On April 3, ARSA joined with several of its industry allies in a letter to the FAA requesting the agency’s assistance in resolving specific “tagging,” requirements in the Maintenance Annex Guidance (MAG).

The MAG contains the detailed guidance that must be developed by the Joint Maintenance Coordination Board (JMCB) of U.S. and EU regulators in implementing the bilateral aviation safety agreement between the U.S. and the European Union that entered into force last spring.

At issue is the MAG “requirement” for an 8130-3 tag, issued by the production certificate holder, on all new parts used by a U.S. based repair station exercising its European Aviation Safety Administration (EASA) privileges. Specifically, the demand conflicts with FAA regulations in several ways. Indeed, the FAA has rejected requiring production approval holders (PAHs) from issuing Form 8130-3 in its own regulations. The letter also notes that EASA regulations allow more flexibility and, therefore, without a change to the MAG provision, U.S. businesses face an unnecessary burden from this significant administrative requirement in the MAG, with no safety benefit.

To resolve this issue, ARSA and its partners suggest changing the MAG language to require U.S. PAHs to use a PAH certificate of conformance stating the production approval under with the component was manufactured. Such a change would ensure consistency with existing FAA rules and improve the international competitiveness of the U.S. aerospace industry in light of the flexibility available to European manufacturers.

As this revision will help the U.S. realize President Obama’s National Export Initiative goal of doubling U.S. exports, the associations suggest that the JMCB adopt the change at its next meeting and incorporate the requested revision into the MAG as soon as possible.

~~~ posted 4/10/12 ~~~

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