FAA 8130-3 Requirement For New Parts
Historically a repair station could repair components using new OEM parts without an 8130-3 for each of the piece parts and release the repaired component with dual FAA and EASA certification. With a recent rule change by the FAA, U.S. repair stations are no longer allowed to provide dual certification without each new part used in the repair having an individual 8130-3.
In order to simplify regulatory oversight across borders, both the FAA and EASA announced a joint strategy regarding documentation requirements for new aircraft parts. Change 5 to the Maintenance Annex Guidance (MAG) creates a clear requirement for a specific FAA Form – the 8130-3 – to be issued by production approval holders (PAH) whereas in the past, this was not required for domestic U.S. use. This FAA update, change 5, now requires that an 8130-3 form must accompany all new parts to be installed on components/parts for which a dual FAA-EASA maintenance release will be issued. However, under current FAA rules, only the agency or its designees can issue this document for a new part.
Recognizing the predicament, the FAA addressed this problem and will now permit PAHs to issue a Form 8130-3 without needing an FAA designee. Unfortunately, aerospace manufacturers could not implement this new quality procedure by the original compliance date of March 29, 2016 due to the lead time for changing procedures, manuals, and training for FAA audit compliance. This causes undue hardship and places U.S. repair stations in limbo regarding issuance of FAA 8130-3 dual compliance documentation without having a PAH issued FAA 8130-3 for new parts installed during the repair process. In essence, U.S. repair shops will not be able to ship their dual release units for export without the new part tags from the manufacturer.
Therefore, the FAA has extended the new part documentation requirement for PAHs until October 1, 2016. AVITAS understands that parts that have technical document information issued by the PAH or supplier with direct ship authority and dated prior to April 01, 2016 have been grandfathered. AVITAS understands that the grandfathering of these parts will also be extended to October 1, 2016.
While both the manufacturers and the FAA are diligently working on implementing the new part process, this also brings up the questions related to aftermarket and PMA parts. AVITAS understands this may potentially be answered in Change 6 to the MAG.
Watch this space, as it is AVITAS’s opinion that the October 1, 2016 time frame may possibly be extended again if all manufacturers don’t have their quality procedures fully implemented for continuous flow of new parts to the various repair shops.