA in an April 14 letter and then reiterated both in Notice 8900.360 and the newly-released MAG Change 6. This will affect the whole industry in a huge way if they leave it status quo.
NOTE: New parts that were received into inventory prior to Oct. 1, 2016 must, at a minimum, have a document or statement (containing the same technical information as an FAA Form 8130-3) issued by the PAH or supplier with direct ship authority. These parts in inventory, documented with the required information, will be grandfathered and remain suitable for installation into EU articles, provided the certification/release date of these parts is prior to Oct. 1, 2016. (emphasis added)
A: On June 17, ARSA joined representatives from the aviation maintenance community at a meeting with the FAA, EASA and ANAC. (Transport Canada Civil Aviation was invited but did not attend.) This was the first annual Maintenance Management Team (MMT) meeting modeled after the Certification Management Team (CMT) formed several years ago to address international certification issues.
During the discussion, industry coalition members requested the FAA and EASA remove the “NOTE” from their April 14th letter to ARSA (and later included in Notice 8900.360 and MAG Change 6) requiring that parts in inventory prior to Oct. 1 be accompanied by a document containing the same technical information as FAA Form 8130-3. Unfortunately, agency representatives indicated this requirement will not change.
For new parts in inventory prior to Oct. 1, a dated certificate of conformance or similar document from the production approval holder (or its supplier with direct ship authority) should be sufficient to comply with this requirement. As for the meaning of the phrase “same technical information as on Form 8130-3,” FAA and EASA representatives advised that they are looking for the part name, serial number (if applicable) and nomenclature.
With regard to new parts for which you don’t have the required documentation (either the grandfathered parts per the above Note or those released by the PAH on and after Oct. 1), the agencies agreed during the June 17th meeting to allow a repair station to perform an inspection in accordance with criteria that it develops and approve the article for return to service with a right side signature on the 8130-3. This is an administrative burden but it provides a safety valve for qualifying a part for use in a repair subject to the MAG. (On a related matter and in accordance with the FAA’s letter to ARSA dated August 25, 2015, repair stations that hold an appropriate rating for the top assembly being maintained are also rated to perform maintenance on sub-articles [i.e., piece parts] associated with that top assembly.)
These agreements will be formalized by their inclusion in the June 17 joint agency-industry meeting minutes. Industry representatives have prepared draft minutes which have been sent to agency representatives for comment and eventual adoption.