Dual-release is becoming the standard

In general, new aircraft parts for U.S registered aircraft need either the FAA Form 8130-3 certificate, the EASA Form 1 from the manufacturer, or a certificate of conformity (CoC) from the manufacturer attesting to the parts conformity to an FAA production level.

For used parts, the documentation is a little different. Here you either need the FAA Form 8130-3, or an EASA Form 1, with a return to service statement on the form. This is commonly known as a “dual-release” or “dual-certification” EASA Form 1.

»Dual-certification is when a part is certified with two different standards – for instance with both the FAA and EASA Standard. Sometimes we even see triple certification to another national authority, for instance, Chinese certification. What’s interesting is that in the US, we’re seeing a strong demand for requirements for dual-certification – both on the aftermarket level and on the airline level. This is not required in the legislation – U.S aircraft don’t have to meet EASA regulations, and British aircraft don’t need FAA certification when they get a part repaired in the EU,« explains Brent Webb, VP of technology integration at CAVU Aerospace, that specialises in dismantling of aircraft.

T. Hastings Siegfried, Vice Chairman & COO of the MRO NORDAM, adds:

»From the MRO side, it’s pretty standard for us to dual-release the parts we repair for FAA and EASA. Some airlines prefer one over the other, so this is also something we do to make things easier for our customers,« he says and adds that there can be many reasons as to why airlines prefer dual-certifications:

»I have one example from a few years where we were asked to do dual-serve for a small airline who was leasing aircraft. They wanted dual-certification of the parts because when they turn back the aircraft, the leasing company requires these certifications based upon where the aircraft will be put into service next if they are not renewed. It’s true – there isn’t an actual regulatory requirement about this, but it just makes more sense for us to dual-serve most parts.«

Pat Markham, VP Technical at HEICO Aerospace, recognizes that there are a lot of misunderstandings about the actual regulation of traceability.

»The regulatory requirements of traceability of parts are small. The issue is that there are a lot of misunderstandings out there, in regards to what people think is required. My personal opinion is that someone once told someone that this and that is important and then it went from there. In a nutshell, the actual requirements are that the parts must be able to be traced back to an approved source – that being a repair station, who can prove that the parts are airworthy, or a manufacturer that can prove that the parts are new. You don’t need both,« he explains.

Complications with older and new-generation aircrafts

The panel also highlights another pressing issue. Many airlines operate a diverse fleet consisting of both old and new-generation aircraft and holding these to the same standards of MRO traceability simply doesn’t make sense.

Brent Webb, VP of technology integration at CAVU Aerospace, explains:

»One of the things that have become my tilt at the windmill, is the fact that we’re living in two paradigms. The documentation for parts that were manufactured for next-generation aircrafts, such as the 787, documentation back to birth isn’t necessarily an issue, but we’re also living in this world where we are flying aircrafts such as the 75s that are no longer manufactured today and don’t have the traceability of the aircrafts manufactured today. Holding these aircraft to the same standards as the new-generation fleet is difficult, sometimes even impossible,« he says and continues:

»Our system needs to be less rigid and we need to understand what’s available. Modern aircraft deliver tons of data, but the case isn’t the same with older aircraft such as the 757s.«

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Aircraft retirements increasing: MRO traceability challenges arise