Thursday, September 11, 2008

International Considerations in STC Kit Export

Welcome to Wired!

One of the interesting things the management and staff of ASIG has noted over the last several months is that much of our kit manufacturing work is being requested from abroad. Specifically non-US clients are either required to (by airframe leases), or have made an intentional company decision, to seek-out and deploy United States FAA STC and FAA-PMA kitting in their aircraft. One of the export related questions our project managers and sales team are asked regularly is, "Are ASIG's U.S. STC's and FAA-PMA approved parts authorized for installation and operation in EASA registered and operated aircraft?"

The answer, as you would imagine, in not nearly as straight forward as one might hope. According to EASA Executive Director Decision 2007/003/C, dated July 16, 2007, on the acceptance of certification findings made by the Federal Aviation Administration of the United States under the Parts Manufacturing Approval of the FAA, in regards to the approval of the design of certain PMA parts:

"An approval is hereby issued by the agency to an organization under the regulatory oversight of the FAA for a part designed under its PMA system, provided:

  1. The PMA part is not a "critical component." Typically, such components include parts for which a replacement time, inspection interval or related procedure is specified in the airworthiness limitations section of the manufacturer's maintenance manual or instructions for continued airworthiness. The statement, "This PMA part is not a critical component," should be written in Block 13 of FAA Form 8130-3; or, A critical component is a part identified as critical by the design approval holder during the validation process, or otherwise by the exporting authority;


  2. "The PMA part conforms to design data obtained under a licensing agreement from the holder of the FAA design approval, according to 4 CFR § 21.303(c)(4) of the Federal Aviation Regulations The statement "Produced under licensing agreement from the FAA design approval holder" should be written in Block 13 of FAA Form 8130-3;


  3. The PMA holder can show that the part has received an explicit approval by means of a design change or STC from the Agency or, when this approval was granted prior to 28 September 2003, from any of the National Aviation Authorities of the Members States of the European Union. The reference to this authorization should be written in Block 13 of the FAA Form 8130-3."

What does this mean to maintainers and operators of EASA registered aircraft? It means, that PMA parts will be subject to reciprocal acceptance between the United States FAA and those countries subject to EASA jurisdiction, provided that the FAA-PMA part is: not flight critical; may be flight critical but conforms to OEM standard and has been manufactured under license from the OEM; or, is approved for installation, operation and continued airworthiness via the issuance of a United States of America FAA Supplemental Type Certificate. In short, item "c" of EASA Executive Director Decision 2007/003/C provides European operators the confidence in knowing that FAA-PMA components and kitted materials may be installed in accordance within the requirements of EASA as long as the prevailing bilateral agreement governing these reciprocal agreements remains in effect.

Until next time stay 5x5, Mission Ready & Wired!

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