On June 24, the Design, Manufacturing and Airworthiness Division (AIR-100) of the FAA’s Aircraft Certification Service issued two deviation memos to FAA field offices that will help repair stations comply with the requirements of the U.S.-EU Maintenance Annex Guidance (MAG).
MAG CHG 6 (and its predecessor CHG 5) require Form 8130-3 to be issued for new parts released by a PAH on and after Oct. 1, 2016 if subsequently installed during maintenance subject to the MAG.
The deviation memoranda:
(1) Facilitate production approval holders’ (PAH) implementation of section 21.137(o) authorizing such entities to issue Form 8130-3 as an Authorized Release Document.
(2) Allow the issuance of Form 8130-3 as an export document for articles without having to mention the article complies with the importing requirements of a specific country. For engines and propellers the FAA will allow multiple countries to be referenced. Other block 12 statements referenced in Order 8130.21 or required by bilateral agreements (e.g., “This PMA part is not a critical component.”) must still be included.
As part of an ongoing effort to address issues with the MAG, an ARSA-led industry coalition worked closely with the FAA for two months ahead of memos’ issuance. The effort included both aviation trade associations and private businesses that made headway with the FAA and EASA by delivering letters, meeting with officials from both agencies and engaging in an informed public discourse about the difficulties caused by the new 8130 requirement.
While there are many challenges remaining for PAHs to modify their quality and IT systems to accommodate the changes in time for the MAG CHG 6 implementation date of Oct. 1, 2016, the memos will go a long way toward giving industry the tools needed to comply.
ARSA’s efforts regarding the 8130 requirement have been supported by: the Aerospace Industries Association, the Aircraft Electronics Association, Airlines for America, the Aviation Suppliers Association, the General Aviation Manufacturers Association, the Modification and Replacement Parts Association, MOOG Aircraft Group, Honeywell Aerospace, Gulfstream Aerospace Corporation and the Boeing Company.
Click here to download both memos (zipped file).
Stay tuned to ARSA’s website for more information on parts documentation requirements (arsa.org/production-certificates) as well as the fifth (arsa.org/mag-change-5) and sixth (arsa.org/mag-change-6) revisions to the U.S.-EU MAG.
