A group of trade associations and aerospace companies led by the Aeronautical Repair Station Association (ARSA) has requested that the directors of the FAA’s Flight Standards Service and EASA revise the guidance on international parts documentation. Since last September, the association and its allies have worked to help the agencies correct regulatory issues created by the 2015 revision of the Maintenance Annex Guidance (“MAG Change 5”) to the U.S.-EU Bilateral Aviation Safety Agreement.

The nine-month-long effort deals with the requirement that U.S. Production Approval Holders (PAH) issue FAA Form 8130-3 with all new parts for which a dual maintenance release will be issued. The privilege to issue that form was created in FAR 21.137(o) last October. Since that time, the FAA and EASA have issued two extensions to give the agency and industry time to comply, but the extensions include a note indicating parts released by a PAH before Oct. 1, 2016 will remain suitable for installation on EU articles only if they have appropriately dated documentation from the PAH containing the same technical information as an FAA Form 8130-3. ARSA maintains that requirement is problematic for a host of reasons.

Brett Levanto, v-p of operations for Obadal, Filler, MacLeod and Klein, PLC (the firm that manages ARSA), told AIN, the point is to not “put industry in the position of having to invest months getting a parts documentation requirement correct. This letter is a great example of industry coordination and engagement—a united effort to produce common sense regulation—but it's also a reminder of the time and consternation that could be saved by truly reciprocal acceptance of international regulatory regimes. The central issue is to help the FAA and EASA rely on its already dependable systems for ensuring airworthiness.”