Avionics News April 2018 - 64

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AEA GENERAL COUNSEL

The Documentation Puzzle
What are the traceability rules in the U.S.?

ecently, my son asked me whether a snail would be
faster or slower if you were to remove its shell.
We'll come back to that question, but while we are
on the subject of moving fast, let's talk about documentation
that comes with aircraft parts.
During the past 25 years, I have seen documentation
become more and more important to transactions in aircraft
parts. I often get calls from industry participants, who ask
"where do I find the FAA regulations for traceability?" I have
to inform them that those regulations don't exist.
That is a surprise to many people today. They think that the
documentation standards must be ensconced in the Federal
Aviation Administration regulations. There are many reasons
for this belief, but one of them can be that the local FAA
inspectors have emphasized the importance of documentation
to such a degree that the repair station concludes that it must
be a regulation.
In fact, the FAA regulations do not require any documentation
at all for purchasing an aircraft part. The regulations were written
before parts documentation was a thing, so they do not require
that part be accompanied by any particular documentation.
In this way, the FAA regulations are different from those
of the European Aviation Safety Agency. The EASA regulations and guidance typically require that parts be accompanied
by some sort of defined documentation in order to make them
acceptable for installation:
* The general rule for parts "in a satisfactory condition" is
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avionics news

april

2018

that they would be accompanied by an EASA Form One
or equivalent. Europe has agreements that recognize FAA
Form 8130-3 (U.S.), TCCA Form One (Canada) and
ANAC Form F-100-01 (also called the SEGVOO 003)
(Brazil) as equivalent documents. EASA 145.A.42(a)(1).
* Standard parts typically are received with a certificate
of conformance as well as documentation showing the
manufacturing and supplier source - an EASA Form 1
or equivalent is not normally issued and, therefore, none
should be expected. AMC M.A. 501(c) (AMC/GM TO
ANNEX I (PART-M) TO REGULATION (EU) No
1321/2014).
* Raw materials and consumables are typically accompanied by documentation showing conformity to specification as well as documentation showing the manufacturing
and supplier source. EASA 145.A.42(a)(1).
* Unserviceable can be accepted with no documentation,
under the EASA standards, as long as it is intended to be
maintained in accordance with the EASA maintenance
regulations. EASA 145.A.42(a)(12).
Many Americans view the term "unserviceable" in a way
that is far more limited than the European regulatory definition. The European definition includes all the various occurrences that would render a part to be in need of maintenance
(e.g. defects that require repair, expiration of service life limits,
applicable airworthiness directives, etc.). EASA M.A. 504(a).
But it also includes parts that do not have "the necessary

Table of Contents for the Digital Edition of Avionics News April 2018