Documents for Aircraft Parts

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 the same of both covering all bases and preserving the aeroplane's market value.

Traceability

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.

U.S. sourced parts fitted to an N-reg

In general, a suitable certificate showing traceability is required. The commonly used 8130-3 form (example on page 1 of this PDF) 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.

There is obviously a grey area regarding just how trivial a part needs to be before traceability documentation is no longer required. In practice, small parts like instrument panel screws are routinely regarded as exempt.

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.

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 installation 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 will draw attention.

The Future?

EASA Part M Maintenance is due to come in September 2008. This will introduce 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.

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, since some level of local maintenance oversight is virtually certain for political reasons. Obtaining EASA acceptable documents for major items (e.g. an 8130-4) is highly recommended; your FAA maintenance facility is not going to do that unless specifically asked.

An alternative viewpoint concerning a forced transfer to G-reg is that the UK CAA always requires an Export Certificate of Airworthiness for the whole aeroplane for such a transfer, and this Export CofA will cover all parts in it, including for example an overhauled engine.

Last edited 19th November 2008.

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