Parts maintenance under US/Canada agreement; paperwork

[photofly]

I have a question for those well-versed with FAA/TC maintenance requirements.

I'd like to send a small component from an aircraft for repair by an FAA-certificated A&P/IA. He's not a maintenance organisation, and can't issue an FAA 8130-3.

I've been reading the "Agreement for the Promotion of Aviation Safety dated June 12, 2000 Between the Government of the United States of America and the Government of Canada" and particularly the Maintenance Implementation Procedures thereof, which are at http://www.tc.gc.ca/eng/civilaviation/s ... i-3736.htm.

Chapter 3.0 of that document says that components repaired in the US need an 8130-3 to be good to use in a Canadian aircraft. Chapter 3.1 implies that if the FAA mechanic could himself approve the product for return to service in the US, that's good enough for Transport Canada.

So the question is, if I can't get an 8130-3 for the repaired part, will the logbook sign-off that the A&P/IA could issue satisfy Transport Canada instead?

Thanks for any help!

[sprayrail]

Photofly

Section 3.1 of the MIP may imply that the FAA A&P/IA can approve your component for return to service and if the aircraft were in the US and he was performing those repairs and installing the component as long as he met the requirements - experienced on type etc. you would be fine. The problem arises when your part comes back to Canada with no Documentation for repairs performed on your component. Chapter 571.13 speaks to this.

Regards

[photofly]

Sprayrail,

Thanks!

The A&P is prepared to send me a maintenance log entry on a self-adhesive label; would that not be sufficient?

[Cranium]

Chapter 3.1 is intended for work on an aircraft, not a part. For example, if your plugs get fouled, an A&P / IA can clean them and sign the book.

See 3.0 (c)
(c) Maintenance and alterations or modifications must be certified by an approval for return to service or a maintenance release that meets the requirements of 14 CFR part 43, sections 43.9 and 43.11, or CAR Part 571, Section 571.10, as applicable, for aircraft and the use of the FAA Form 8130–3 or TCCA Authorized Release Certificate for aircraft components, and any other information required by the owner or operator, as appropriate. For the purposes of compliance with this MIP, the requirements of 14 CFR part 43, sections 43.9, 43.11, and CAR Part 571, Section 571.10, are considered equivalent.

A maintenance log entry is only enough if the the work is completed on an aircraft. "...and the use of the FAA Form 8130-3 or TCCA Authorized Release Certificate for aircraft components..."

If it's a part, you need an 8130, especially if it's a life-limited component.

Another sticky situation I have heard of is Canada Customs can occasionally be sticky about parts crossing and re-crossing for repair. They may charge duty on the cost of the repair or the full value of the part.

[photofly]

Hi Cranium

I initially thought that too. But then see http://www.tc.gc.ca/eng/civilaviation/s ... 3-2642.htm - particularly Appendix A and footnote 5 therein.

That whole document is about documentation required for installation of parts, and the appendix says "The maintenance release document (return to service) could be in the form of a repair station tag, work order, FAA Form 337, FAA Form 8130-3 or a maintenance record entry signed by an appropriately certificated person describing the maintenance performed."

[Cranium]

OK, so as long as the part was accompanied by some sort of maintenance release, as long as it's specific enough (describing what was done, standards used, etc.), that would be legal. You would just have to attach the paperwork to the tech logs of the aircraft.

I have one other concern. Does the A&P have the required tooling, manuals, and test equipment for the part? As an AME, I can repair a carb, for example, but I can't sign it out "IAW the applicable standards of airworthiness" if I don't have a manual or flow tester for that model.

[photofly]

he tells me he's been approved by the FAA (presumably his local FSDO - I don't know the details) to carry out this particular repair. So I guess that would be ok.

[sprayrail]

Photofly

The problem with the sticky that your A&P is providing is, does it meet the requirements below when you or an AME go to install your repaired component?

571.13 (1) Subject to sections 571.07 to 571.09, no person shall install a part on an aeronautical product unless the part is
(amended 2002/03/01; previous version)

(a) inspected and its accompanying documentation verified in accordance with a procedure that ensures that the part conforms to its type design, as is indicated by the maintenance release; and
(amended 2002/03/01; previous version)

(b) installed in accordance with the requirements of section 571.13 of the Airworthiness Manual.

Regards

[Heliian]

What kind of part is it? If it's a small item like a strobe power supply, I would be happy with the maint release. If it's a bigger item like a prop or cylindre, I would need the 8130. And then, like said above, there is the customs req's. You technically need supporting documentation to prove that the part will be returning to Canada after the repair. Don't ship u.p.s or you'll get fees that make shipping it there in the first place cost prohibitive. Is there no place in Canada to get it repaired? Again, it all depends on what the part is.

[robertw]

HOLD ON!!!

It's extremely important to consider what type of component and the type of repair required.

CAR 571.04 says:

No person shall perform the specialized maintenance set out in Schedule II to this Subpart on an aeronautical product other than an aircraft operated under a special certificate of airworthiness in the owner-maintenance or amateur-built classification, except in accordance with
(amended 2002/03/01; previous version)

(a) a maintenance policy manual (MPM) established by the holder of an approved maintenance organization (AMO) certificate issued pursuant to Section 573.02 with a rating of a category appropriate to the work to be performed; or

(b) a foreign document equivalent to an MPM established by a maintenance organization approved under the laws of a state that is party to an agreement with Canada, and the agreement provides for recognition of the work to be performed.

