AMP Meeting | February 20, 2014GAMA | Washington, DC F. FAA/EASA MAG Requirement for All New Parts
AMP Meeting | February 20, 2014GAMA | Washington, DC For All Parts: Background FAA/EASA Maintenance Annex Guidance (MAG) Issued May 2011 2013 Audit Findings - New Parts Fitted During Maintenance Must Have an Tag (or equivalent) Significant Change in Interpretation/Application Resulting in a “New” Requirement for US Based EASA 145 Repair Station Contrary to Custom & Practice of Recognizing & Accepting FAA System for Parts Traceability – i.e. Certificate of Conformance Significant Impact on US Based EASA 145 and PAHs for ALL Parts Administrative and Delegation Burden
AMP Meeting | February 20, 2014GAMA | Washington, DC For All Parts: Status Meetings & Letter to FAA AFS/AIR-1 (June 2013) Position Not Intent of MAG to Change Past Practice Contrary to Principles of US-EU Agreement EASA Regulation 21.A.130 Specifically Recognize Form 1 Equivalent PAH Certificate of Conformance Equivalent to Form 1 Traceability Request Suspend All LOI/Certificate Action Pending Clarification Provide FAA Position on Interpretation Coordinate with EASA to Provide Written Clarification to Field If Tag Required for All Parts, Provide Transition Period for Implementation by US Based 145 and PAH
AMP Meeting | February 20, 2014GAMA | Washington, DC For All Parts: Status (Cont.) FAA Response (July/October 2013) MAG Interpretation for EASA 145 Up to EASA Part 21 Requires Form 1 – MAG Designates for US PAH FAA Interpretation of Part 21 & TIP All New Parts Exported to the EU System (e.g., to an EASA part 145 repair station) Require an Will Work With EASA to Produce Written Clarification & Consider Time-Limited Transition/Deviation Options How Much Time is Needed by GAMA Members?
AMP Meeting | February 20, 2014GAMA | Washington, DC For All Parts: Next Steps Informal “Transition” Already In Place Is This Still an Issue for GAMA Members? Is Further Action Needed? Future Rulemaking: Part 21 PAH Privilege to Issue