Avionics News August 2018 - 41

aircraft when received with a U.K. CAA EASA Form 1. For
Basic Regulation (and because disallowing U.K. certificates
manufacturers with multiple production facilities, it may be
as "third-party certificates" is consistent with the message of
possible to shift production in order to obtain the "right" tags
the notice).
for the components that they produce, but some U.K.-based
How do you know if a Form 1 is subject to these condimanufacturers could be closed out of the installation market
tions? Look in block one (in the upper-left corner). That
on EU-registered aircraft (even if a prior type certificate or
block identifies the aviation authority under whose legal
supplemental type certificate approved their articles as eligible
authority the form was issued (usually by identifying the
for installation in that product). This is because the EASA
name of the nation and/or the name of the aviation authorregulations, like EASA 145.A.42, require a valid EASA Form
ity). You should look for language in that block like "United
1 on most acceptable parts for installation.
Kingdom" or "CAA U.K."
If the repair station relies on U.K.-produced parts, then
Of course, avionics with U.K. CAA EASA Form 1 should
the repair station should now consider how it will get those
continue to be eligible for installation on U.K.-registered airparts into its system after the withcraft. It is likely (but not yet certain)
drawal date. One suggestion would be
that the United States and the United
to use the provision for acceptance of
Kingdom will conclude some sort of
MANY U.S.-BASED REPAIR
unserviceable parts (found in EASA
agreement to facilitate U.S.-U.K. aviaSTATIONS HOLD EASA
145.A.42(a)(2)).
tion safety relations comparable to the
CERTIFICATION.
AS
OF
The definition of the term "unsercurrent U.S.-EU aviation safety relations.
viceable" component includes one that
So it is likely that tags derived from the
THE WITHDRAWAL DATE,
lacks "the necessary information to
legal authority of the U.K. CAA will
THOSE U.S.-BASED EASAdetermine the airworthiness status or
continue to be acceptable in the U.S. to
145 REPAIR STATIONS
eligibility for installation." Parts that
the same extent that they were acceptWILL NOT BE ALLOWED
bear U.K. EASA Form 1 after the withable before the withdrawal date. But no
TO INSTALL AVIONICS ON
drawal date will be considered unserformal statement has yet been issued, so
EU-REGISTERED AIRCRAFT
viceable in the EU, based on the curthis paragraph is mere conjecture.
IF THE AVIONICS BEAR
rent Brexit policy. Unserviceable parts
There is a grandfather-clause
AN EASA FORM 1 THAT
can be accepted when they "shall be
that applies to parts that are already
WAS ISSUED UNDER THE
maintained." The term "maintenance"
installed on an aircraft; so operators
AUTHORITY OF THE
is defined in European law to include
will not need to remove things that had
UNITED
KINGDOM.
inspection activities. So a repair stabeen tagged under the U.K. system.
tion that has recognized procedures for
This clause does not provide any safe
inspecting these parts may be able to
harbor for parts already in a repair stainspect them and find them servicetion's inventory, but it does illustrate a
able. This is a matter to be discussed and coordinated with
remedy for repair stations that want to move these parts out
the local civil aviation authority (e.g. the Federal Aviation
of their systems. Until the withdrawal date, it is still legal
Administration in the United States), because there are politito install those parts on EU-registered aircraft, and once
cal ramifications that could impact these procedures - this
they are installed, the current EASA notice states that they
may not be a merely technical discussion.
will continue to be acceptable in the EU system as a conseWhat about release to service documents issued by 145
quence of their installation. Repair stations with avionics or
organizations located in the U.K.? These are issued on EASA
other parts that bear EASA Form 1 issued under the authorForm 1 tags, but they arguably do not reflect certification "in
ity of the U.K. CAA should consider moving these parts out
accordance with Article 5 of the Basic Regulation." This techof their inventory by installing them on appropriate aircraft
nical argument is unlikely to save those tags. Another provibefore the withdrawal date.
sion in the notice makes it clear that:
It is possible that further negotiations will result in an
"Certificates confirming compliance with the proagreement between the EU and the U.K. to change this
visions of the Basic Regulation and its implementexisting declaration. It is also possible that Brexit could be
ing rules issued before the withdrawal date ... will
reversed. But, absent some other agreement, the EU will no
no longer be valid."
longer accept U.K.-based EASA Form 1 for new parts, even
This would appear to apply to maintenance release docuif the Form was issued while the U.K. was still part of the
ments, as well, because they are described in Annex IV of the
EU, after the withdrawal date. q
avionics news

august

2018

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