Follow this link for a listing of what is considered "specialized" maintenance.

http://www.tc.gc.ca/eng/civilaviation/r ... 2-1769.htm

If your "small component" repair falls under "specialized maintenance" and your A&P is not working under an appropriately rated FAA repair station, then the 8130-3 that will accompany your freshly repaired part will not be worth the paper it's written on. You will have wasted your money and if you have an AME or AMO install that part without telling them that the guy who fixed it was not qualified per the above CAR, they will become liable for installing a part not elligible for installation on a Canadian aircraft.

[photofly]

Interesting responses - thanks everyone.

If your "small component" repair falls under "specialized maintenance" and your A&P is not working under an appropriately rated FAA repair station, then the 8130-3 that will accompany your freshly repaired part will not be worth the paper it's written on.

It's *not* specialized, the A&P is *not* part of a repair station, and (as I tried to make clear in my original post) there's no question of an 8130-3 as he's *not* in a position to issue one.

My question is really about whether paperwork *other* than an 8130-3 is acceptable; one TC source implies 'yes, very much so', and another TC source implies 'no'.

[robertw]

Good ol' TC. You get that all the time. One inspector says "Sure! No problem." The next one says "What are you crazy?" It seems to be a common thing with TC.
Can you tell us exactly what it is you're having repaired?

[photofly]

Well, why be coy? It's the baggage door latch from a Skylane. The repair is to remove a pin, replace the two tiny coil springs that push the bolt home and pull the handle in, insert a new pin and crimp its end. The old springs have corroded through, over 30+ years.

[robertw]

I've actually done that exact repair on a 182. It ended up being cheaper to order the guts of the latch as an assembly than spend the labour fiddling around with replacing springs and pins. Here's the p/n S1359-7. It goes into latch assembly p/n 0711790-1. It may or may not be the same. You would have to check.

[photofly]

S1359-7 is indeed the part but it lists at $617. The repair is $175. The Hartwell latch that is the heart of the unit is (was) $10 for two new on ebay, but that wouldn't be an approved source and anyway I'd have the same issues getting it riveted to the backplate.

[robertw]

Hmmm... That is a little more expensive than what I remember it being. I don't seem to remember having to do any riveting. The whole job took no less than an hour and a half to replace the latch mechanism.

Back to your original question, I think that you could get yourslef into a sticky situation should TC ever question you about it. I know that the IPC does not list any other part #'s for that subassembly, so if the A&P were to install new springs and pins, there would be the issue of those parts being "approved for installation" into your aircraft. There is also no procedure in the maintenance manual detailing the disassembly and reassembly of the latch. You also have to consider who will be signing out the re-installation of your baggage door as I'm assuming it's removed. Most likely TC would not question you about it as they are not too worried about private guys and their Cessna's or Pipers. They start to look more closely if you are making money with the aircraft or if you have a history with them. To be honest, some owners in your situation would just buy the latches off Ebay, have a spare, and do the repair themselves without a log entry. That would be a contravention of the CAR's. I don't recommend that. If you want to do things correctly, you need to buy the part specified in the IPC (with the correct certification, Cessna provides an 8130-3 with everything they sell), and carry out the installation in accordance with the maintnenace manual. You could have an AME (M1) or A&P sign that out as long as you are a private operator. That's the right way to do it.

[Heliian]

A cheaper and still legal solution would be to find a used serviceable one in Canada and get your local AME to do the repair. I don't know of anywhere to find it but i'm sure that the good folks on this site would be able to point you in the direction of a GA "salvage yard"

[helicopterray]

Call these guys and see if they have the used parts you need.

http://www.westcanaircraft.com/flash/ma ... /index.php

[photofly]

For closure: I emailed a request to Transport Canada, and I've just had this reply:

The agreement between Transport Canada and the FAA recognizes most of our regulations as being equivalent. When trying to determine if the certification for work performed will be acceptable to Transport Canada first look to the FAA requirements. If the performance of the work and the certification for that work complies with the applicable FAA regulations, it will almost always be acceptable to Canadian regulations except for what is listed in the MIP.

If the aircraft is operated commercially to the Canadian regulations (refer to the MIP section 4.2) the work would need to be completed and certified by a repair station that has a supplement per the MIP and any other special conditions for Canadian aeronautical products.

In terms of my original question, and as this is not a commerically operated aircraft, I interpret this as meaning that the A&P sign-off is valid for the part to be installed in a Canadian registered aircraft, just as would be in a US registered aircraft.

[photofly]

For closure: I emailed a request to Transport Canada, and I've just had this reply:

The agreement between Transport Canada and the FAA recognizes most of our regulations as being equivalent. When trying to determine if the certification for work performed will be acceptable to Transport Canada first look to the FAA requirements. If the performance of the work and the certification for that work complies with the applicable FAA regulations, it will almost always be acceptable to Canadian regulations except for what is listed in the MIP.

If the aircraft is operated commercially to the Canadian regulations (refer to the MIP section 4.2) the work would need to be completed and certified by a repair station that has a supplement per the MIP and any other special conditions for Canadian aeronautical products.

In terms of my original question, and as this is not a commercially operated aircraft, I interpret this as meaning that the A&P sign-off is valid for the part to be installed in a Canadian registered aircraft, just as it would be in a US registered aircraft.