Where in the safety directives are the instructions for spare parts or service 
parts. We manufacture a device for an end customer but don't do the safety 
approvals - we are just designated as a factory. I haven't seen any activity in 
getting this device approved under the new edition of the standard and am 
concerned that it has fallen through the cracks by the customer.
I don't believe it's a current production system but they are maintaining the 
systems already in the field, meaning that this are service parts I believe, 
but I don't know exactly what allows them to continue importing them into 
Europe.

The real issue is that some of the plastic that had been used in the past isn't 
going to be available but it is described as a critical component in the safety 
files by manufacturers name. model type. We can replace the material with the 
same flame rating but the raw material is from a different supplier. Even if 
spare parts are allowed for a system with an out of date harmonized safety 
standard I don't think one can just change the components without some 
activity, but exactly what and how, add some notes to the technical file?

I've tried discussing the issue with the customer but can't get through the 
purchasers to the compliance people, to insure that this isn't just slipping 
through the cracks.




Esterline Interface Technologies

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