EASA Design – Manufacture and Certification of Placards

Sofema Aviation Services (SAS) www.sassofia.com considers the key aspects related to ensuring aviation placards are fully compliant with the regulatory requirements and may be installed on aircraft.

Introduction

As a general comment - If a company other than the OEM manufactures an item they must identify who they are.

·?????? Also to strictly adhere to the Manufacturer design data you would need to ensure that the information is at the latest revision and also have access to the certification data.

Here we consider the authority of a Part 21 DOA to create a placard and annotate with the OEM P/N - is this acceptable for Form 1 certification - or must we go the EPA route - mean annotate with OEM P/N plus letters EPA?

The Responsibilities of the DOA - Regulation (EU) No 2021/699

(a) Each part or appliance which is eligible for installation in a type-certified product shall be marked permanently and legibly with:

·?????? 1. a name, trademark, or symbol identifying the manufacturer in a manner identified by the applicable design data;

·?????? 2. the part number, as defined in the applicable design data; and

·?????? 3. the letters EPA for parts or appliances produced in accordance with approved design data not belonging to the type-certificate holder of the related product, except for ETSO articles and for parts and appliances covered under point (b) of point 21.A.307.

(b) By way of derogation from point (a), if the Agency agrees that a part or appliance is too small or that it is otherwise impractical to mark a part or appliance with any of the information required by point (a), the authorised release document accompanying the part or appliance or its container shall include the information that could not be marked on the part or appliance.

DOA Procedures

The DOA should use their own numbering system as per their procedures and yes it must include the letters EPA (21.A.804(a)).

·?????? If their procedures say they can put OEM part numbers on parts, then that would be OK (again with the letters EPA included)

Concerning 145 Fabrication of Parts ?

If a 145 organisation makes a part to an OEM drawing then they could legitimately put the OEM part number on it. (again, it should be identified with a suffix related to the 145) – (possible licensing issues)

·?????? Such parts cannot be sold or provided with an EASA Form 1

EASA FAQ n.20095 - Why and how must Parts and Appliances be marked, when are the letters EPA required, and which exceptions are acceptable?

·?????? To comply with EASA Part-21, Subpart D, 21.A.109, Subpart E, 21A.118A (b) and Subpart M, 21A.451(a) and (b), it is the obligation of the respective Holders of a Minor Change Approval, a STC, or a Major Repair Design Approval, to specify the required markings, including EPA letters as applicable, in their Design (read, ‘Approved Data’), according EASA Part-21, Subpart Q.

·?????? Subpart Q, 21.A.804(a), and related GM, require proper identification of each Part and Appliance that is designed or redesigned, including parts designed to be incorporated in repairs (21A.451), by ‘permanent and legible marking’ hereof, and is applicable for Design Organisations and Manufacturers.

·?????? 21.A.804(a) 1 and 2? clearly require marking of Parts and Appliances with ‘name, trademark, or symbol identifying the Manufacturer’ and ‘Part number’, as defined in the applicable Design Data.

·?????? According to the GM the Design Approval Holder shall identify in all its Design (TC, STC, ETSO, Repair, Change) approved after 28 December 2009, how the Manufacturer has to mark subject Parts and Appliances in accordance with 21A.804(a) 1; which can be limited to identifying a marking field and the method, without prescribing the actual text or symbols.

·?????? 21.A.804(a) 3 requires additionally marking with the letters ‘EPA’ of all parts produced (manufactured) in accordance with data ‘not belonging to the TC holder of the related product’.

EPA Marking

·?????? Each interchangeable or removable Part or Appliance that is manufactured in accordance with a design issued by the Design Organisation, shall be permanently and legibly marked according to 21.A.804.

Note 1- The EPA marking was introduced in 2004; this was done to clearly identify any ‘not original’ Part, (which means any Part or Appliance not designed by the TC- or ETSO- Approval Holder), as a trigger for Maintenance Organisations and Accident or Incident investigators, in the light of Continuing Airworthiness.

Note 2 The intention was certainly not to require adding of the letters ‘EPA’ to mark repairs. In this context, EPA marking only applies to the new designed and manufactured parts to be incorporated in the repair. Especially where repairs have an impact on interchangeability, identification of incorporated new Parts is very important, and DO Procedures should address this item.

Note 3 That for parts referred to in 21.A.307(b), as amended with (EU)2021/699 (applicable from 18.05.2022), the EPA marking is not required as stated in 21.A.804(a)(3).

Small Parts Marking

·?????? The only accepted exception with regard to Marking (including EPA), is defined in 21.A.804(b). This subparagraph offers the possibility to not physically mark the Part of Appliance, when it is too small or when marking hereof is otherwise impractical, but only after “Agency agreement”.

o?? This wording allows an Applicant/Holder of a Design and the Agency to further define in detail how this ‘agreement’ can be obtained and will be formalised. DOATL should however ensure that the DOA Applicant/Holder reflects this approach in its DO Handbook or Procedures, requiring at least a justification of the reason for not marking physically, and details of the alternative way chosen for the identification, in accordance with 21A.804(b), to know on the authorised release document accompanying the Part or Appliance, or on its container.

?C of C or EASA Form 1?

·?????? In the case of Placards which are manufactured by a Part 21G Organisation (holding the applicable scope of approval), the expected release will be on EASA Form 1 ?

o?? Placards shall comply with flammability and traceability requirements.

Note - A Certificate of Conformity is only applicable to Standard Parts with traceability to source, therefore such a release is not acceptable for Placards.

Next Steps

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