Point of entry to service 21 to 145


Starting to get Involved
Seeking clarification of what the technical point of entry to service for Aerospace components is.

The scenario I'm facing is as follows;
- Component released under my organisations Part 21G approval as part of a top level assembly.
- Component has been fitted on wing and flown as part or our customers 'Flight test' and end users buy off process.
- Reported Flight testing has completed in excess of 50 operations over 40 hours of flight time (Critical part).
- Component was removed following an error report flagged during flight testing.
- Component has been returned to the OEM for 'Repair' activities.

Typically we've locally worked the approach that providing components have been subject to a Minimal, Fair and reasonable level of Operational use any re-release of the components and top level units could be under part 21.

Recently we've seen a significant increase in operational use of components upto around 40 hours prior to the techincal 'Entry to service' when the airframe is bought off by the end user.

We have seen a number of parts returned for repair/re-validation with the expectaiton that they are still 'New' part 21 components.
Our organsiaiton has processed these based upon the use and flight times against part 145 data given they have flown. Our customer is unhappy with this as they still wish to certify the product and comonents under part 21.

Cannot locate anything of value within the Regualtions that covers when when ICA (Instrucitons For Continuing Airworthiness) applies to Part 21 items - when the technical change from parts 21 to 145 is.

We've always applied a pragmatic approach but with the increasing level of 'Flight testing' its becoming harder to justify revalidating 'Used and Flown' components back under production data without placing risk to our organisation to remain compliant with the regulations.

Whats fair use? When is the jump from 21 to 145?
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