Avionics News - September 2023 - 38

THE VIEW FROM WASHINGTON
Continued from page 15
Paragraph 8 addresses approved design and repair data. Changes
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to the Type Design: Major Changes, Minor Changes, Supplemental
Type Certificates is contained in paragraph 8.1. Here, the MAG
states, " The EASA-approved design engineering data is normally data
supplied by an EASA design organization approval holder, or data
approved by the AA of the type certificate holder (or equivalent), or
data supplied by the customer and approved by EASA. In all cases,
the customer is responsible for confirmation of data approval. Details
for the acceptance and/or validation of FAA-approved changes to
the type design by EASA are contained in Annex 1 to the agreement
and in the associated technical implementation procedures for
airworthiness and environmental certification. "
Although alteration/modification data must be approved by the
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state of registry, with a few exceptions, the bilateral agreement has
a reciprocal acceptance of repair data. Under the MAG, " The FAA
shall approve design data in support of major repairs in accordance
with FAA Order 8110.4, Type Certification; FAA Order 8110.37,
Designated Engineering Representative Guidance Handbook; FAA
Order 8100.15, Organization Designation Authorization Procedures;
and FAA Order 8900.1. Minor repairs are made in accordance
with 'acceptable' data, in accordance with 14 CFR Part 43. " And
reciprocally, " EASA shall approve design data in support of repairs
in accordance with EASA Part 21, Subpart M-Repairs, and EASA's
procedure Type Certificate Change and Repair Approval. "
There are a few differences that are critical to the operation of
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United States-European Union bilateral repair stations.
First, the receiving inspection has some unique requirements.
Paragraph 10 addresses the release and acceptance of components.
In essence, while the traceability criteria are similar, the traceability
documentation is different. For an FAA repair station, there is no
regulatory requirement for a formal receiving inspection, but there is
an extensive advisory circular that provides guidance on the design
of a receiving inspection as well as the acceptability of parts.
FAA AC 20-154 provides guidance for the development of
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a receiving inspection system for aircraft parts and material.
FAA AC 20-62 provides guidance on the eligibility, quality and
identification of aeronautical replacement parts. EASA 145.A.42
provides the acceptable means of compliance for the receipt
and documentation of components. The basic structure of these
guidance documents is similar; however, the acceptability of
documentation is uniquely different, which needs to be addressed
by U.S.-based EASA 145 repair stations.
There are two additional areas that need to be addressed: the
requirement for a quality assurance system and the requirement to
Continued on page 47
38 avionics news * september 2023
http://www.uAvionix.com/tbx
Avionics News - September 2023

Table of Contents for the Digital Edition of Avionics News - September 2023
