Parts Rule Changes Hit Gazette One
Some key points of this rule change governing installation of parts
On September 29, 2001, several changes to Canadian Aviation Regulations (CARs) Part V and the associated standards (571 and 573) governing the installation of parts were published in the Canada Gazette Part I. They are now available for comment from the general public. After completion of the comment period and incorporation of any resulting amendments, the final rules will be published in Canada Gazette II, and come into effect on the specified date. Key points of the changes are summarized in this article.
The new rules introduce the terms "standard part" and "commercial part," and define "undocumented parts." To paraphrase, commercial parts are parts that were not originally intended for aeronautical use and that do not affect the safety of the aircraft. Standard parts are parts conforming to specifications established by a standard setting body. Undocumented parts are parts without sufficient certification or history to make them eligible for installation on an aircraft.
The reference to life-limited parts has been amended to clarify the issue of disposal. A new paragraph has been added to require life-limited parts that have reached their service limits, to be either rendered unusable, or identified as unairworthy and segregated from other parts.
The standards on life-limited parts have been reworded to clarify the minimum technical history required, and two information notes have been added. The new wording makes clear that the technical records for life-limited parts differ from those for other parts only in one major respect; life-limited part records must include the number of hours, cycles, or calendar time since new, as applicable.
New standard and commercial parts may be used without conformity certification, provided they can be identified through markings or other documents, and are specified in the type design. Used commercial and standard parts are still subject to a maintenance release. Parts removed from damaged aircraft and aircraft that have been permanently withdrawn from service may be used, provided they are traceable to the manufacturer, have been inspected for conformity and condition, and an applicable maintenance release issued. The Authorized Release Certificate (24-0078) has been amended to bring it into line with the standard agreed upon between Transport Canada, the FAA, and the European JAA. The three national documents (24-0078, FAA 8130-3, and JAA Form One) are now virtually identical, but not interchangeable. Maintenance organizations must use the appropriate form that applies to their particular regulatory framework.
The restrictions on FAA Parts Manufacturing Approval (PMA) parts will soon be lifted, and an equivalent Canadian system, the Parts Design Approval (PDA) has been introduced. Unlike the FAA PMA system, which combines design and production approval under a single authorization, Canadian PDA holders will be required to hold a separate manufacturer approval in order to manufacture the parts.
Re-certification of undocumented parts
The biggest change relates to the procedures for "rehabilitating" undocumented parts. While done in the past, this is the first time it has been officially recognized. This should add a measure of standardization. A new appendix outlines the process. The re-certification will take the form of a maintenance release, stating that the part has been inspected and tested in accordance with an approved procedure, to ensure it conforms to its type design. The process is not applicable to life-limited parts or to parts that are subject to rejection following an abnormal occurrence. (For example, in the absence of appropriate technical records, parts that are subject to absolute limits on torque or temperature, must be assumed to have exceeded those limits, and rejected, regardless of their visual condition.)
The procedure consists of two phases, one relating to the origin of the part, and the other to its physical condition. The origin element depends on knowing where the part was obtained, and a plausible explanation for not having applicable documentation. Examples include parts that have become separated from their documentation in storage, and parts that have been inadvertently mixed with like parts, all of which are known to have come from a reliable source, even though they are not individually identifiable. Where there is insufficient information to give reasonable confidence of having come from an authentic source, the part must be rejected.
Parts that have a reasonable origin must then be inspected and tested for condition and conformity to their applicable type design. The nature of the inspection will depend on the part. For simple parts, it could consist of visual and dimensional checks. With detailed parts it may be necessary to select samples at random for testing to destruction. Parts that are more complex may require a complete overhaul. Any defects found must be rectified and separately documented.
Approved Maintenance Organization (AMO) privileges
The re-certification process is only available to Approved Maintenance Organizations (AMOs) with documented procedures that have been approved by Transport Canada. The privilege will not be indicated by a rating, but by inclusion in the scope of limitations for the existing ratings. This will help to ensure that AMOs are only authorized to re-certify parts that fall within their particular area of expertise. The AMO's Maintenance Policy Manual must include the details of the process and the persons authorized to sign the resulting maintenance release. Signatories must be trained in the procedures, and must have at least five years' experience as an approved signatory.
These rule and standard changes will allow some increased flexibility within our regulatory structure. The definitions will add clarity and allow for reduced documentation on some basic parts. The interpretation of life-limited parts will reduce some of the burden on record keeping not required by other countries and help ensure parts beyond their limits are removed from circulation. The new parts tag and substitution rules will bring Canada in harmony with other authorities in addition to developing a system where a common form is used to verify compliance to type design. With the re-certification rules, industry will benefit in the availability of parts, which can be re-certified through an approved process. The level of safety is maintained through a documented and approved process within the AMO's maintenance policy manual. AMT
John Glavind is a Civil Aviation Safety Inspector for the Aircraft Maintenance and Manufacturing Branch in Ottawa. Comments or questions may be sent to him at firstname.lastname@example.org