Documents for Aircraft Parts
This article was originally written in 2010.
This is a rather tedious subject, normally dealt with by one's maintenance organisation. However, it is worth a bit of an aircraft owner's time to learn at least a little bit about it, because the ability (particularly of an N-reg owner) to source parts (both new and overhauled) directly from the USA, and have them fitted by an A&P and signed off by an IA, can be a major cost saver over the traditional supply route via the UK distributor etc.
The downside of this capability is that if the aircraft is to be later transferred to a European register, there could be major problems with the issue of the CofA if the appropriate documentation on the parts in question is not available. This is a trap worth avoiding, given the small but constant uncertainty concerning the future of N-reg aircraft in Europe, for covering all bases and preserving the aeroplane's market value.
Recent developments in Europe (EASA Part M) are still fluid in the way they are interpreted by various organisations or CAA inspectors. However it appears clear that when an aircraft is initially placed on a European register, its paperwork is examined all the way back to birth and anything not supported by documentation either has to be ripped out, or recertified by an EASA company with the appropriate authority. This can be hugely expensive. To make matters worse, some over-zealous CAA inspectors have been implementing this back-to-birth policy on aircraft being issued with the initial Part M certificate but which were always on the UK register; this is another reason to keep all paperwork for ever.
The general requirement for aviation parts is traceability. This enables a defective part to be traced all the way back to the manufacturer, enabling the recall of an entire potentially defective batch. It is also intended to prevent the use of inadequate-specification or outright counterfeit parts. So, each part should be accompanied by the appropriate documentation, and this documentation must be retained after the part has been installed.
The suprising bit is that the legal requirements under both FAA and UK CAA do not generally specify any particular form for the documentation. So, while someone may say that e.g. an 8130-3 or EASA-1 form is mandatory, in reality it probably isn't and any documentation which supports the traceability requirement will do. This is particularly the case for the countless small parts on an aircraft - small screws, pipe fittings, etc - which are traditionally accompanied by a Certificate of Conformity and which (dut to the nature of the aviation supply chain) would not normally come with other documentation.
Update 12/2016: over the past few years, EASA has pushed the industry towards a mandatory EASA-1 form for most items. Obviously this is great business for aviation parts suppliers. However, with the ELA1/ELA2 system (a somewhat relaxed maintenance regime for privately operated aircraft below 2000kg) there is now a relaxation of the EASA-1 form requirement, documented here and here. These don't go very far though... the restrictions are significant and the vendors get around the "same part" concession by labelling the "aviation versions" differently, so that one cannot use the commercial part even if it is provably identical.
U.S. sourced parts fitted to an N-reg
In general, a suitable certificate showing traceability is required. The commonly used FAA 8130-3 form (example guidance notes editable version) is desirable but not mandatory; indeed many smaller U.S. vendors either cannot supply it (because they don't have an in-house person authorised to sign it) or they charge extra for it. The regulations are in FAA Order 8130.21. For parts sourced in Europe, a JAR-1 or EASA-1 form meets FAA requirements too.
The potential problem is if the N-reg might later be transferred to G-reg. You may never intend to do this but if the aircraft has had parts fitted not supported by documentation acceptable in Europe, this can impact its market value. In that case, if you take care to get an 8130-3 for everything, that should be fine for all new parts except Class 1 components (engine and propellers) which ought to come with an 8130-4 Export Certificate of Airworthiness. Trivial items (e.g. small screws) ought to come with some kind of documentation too but in practice this doesn't matter, not least because nobody notices them. The following notes will be relevant.
U.S. sourced parts fitted to a G-reg
The UK CAA document covering this is Airworthiness Notice 14 (AN14) (local copy, 2007) and this specifies nothing more than "the component shall be accompanied by an appropriate release certificate from the state of export following maintenance in that state and prior to fitting to the UK registered aircraft". An 8130-3 form has customarily been OK for this purpose, although not for aircraft operated for Public Transport. Normally, "Public Transport" means an AOC, particularly as under current EASA regs the CofA is the same and it is the actual maintenance regime that determines whether the aircraft may be used for Public Transport. Update 12/2016: see the above notes under Traceability - this situation has changed.
There is a distinction between new and used parts. Note that an overhauled engine or propeller is a "used" part, even if you have owned it all along! On used parts, AN14 states
Prior to 28 September 2008 where it is intended to fit used components which have been maintained in a state other than the United Kingdom to an aircraft, in accordance with this Airworthiness Notice, the component shall be accompanied by an appropriate release certificate from the state of export following maintenance in that state and prior to fitting to the UK registered aircraft. For Class 1 components (engines 31 October 2007 Airworthiness Notice No. 14 Page 6 of 6 and propellers) an export statement is required (e.g. from the USA, a Form 8130-4 for Class 1 components and Form 8130-3 for all other used components). After 28 September 2008 all used components fitted to UK-registered aircraft must be in compliance with Part M Subpart E.
