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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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Presentation on theme: "AMP Meeting | February 20, 2014GAMA | Washington, DC F. FAA/EASA MAG 8130-3 Requirement for All New Parts."— Presentation transcript:

1 AMP Meeting | February 20, 2014GAMA | Washington, DC F. FAA/EASA MAG 8130-3 Requirement for All New Parts

2 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

3 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

4 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?

5 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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