ARSA Flags Confusion Over New-part Validation Process
Some U.S.-based repair stations with European Union Aviation Safety Agency (EASA) approvals are getting pushback from that agency and the FAA on an approved method of showing a new part is traceable to the manufacturer, prompting the Aeronautical Repair Station Association (ARSA) to ask that FAA clarify its position.
The issue concerns E100 “New Article Inspection" forms, which repair stations can use when inspecting new parts that do not have certain documentation required by EASA. The form, created in 2016 by ARSA, addresses a U.S.-European Union bilateral guidance requirement that a new part being used on an aircraft that the bilateral applies to be traceable to the production approval holder (PAH). Usually, this is done with an 8130-3 airworthiness approval form, or tag. But many new parts shipped to repair stations do not come with one. The E100 form and related inspection process was developed to give U.S. shops a standardized way to validate new parts.
“The E100 form requires an extensive inspection process that assesses the part, its packaging, records, physical condition, identifying information, conformity with manufacturer data and other attributes,” ARSA explained.
The FAA in a September 2016 letter told ARSA that the E100 "is an acceptable method of compliance” with applicable FAA regulations "when inspecting new parts received without the documentation required by the FAA-EASA Maintenance Annex Guidance (MAG).”
EASA, which was consulted by ARSA during the E100 development process, took the position that while it prefers an 8130-3 from the PAH, the E100’s validity as an acceptable means of compliance is an U.S. regulatory issue.
Recently, however, some FAA inspections have been rejecting E100s as have EASA representatives conducting visits to U.S. shops. The news prompted ARSA to write Acting FAA Administrator Billy Nolen and ask that the agency reiterate its position on E100s—one that some shops have used to refute inspectors’ positions.
"In one case, an E100 form-related finding was subsequently withdrawn after the repair station provided the [September 2016] letter and additional explanation of why the practice was appropriate” under FAA regulations, ARSA noted in the April 7 letter.
"It is clear EASA would prefer that the FAA Form 8130-3 originate from the PAH; however, the U.S. regulations, the [bilateral’s] special conditions and the plain language in the MAG do not require that result,” ARSA wrote. "It seems that some FAA personnel are more committed to enforcing EASA preferences than the FAA regulations and the bilateral agreement’s special conditions. We are also concerned that FAA personnel below the level of division manager have apparently ignored FAA policy...issued six years ago.”
ARSA’s specific request to Nolen is "confirmation of ARSA’s position that the E100 form is still an acceptable method of compliance with the U.S. aviation safety regulations...and the MAG when inspecting new parts received without an FAA Form 8130-3 from the PAH.”