No 8130-3 Triple Release
Changes in Certification Requirements for FAA Repair Stations
Once the Special Arrangement for Continuity in Aircraft Certification Projects between the US and UK ends this January, FAA Repair Stations offering products to customers operating G-registered aircraft (those registered in the United Kingdom) will need to be certificated by the UK Civil Aviation Authority (CAA). If you own, operate, or manage a Repair Station in the United States, I hope this isn’t new information! If it is, here’s a copy of the most current US-UK MAG to get started: Maintenance Annex Guidance (MAG) between the Federal Aviation Administration of The United States of America and The Civil Aviation Authority of The United Kingdom of Great Britain and Northern Ireland. That title is a mouthful!
Introduction of the Third Regulatory Agency Certification
For the first time, many US Repair Stations certified by the FAA and EASA (under the United States – European Union bilateral agreement) will have a third regulatory agency certification: the UK CAA. The US-UK bilateral agreement is a copy-and-paste version of the US-EU agreement and so many Repair Stations have enjoyed a relatively “simple” addition of UK approval.
Triple Release Forms in Europe vs. USA
What’s notable is that our friends in Europe have no problem issuing a “triple release” Form 1 for maintenance performed under the framework of multiple regulatory agencies. That is, a facility approved by 3 different aviation authorities (like so many now in the USA) may release an article back to service on one Form 1… say EASA, FAA, and ANAC, for example. In this case, the one document is good for an EU, US, or Brazilian registered aircraft. Easy!
Challenges with Triple Release in the USA
What’s not so easy is the fact that those of us in the USA cannot provide a triple maintenance release with FAA-UK-EU approval. We must issue a FAA 8130-3 form after maintenance (not a Form 1) and therefore we must follow the “rules” for the use of the 8130-3 form. Those rules only refer to a “dual release” (i.e. two regulatory agencies and no more). Further, the FAA made it clear during a recent question-and-answer session that a FAA-UK CAA-EASA “triple release” 8130-3 is not acceptable. Here’s a link to that document: FAA-UK-MIP-Webinar-Questions.
Navigating the Triple Release Limitations
I could go on about the language in the US-UK and US-EU MAG that likely resulted in US Repair Station’s EASA and UK manual supplements similarly limiting the use of a triple release but I think you get the point. It’s not allowed (even though we can all agree it should be and maybe it will be in the future).
Preparing for Customer Conversations
This will result in some tough conversations with customers, most definitely, and certainly some US Repair Stations will inappropriately issue a “triple release” 8130-3 at some point. I can already hear it: “but Brian, so-and-so did it, why can’t we?” or “Just issue a Form 1 then” lol.
Creative Solutions to the Problem
What’s the solution? Get creative!
The FAA has made it clear there’s nothing wrong with issuing multiple release documents. That is, you can offer a customer a FAA-EASA dual release 8130-3 and a FAA-UK dual release 8130-3. What if you were to print both of those documents on the same piece of paper? No problem!
Educating Customers on the New Process
Obviously, US Repair Stations will have to educate customers, especially those who resell services, on the use of the 8130-3 and why they must endure more paperwork than they receive from our European counterparts. If that’s the case, just send them a link to this article or have them contact Tym’s and we’ll set them straight for you.
Need Help? Reach Out for a Consultation
If you have questions about how to acquire EASA or UK approval for your Repair Station, reach out for a consultation: Tym’s LLC Consultation Request.