This page contains a Flash digital edition of a book.
GUEST OPINION COLUMN


BY JASON DICKSTEIN


NEW US-EC AGREEMENT AFFECTING AIRCRAFT PARTS


W


elcome to a bold new era of aerospace transactions between Europe and the United States. The United States and the European Community (EC) have


signed a new Bilateral Aviation Safety Agreement (BASA) that replaces existing agreements between the U.S. and certain European nations and replaces it with an agreement that spans the entire European Community. Prior to the new agreement, the U.S. had several agreements with EC member nations, and other nations accepted U.S. -sourced aircraft parts as if they were also parties to those agreements. This new BASA clarifies the legal status of transactions that occur between the majority of the EC and the United States.


In some cases, the new agreement will make no changes to the status quo. For some categories, it may reflect some minor changes in the way that companies do business. Purchasers in both the U.S. and in Europe need to be aware


of the requirements mandated by the new agreement. Before installing any part that was imported from the U.S. or Europe, installers need to confirm that the part complies with the rules established by the agreement, as well as the domestic airworthiness rules that apply to the aircraft based on country of registry.


Requirements for Parts Imported Into the U. S. What should you expect if you are located in the U.S. and buying parts made under European production authority? You should expect to see an EASA Form One with the part or product. In some cases, where an EASA Form One is mentioned, it is also possible to see a JAA Form One if the article was tagged before the change-over to EASA Form One. Previously, the U.S. had not agreed to accept EASA Form Ones issued in any nation other than the six original BASA nations in Europe, although normal practice dictated that other EASA Form Ones would be accepted for airworthiness certification when issued elsewhere. The new standard extends privileges across the European Community, although it is important to look at the details because different European nations may have subtly different requirements. For example, Romania has authority to export sail planes and very light aircraft to the U.S. (and the U.S. would accept the EASA certifications for such aircraft) but not to export transport category aircraft to the U.S. (that is, the U.S. would not be obliged to accept the airworthiness documentation for such an airplane from Romania). Where the U.S. accepts an EASA Form One, it will also usually accept a JAA Form One that was issued before September 28, 2005. For any new aircraft there will be an EASA Form 27 certificate for the aircraft. For any new aircraft engine or propeller there will be an EASA Form One certificate on the engine or propeller. This certificate verifies conformity to approved design as well as verifying that the product is in a condition for safe operation (including compliance with all airworthiness directives).


48 Aviation Maintenance | avmain-mag.com | June / July 2011


All new aircraft engines and propellers shall have an EASA Form One attached with the following statement: “The [INSERT Aircraft Engine or Propeller Model] covered by this certificate conforms to the type designs approved under U.S. Type Certificate Number [INSERT TYPE CERTIFICATE NUMBER and REVISION LEVEL], is found to be in a condition for safe operation and has undergone a final operational check.” For new TSO appliances that have been granted a FAA letter of TSO Design Approval there should be an EASA Form One validating the conformity and condition of the appliance. There should be a reference to the FAA letter of TSO Design Approval in the remarks block of the EASA Form One. For new replacement or modification parts there must be a JAA or EASA Authorized Release Certificate (Form One) on those new parts. When properly completed, this Certificate certifies that each part is eligible for installation in a product or appliance that has been granted FAA design approval; and, conforms to FAA approved design data and is safe for use.


Requirements for Parts Imported into Europe The United States does not have specific domestic traceability requirements — most non-import airworthiness documentation requirements in the United States have arisen as a matter of common usage and commercial practice. In Europe, however, most 145 organizations are obliged to follow EASA 145.A.42, which imposes specific documentation requirements on different classes of parts. Thus, if you are in Europe and importing parts from the U.S. (or if you are in the U.S. exporting parts to Europe) then you need to make sure the parts meet the requirements of EASA 145.A.42 as a threshold. This is a practical requirement in addition to any obligations imposed under the bilateral agreement. For most parts sourced from the United States, a European importer should expect to obtain an 8130-3 tag. For new aircraft, there must be a certificate from the FAA (8130- 4). This certificate verifies conformity to approved design as well as verifying that the product is in a condition for safe operation. Every new aircraft engine, propeller, or rebuilt engine shipped to the European Union shall have an FAA Authorized Release Certificate (8130-3).


New TSO appliances including APUs granted ETSO or JTSO authorization will be accompanied by an 8130-3 tag that certifies conformance and condition, just like the 8130-4 does for aircraft. The designee will check for compliance with European ADs and will reference the ETSO/JTSO number in block 13 of the tag before issuing it.


For new modification or replacement parts there must be a


FAA Form 8130-3 verifying that the part is eligible for installation in a product or appliance which has been granted an EASA design approval, that the part conforms to design data approved by EASA and is safe for installation. In practice, the 8130-3 generally confirms that the part is in compliance with FAA- approved standards for a product design that was also approved by EASA.


Page 1  |  Page 2  |  Page 3  |  Page 4  |  Page 5  |  Page 6  |  Page 7  |  Page 8  |  Page 9  |  Page 10  |  Page 11  |  Page 12  |  Page 13  |  Page 14  |  Page 15  |  Page 16  |  Page 17  |  Page 18  |  Page 19  |  Page 20  |  Page 21  |  Page 22  |  Page 23  |  Page 24  |  Page 25  |  Page 26  |  Page 27  |  Page 28  |  Page 29  |  Page 30  |  Page 31  |  Page 32  |  Page 33  |  Page 34  |  Page 35  |  Page 36  |  Page 37  |  Page 38  |  Page 39  |  Page 40  |  Page 41  |  Page 42  |  Page 43  |  Page 44  |  Page 45  |  Page 46  |  Page 47  |  Page 48  |  Page 49  |  Page 50  |  Page 51  |  Page 52  |  Page 53  |  Page 54  |  Page 55