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Parts Approval in Europe Becomes a Reality

For years, PMA parts were a uniquely American product. But recent European events may suggest that others will be following our lead. BAE has been focused on obtaining design approval and production approval to create approved independent replacement parts under the European system.

On January 22, Graham Smith and Phil Beard explained how BAE has been obtaining replacement parts approval user EASA standards. They explained that BAE has been able to get European approvals that are very similar to US PMA approvals.

As with FAA PMA, they start with a significant review of a part in order to determine whether it is feasible to reverse engineer and produce the part. They perform a full reverse engineering operation. They develop their own engineering drawings. Like most modern PMA companies, they take special pains to avoid using OEM data to support their analysis in order to make sure tat they are avoiding misuse of someone else’s intellectual property.

Beard feels that the substantiation of these engineering documents is a little different from the U.S. process. He explained that EASA does not allow BAE to use identicality. Instead they must use positive substantiation of compliance with the airworthiness standards. He said that this generally comes from analysis, understanding of the part’s function, and testing.

As with test and computation PMAs in the US, the substantiation process that BAE uses permits them to fully understand the part, which in turn permits them to remedy reliability problems with the original design or make other improvements desired by the customer. Beard offered an example during his discussion; he commented that if service history has shown evidence of unexpected corrosion, then BAE might change the coating in order to better protect against corrosion.

BAE has made good use of its Design Organisation Approval (DOA) system, which allows BAE to operate under a government-controlled system in order to make findings of compliance up which the government can rely (similar to the ODA system in the United States). Smith and Beard affirmed that this system has been invaluable to their parts approval efforts.

BAE’s initial efforts appear to be largely focused on parts for Regional Jet Aircraft; but they are approved and willing to undertake work on all fixed-wing aircraft types.  This an exciting development for international trade in civil aircraft parts.

Planning on Having Your Company Literature Featured in MARPA’s Booth in Tokyo? Here’s How:

We previously wrote in this space that MARPA will be attending the  2013 Aerospace Industry Exhibition Tokyo (ASET). As a benefit to our members, MARPA plans to feature member-company literature in our booth to allow you to make connections with the Japanese aerospace manufacturing market.  This is just one of the benefits of MARPA membership.  ASET offers an excellent opportunity get in front of a substantial segment of the Japanese aerospace manufacturing community; at the last conference over 23,000 people attended!

In order to help us feature member companies in the MARPA booth, members must ship their literature to us in Tokyo.  To ensure we are able to showcase your literature, you must follow these steps:

1.  Act quickly!  ASET runs October 2-4.  You should plan to have your literature arrive absolutely no later than Monday, September 23.  This will allow adequate time to ensure your package clears customs.

2.  Ship your package to:

MARPA (Booth No. G-01)
c/o AEROSPACE INDUSTRY EXHIBITION TOKYO 2013
2013 Management office
Tokyo Big Site
3-11-1 Ariake, Koto-ku, Tokyo 135-0063, Japan
 

3.  Email Katt Brigham at MARPA with your package tracking information.  This should include the date the package was shipped and the estimated date of arrival.  You should also include the contents of your package so we know what to look for.

4.  Confirm your package arrives in Tokyo.  When you have confirmed arrival email Katt to let us know as well.

Remember it will take about a week for your shipment to clear customs upon arrival in Japan.  It is therefore vital that you ship your literature in time to ensure arrival by September 23.

MARPA is excited to be able to offer this opportunity to its members.  If you have any questions about shipping, please contact Katt at (202) 628-6777 or by email at katt@marpa.aero.

Opportunity for MARPA Members to Have Their Company Literature Presented Japan

MARPA is pleased to announce that we will be at the 2013 Aerospace Industry Exhibition Tokyo, and you can be there too!

While this is a fantastic opportunity for making connections in the Japanese aerospace manufacturing market, we recognize that not ever member can afford to add this to their trade show agenda, so MARPA will be featuring literature from members at their booth.  That’s right – you can have your company literature included in the MARPA literature rack at ASET 2013 in Tokyo!

COST: Free to MARPA members (it is a membership benefit).

HOW BIG IS THIS CONFERENCE: The last conference was in 2011 (it is held every two years) and there were 23,373 visitors for the aerospace trade floor.

