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F. FAA/EASA MAG 8130-3 Requirement for All New Parts

F. FAA/EASA MAG 8130-3 Requirement for All New Parts. 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)

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F. FAA/EASA MAG 8130-3 Requirement for All New Parts

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  1. F. FAA/EASA MAG 8130-3 Requirement for All New Parts

  2. 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. 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. 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. 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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