No Joke: FAA, EASA Extend 8130-3 Requirement
Editor’s Note: To see all of ARSA’s work on the MAG, visit arsa.org/mag.
The “new” parts documentation requirement imposed on U.S.-based production approval holders by change 5 to the U.S.-EU Maintenance Annex Guidance has once again been postponed.
On April 1, the FAA notified its aviation safety inspectors via email (see below) that, in cooperation with EASA, the agency has agreed to delay the implementation of the FAA Form 8130-3 requirement. The new effective date is Oct. 1 – six additional months to fully realize the benefits of the new 14 CFR § 21.137(o) (to read about ARSA’s efforts specific to the new privilege, visit arsa.org/production-certificates). A notice confirming the extension is expected in the near future.
Since the September 2015 release of MAG Change 5, ARSA has been the industry leader on multiple efforts to “smooth” its implementation and prevent disruption of international maintenance operations. Having earned the original extension from December 2015 to April, the association persuaded both agencies that industry circumstances demanded another postponement. While we are relieved to finally have agreement, much work remains to fully implement the privileges of § 21.137(o).
It may be April Fools’ Day, but for once the joke is not on maintenance providers. Stay tuned to ARSA as the situation unfolds. For a complete history of the association’s efforts since the September 2015 release of MAG Change 5, review the content below.
From: Logan, Cindy (FAA)
Sent: Friday, April 01, 2016 7:23 AM
To: 9-AWA-AFS-300-Maintenance (FAA)
Subject: FYI from the AFS-300 Management Team — April 1, 2016 >> FAA Notice 8900.336 FAA Form 8130-3 requirements <<
Good Morning Everyone…
This email is provided as interim notification.
Since the release of the Maintenance Annex Guidance (MAG) Change 5, between the United States and the European Union (EU), many concerns were raised by U.S. repair stations regarding changes contained in Section B, Appendix 1, paragraph 10: “Release and Acceptance of Components,” and the timelines established. Industry stakeholders recommended that the MAG be aligned with the changes in part 21 set forth in Amendment 21-98, which became effective on March 29, 2016. The alignment would allow PAHs in the U.S. to establish a process in their quality systems to issue an authorized release using FAA Form 8130-3 for new parts. Other concerns include what provisions could be made regarding components received prior to that date.
On November 17, 2015, the FAA issued FAA Notice 8900.336, aligning the requirements of MAG CHG 5, Section B, Appendix 1, paragraph 10, with the effective date of the part 21 Amendment 21-98. Unfortunately, implementing the changes to part 21 set forth in Amendment 21-98, i.e. 21.137(o) is taking longer than stakeholders expected. Both FAA and EASA were asked by several industry stakeholders to extend the implementation date of MAG CHG 5 requirements specified above (specifically Section B Appendix I, Paragraph 10).
To allow implementation of the privileges under 21.137(o) to the greatest extent possible, FAA and EASA agreed to extend the implementation deadline specified in FAA Notice 8900.336 from April 1, 2016 to October 1, 2016. All other provisions of MAG CHG 5 remain in effect.
FAA Notice 8900.336 is undergoing revision and will address this change and will be issued as soon as coordination procedures are complete.
This message was sent to Principal Maintenance and Avionics inspectors and Office managers. While our list is extensive it may not touch everyone, please distribute as necessary.
Have a GREAT weekend!
Management and Program Analyst, AFS-310