YOUR REQUIREMENTS: YOU are responsible for producing your company materials.  YOU are responsible for shipping the materials to the convention center and for alerting us to look for it.

WHAT WE WILL DO: We will keep your literature in our literature rack or on our display table (depending on factors like size and volume of member response) and hand it out to interested conference-attendees.

HOW DO I GET STARTED: Contact Katt Brigham by calling or emailing the Association

OTHER CONFERENCE DETAILS:

The Aerospace Industry Exhibition Tokyo (ASET) is the only exhibition held in Tokyo dedicated to specialized aerospace technologies.  In addition to the unique business opportunity, ASET also features programs and lectures from key industry figures, as well as business and social networking events.

MARPA will have an exhibit booth for the three day event, October 2-4, 2013, and MARPA President Jason Dickstein will give a keynote address discussing PMA and the advantages that it represents.  This is an excellent opportunity to further raise industry awareness about the value and benefits of PMA and about MARPA itself.

DO YOU PLAN TO ATTEND?

ASET has asked for our help in getting the word out about this opportunity, as ASET is seeking PMA companies to join their PMA session.  The PMA companies would be asked to introduce their business to the attendees and participate in a PMA panel.  As inducement for participation, ASET is offering to provide exhibition booth space (three-day exhibition required) and potentially other inducements to PMA companies who are willing to present at the exhibition.

The city of Tokyo’s event planning subsidiary specifically requested the presence of PMA manufacturers at ASET 2013.  This is a great opportunity for our members to exhibit their products in front of a large audience in one of Asia’s key business hubs.  It is also a chance to further educate the aerospace community on the advantages of PMA.

If your company is interested in taking advantage of this opportunity, please contact ASET advisor Jay Kato via email at  jktechci@jcom.home.ne.jp.  ASET 2013 runs October 2-4, so it is important to act quickly.  MARPA hopes to see you there!

Updated Agenda for Int’l Safety Conference

Today, EASA issued an updated agenda for the 2013 EASA / FAA International Aviation Safety Conference.  The Conference is the annual meeting among EASA, FAA, TCCA and other regulators to discuss new paradigms in regulatory oversight.  This meeting directly impacts the aviation industry, which is the subject of this regulatory oversight!

The updated agenda provides better guidance on what to expect from the 2013 meeting.

Sessions that will be interesting to member of the PMA manufacturing community will include:

  • New Technology: A Challenge for Regulators
  • Safety Management and Global Harmonisation
  • Safety Continuum: Regional flexibility vs Global Harmonization?
  • Performance Based Oversight
  • Rulemaking Cooperation: towards a Regulatory Framework Based on Safety Oversight Data
  • The New Normal: Strategies for Safety Success in Fiscally Challenging Times
  • Compliance Assurance
  • Global Production: The New Reality

MARPA will be there and will be reporting on the new directions proposed by the regulators.

PMA Parts for Export to Europe – When is the PMA Part “Critical?”

Over the past few months, I have encountered a number of PMA exporters, and European PMA importers, who have asked for clear guidance on how to distinguish a “critical” PMA parts from a “non-critical” PMA part.

This is an important distinction because under the Bilateral Airworthiness Safety Agreement (BASA) that was signed between the United States and the European Union, there are three types of PMA parts that are accepted in the European Union (for installation on products certified or validated by EASA) without further showing.  Those three “acceptable” situations, as described in the BASA Technical Implementation Procedures (TIP) are:

(1) The PMA part is not a “critical component”;  or

(2) The PMA part conforms to design data obtained under a licensing agreement from the TC or STC holder according to 14 CFR §21.303; or

(3) The PMA holder is the holder of an EASA STC which incorporates the PMA part.

Thus, non-critical PMA parts are directly acceptable (and they should have text on their export 8130-3 tag that states “This PMA part is not a critical component”).  So there is a significant advantage to having a clear understanding of when a PMA part is critical and when it is not critical.

This can be a little confusing if you don’t know where to look.  The FAA has used the term “criticality” to define different categories of parts for approval purposes, and to set differnt levels of FAA involvement in the approval process.  The distinct use of the term means that we need to look in the right place for the definition of “critical” that applies to our export/import transactions.

