There are some documents that are essential for the smooth operation of aviation. When it comes to moving products, parts or components of aircraft around the world the Authorised Release Certificate is key. This certificate must be trusted and accepted by those who receive it. Even with an international framework that describes how this is done this acceptance is not automatic.
In Europe, the format of Authorised Release Certificates has been harmonised after decades of work. In addition, work has been undertaken harmonise the instructions for completing these standard release forms.
The EASA Form 1 is the Authorised Release Certificate provided by a manufacturing organisation (Part-21 POA holder) for stating that a product, a part, or a component was manufactured in accordance with approved design data.
What that means is that the form accompanies an aircraft product, like say an engine, and if it’s not valid that product cannot be used. Organisations doing maintenance, repair and overhaul must keep detailed records when working on an aircraft.
As an example, in Europe we may have a British manufactured aircraft engine being fitted to a Spanish registered aircraft in a German hanger by an engineer who holds a Dutch licence. For this to happen in an approved manner the paperwork must be accurate, complete and valid. If the EASA Form 1 coming with the British manufactured aircraft engine is not recognised, then the work described above cannot take place.
I’ve described this situation because there’s the possibility that in a full “No Deal” Brexit there will be no automatic recognition of a British issued EASA Form 1.
This is not the first time I’ve mentioned the EASA Form 1. The reason for mentioning it again is that I became more acutely aware of this problem when visiting a major conference and exhibition in Amsterdam. On Wednesday last, I chaired a one-hour panel discussion on: “Regulatory Changes and Challenges”. This included a Policy Specialist (Brexit) from the UK CAA. He described the preparatory work that’s being done and some of the differences in positions between UK published papers and EU published papers. To date, the UK CAA and EASA are not in formal talks. Both are ready to initiate technical discssions but this is being held up by the lack of clarity in relation to the withdrawl agreement (See exchange of letters from June/July).
I conclude that rash headlines that suggest a “No Deal” option is doable are way off the mark. The regulatory maxim – trust but verify – must be satisfied one way or another.
2 thoughts on “Brexit and Aviation 40”
Agreed John: This is the tip of a substantial regulatory iceberg, not limited to the recognition, certification, installation and maintenance of aircraft products. There are many tasks that will be expected of the CAA, that it is not yet equipped or formally mandated for. Simply resurrecting old regulations will not suffice. The regulation of UK Airlines, ATC, Airports and the myriad of related products and services in line with current ICAO requirements (including updating UK regulation itself) needs urgent attention (and funding!).
As I understand it, all the applicable Regulations will be copied into UK law with a few changes along the way. If an agreement is put in place then a transition should be possible with the right level of trust and verification. However, the “No Deal” case isn’t one that anyone sane would opt for. It’s the ultimate loose-loose.