So, for non-Class 1 parts, an 8130-3 is sufficient but apparently not mandatory. Class 1 parts do need fancy paperwork, however. The FAA form 8130-4 is an Export Certificate of Airworthiness; example on page 2 of this PDF. The 8130-4 needs to be signed by an FAA DAR (a Designated Airworthiness Representative) who charges around $200 in the USA. In the UK, an FAA DAR charges in excess of £1000! To be safe, anybody purchasing a new or overhauled engine from the USA ought to obtain an 8130-4 form for it even if fitting to an N-reg.
Dual Release: There are many companies in the USA which have JAA/EASA approval. These companies can issue an 8130-3 form which carries the company's EASA approval number, and such an 8130-3 form is as good as an EASA-1 form. In this case, the 8130-3 form is good enough for a Class 1 component too. The major engine manufacturers have EASA approvals nowadays but there was a hilarious temporary situation when Continental did not have this, so while one could install a new engine in a G-reg, one could not have the same engine overhauled by Continental because it was a "used" part!
Another weighty tome on this is the UK CAA CAP562 (2008 local copy) which gives the rundown in Leaflet 1-12 para 4 (page 174 of the PDF). This generally supports AN14 but with extra complications.
On a certified aircraft there are, apparently, none. Even a toilet door handle on a 747 has to be traceable all the way back. However, for trivial parts (e.g. instrument panel screws, or the aforementioned door handle) the traceability paper trail is obviously ridiculous. One would spend half a day (billed to the customer) copying through the various document references from one's bulk screw stock to the job-pack documentation. Most maintenance organisations simply ignore this nonsense for trivial items like that.
Generating New Paperwork
It is possible to generate fresh paperwork for any item which did not come with any. The process depends on the item, and is surrounded by grey areas and all kinds of "industry practices".
For small items, it is just an inspection - what else could you do with a toilet door handle? This is how the airliner salvage business works; they strip down a 747 and each usable part is inspected and fresh paperwork is generated for it.
Larger items need to be "overhauled", which means different things; with an engine it may actually mean a real overhaul, but with say an aileron it might mean replacing one rivet and a visual inspection. This isn't cheap because the company doing it spent a lot of money getting the authorisation to generate a fresh EASA-1 form; 4 digits for what was actually just an inspection is not unusual.
The moral of this story is: keep every single scrap of paper; every invoice, delivery note, certificate, the lot. And keep it for ever. You never know when you will need it. Aircraft maintenance is necessarily done on trust - a maintenance company is not normally going to query whether some modification done 10 years previously was correctly documented - but when an aircraft is being placed on a new register, an inspector goes through everything, and anything that looks out of place or otherwise draws attention is going to have its documentation examined.
EASA Part M Maintenance arrived in September 2008. This introduced new requirements and few people yet understand it well. On the face of it, it looks like recognition of FAA certification will be a bigger problem than under the UK CAA, but the reality of aviation is that nearly everything is made in the USA anyway, and EASA will have to find a way to deal with this. EASA subcontracts certification to the old local CAA offices around Europe and their inspectors are busy making up regulations as they go along!!!
Here (local copy) is a slightly interesting document which around page 9 details the requirements for used components: an 8130-3 is required initially and then an EASA Form 1 must be generated - this implies that any used component fitted to an EASA-reg aircraft needs to be processed by an EASA 145 company. This makes the importation of most used parts uneconomical. The interesting question is whether this also applies to getting your own parts (e.g. an engine) overhauled in the USA.
There are reports of a new EASA-FAA treaty for mutual STC recognition. This will be good news, of course, but it doesn't help with PMA parts or with field modifications done either as minor mods, or as major mods with an FAA 337 form.
N-reg owners are able to operate outside EASA requirements so long as they comply with FAA requirements, but the need to keep the paperwork straight is going to be at least as important as in the past, not just to maintain market value but also because some level of "local maintenance oversight" is likely for Euro-political reasons. Obtaining EASA acceptable documents for major items (e.g. an 8130-4) is highly recommended; your FAA maintenance/overhaul facility is not going to do that unless specifically asked.
In the case of a transfer to G-reg, the UK CAA always requires an Export Certificate of Airworthiness for the whole aeroplane, and this Export CofA (which is done under bilateral agreements) will cover all parts in it, including for example an overhauled engine. This is a complex subject but for example the DAR performing the Export CofA will accept any work done by an FAA Repair Station. Work done under the "owner manufactured parts" concession will not be acceptable for export, however.
Update 5/2010: The FAA no longer exports engines and propellers with an Export CofA. The UK CAA now accepts these items with an 8130-3. The CAA leaflet is here (local copy). This makes it a lot easier to get engines and props from the USA.
Update 11/2015: There have been many changes since this article was
written in 2010. For example EASA is accepting FAA-PMA parts - here
subject to some restrictions - local copy. It is recommended that you post a question on EuroGA, for current information.
Update 12/2016: some more changes, for ELA1/ELA2 - see notes above under Traceability.
Last edited 30th December 2016
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