How shall I maintain my certified emergency parachute?
Answer
Emergency parachutes are not installed on aircraft as a component, except when they are a part of the type design. As a consequence, emergency parachutes are not subject to the continuing airworthiness / maintenance requirements of Commission Regulation (EU) No 1321/2014 (in particular its Part M and Part ML), except when they are a part of the type design.
The owner of the emergency parachute is responsible for keeping the emergency parachute in a proper condition in accordance with the approved instructions published by the manufacturer. In particular:
- Packing of emergency parachutes shall be performed in accordance with the approved instructions published by the manufacturer. There might be additional national regulations which might also have to be considered.
- Any repair or maintenance, other than packing, in accordance with the approved instructions, should be carried out only by either the parachute manufacturer or an organisation which is authorised by the manufacturer except when the emergency parachute is to be treated as part of the type design.
- When the emergency parachute is to be treated as part of the type design, any repair or maintenance, other than packing, in accordance with the approved instructions, is a component maintenance falling under Part-145 or Part-CAO.
Furthermore, when carried on board aircraft, relevant mandatory safety information issued by the European Union Aviation Safety Agency (EASA), including airworthiness directives, need to be complied with, as required by either point ORO.GEN.155 (b) or point NCO.GEN.145 (b) of Commission Regulation (EU) No 965/2012, point SAO.GEN.120 (b) of Commission Implementing Regulation (EU) 2018/1976, or point BOP.BAS.020 of Commission Regulation (EU) 2018/395.
Under Rulemaking Task RMT.0727, EASA is currently developing the implementing rules for the certification of non-installed equipment in accordance with Article 13 of Regulation (EU) 2018/1139. Ultimately, those future rules may contain requirements for the maintenance of non-installed equipment, and emergency parachutes may be(come) subject to those.