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Published byGeoffrey Moore Modified over 9 years ago
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AMP Meeting | February 20, 2014GAMA | Washington, DC F. FAA/EASA MAG 8130-3 Requirement for All New Parts
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AMP Meeting | February 20, 2014GAMA | Washington, DC 8130-3 For All Parts: Background FAA/EASA Maintenance Annex Guidance (MAG) Issued May 2011 2013 Audit Findings - New Parts Fitted During Maintenance Must Have an 8130-3 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 8130-3 for ALL Parts Administrative and Delegation Burden
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AMP Meeting | February 20, 2014GAMA | Washington, DC 8130-3 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 8130-3 Tag Required for All Parts, Provide Transition Period for Implementation by US Based 145 and PAH
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AMP Meeting | February 20, 2014GAMA | Washington, DC 8130-3 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 8130-3 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 8130-3 Will Work With EASA to Produce Written Clarification & Consider Time-Limited Transition/Deviation Options How Much Time is Needed by GAMA Members?
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AMP Meeting | February 20, 2014GAMA | Washington, DC 8130-3 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 8130-3
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