With the new rule making to accommodate the above, I am unclear as to what document a non-designees will create to set forth all the data that is typically in a -3. Can it be a modified CofC with additional verbage? What is required and who can do it if they're not a designee - all I have read so far is that they must be "qualified person". Does the rule imply that after 4/1/16, all such tags must still come from a designee or can the "qualified person" simply carry on for the PAH?
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Reading the letter from FAA and EASA to ARSA dated 25 Nov 2015, it looks like the PAH quality system is supposed to identify who within the organization can sign the 8130-3. Existing stocks received prior to 1 Apr 2016 can be used without having an 8130-3 providing the documentation you have indicates you had it prior to that date. Any parts received after that date that could be used for EASA aircraft will need to have an 8130-3. INAL, but that's my take on it. The subject letter can be found here
http://arsa.org/wp-content/uploads/2015/12/FAA-EASA-ResponsetoIndustry-M...