[AT-ASB] FW: FW: EPA Marking References

Thu Feb 11 08:32:32 EST 2021

Hello All:

Please see the message from Michael.

Sam

From: Kröger, Michael <michael.kroeger at airbus.com>
Sent: Thursday, February 4, 2021 11:01 AM
To: Sam Buckwalter <Sam.Buckwalter at sae-itc.org>; Samson Yimesgen <samson.s.yimesgen at airbus.com>
Subject: Re: [AT-ASB] FW: EPA Marking References

Hi Sam
Please have a look at ATAiSpec 2200
Section 3-3-4. covers Service Bulletins (SB)
The Approval details are given in Paragraph 3.2.6.Approval
[cid:image002.png at 01D70050.7023FF70]

Best regards
Michael

Michael Kroeger
Head of Cabin & Cargo Service Bulletins
Customer Service - SEMBC
AIRBUS

Phone: +49 40 743 77337
Mobile: +49 160 535 6518
Mailto:michael.kroeger at airbus.com<mailto:michael.kroeger at airbus.com>

AIRBUS Operations GmbH
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21129 Hamburg
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Airbus Operations GmbH
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Am Do., 4. Feb. 2021 um 16:31 Uhr schrieb Sam Buckwalter <Sam.Buckwalter at sae-itc.org<mailto:Sam.Buckwalter at sae-itc.org>>:
See message from Oliver.

Sam

From: PREUSS, OLIVER DANIEL <oliver-daniel.preuss at lht.dlh.de<mailto:oliver-daniel.preuss at lht.dlh.de>>
Sent: Thursday, February 4, 2021 10:30 AM
To: Sam Buckwalter <Sam.Buckwalter at sae-itc.org<mailto:Sam.Buckwalter at sae-itc.org>>
Subject: EPA Marking References

Hello Sam,

please find the reference below.

Kind regards

Oliver

https://www.easa.europa.eu/faq/20095

Why and how must Parts and Appliances be marked, when are the letters EPA required, and which exceptions are acceptable?
Answer
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’.
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. 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. 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.
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”. 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.

____________________________
Oliver D. Preuß, Dipl.-Ing. (FH)
Senior Component and Production Engineer
Avionic & Radio Components
Component Services

Lufthansa Technik AG
HAM T/CE 43/E
Weg beim Jäger 193
22335 Hamburg, Germany
Phone: +49-40-5070-67653
oliver-daniel.preuss at lht.dlh.de<mailto:oliver-daniel.preuss at lht.dlh.de>
www.lufthansa-technik.com<http://www.lufthansa-technik.com/>

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