For purposes of US exports of PMA parts that are imported into the European Union, the controlling guidance is found in the BASA’s Technical Implementation Procedures for Airworthiness And Environmental Certification (BASA TIP). The definition of critical component for purposes of that document is found in Section 1.6(i) of the BASA TIP:

“Critical Component” means a part identified as critical by the design approval holder during the product type validation process, or otherwise by the exporting authority. Typically, such components include parts for which a replacement time, inspection interval, or related procedure is specified in the Airworthiness Limitations section or certification maintenance requirements of the manufacturer’s maintenance manual or Instructions for Continued Airworthiness.

Don’t fall for the temptation draw a semantic difference between a “critical component” and a “critical part.”  The PMA acceptance procedures found in section 2.8.2(a)(1) of the BASA TIP explicitly cross reference the definition in section 1.6(i).

In light of this definition found in the BASA TIP, the question of whether a PMA part is “critical” will be based on the decision of the FAA (the exporting authority) about whether it was critical at the time of approval.

The regulatory guidance for critical parts is found in the marking requirements discussion in section 45.15(c) of the FAA’s regulations. That section makes it clear that an article is “critical” if it has a hard time specified in the Airworthiness Limitations section of the manual (instructions for continued airworthiness), like a life limit, then it is a critical part (or critical component).

Under normal circumstances, there are two methods for specifying such a limit on a PMA part. The first is during the FAA approval process (usually as an airworthiness limitation published in the instructions for continuous airworthiness), when the airworthiness limitation section associated with the part would be approved. The second is by an FAA airworthiness directive issued after initial approval in response to an identified safety issue.

Thus the best source for identifying whether a PMA article is “critical” is the PMA manufacturer, who should be able to tell customers whether there were any such hard times associated with the article as part of the approval process (or review of the PMA manufacturer’s instructions for continuous airworthiness).  If the FAA did not establish that the part was critical at the time of approval, and if they did not subsequently issue an airworthiness limit (such as through an airworthiness directive), then the part is not critical.

How Might REACH (European Environmental Regulations) Affect Your Business?

The U.S. Commerce Department will hold a webinar on November 29 to discuss the effect of European Evironmental Regulations on  U.S. Aerospace companies.

The European Union has a regulation called the REACH regulation.  REACH stands for Registration, Evaluation, Authorisation & restriction of CHemicals.

REACH imposes certain obligations on companies that manufacture certain chemicals in Europe, and on companies that import certain chemicals into Europe.  Under REACH, the continued marketing of substances of Very High Concern (SVHCs) requires an authorization. Businesses active in the aerospace marketplace use a number of substances that are being considered for SVHC classification, and unauthorized import into Europe of such substances could violate REACH.

For more information, see the notice on the Commerce Department website.

MARPA 2012 is the Place to Do Business: Air Carrier Update

Need to meet with air carriers about your PMA parts?  They will be at the 2012 MARPA Conference, and they will be looking for PMA solutions.

MARPA has 40 pre-registered air carrier representatives from 17 different air carriers attending the 2012 Annual Conference in Las Vegas:

  • Air Canada
  • ANA
  • Allegiant Air
  • American Airlines
  • American Eagle Airlines
  • Bismillah Airlines
  • Copa Airlines
  • Delta Air Lines
  • Horizon Air
  • Japan Airlines – JALUX
  • Kenya Airways
  • SkyWest Airlines
  • Southwest Airlines
  • United Airlines
  • UPS
  • US Airways
  • Westjet

For a complete look at the pre-registered attendees for the Conference, please be sure to check out our pre-registration list, which was published on September 22.  This list is not complete, as we always have had a significant numbers of attendees who register in the lat week or at the door; but it does provide a reasonable look at the businesses that have already made a commitment to attend.

Last Chance to Book a Hotel Room at the MARPA Discounted Rate

The MARPA 2012 Conference will be held in a month, on October 3-5, 2012 at the Renaissance Las Vegas Hotel.  But the deadline for making hotel reservations at the discounted rate is Monday, September 3!

We have negotiated a room rate of $129.00 per night (not including taxes) for single/double occupancy. This rate applies on a limited basis for rooms up to three days before and after the event, for those who wish to extend their stay. This is the lowest rate available to any group at the Conference Hotel during this time period!  In order to qualify for this special rate, you must book your room by Monday, September 3, 2012. Click here for a link to the hotel for the MARPA room block. Clicking this link should automatically reference the 2012 MARPA discount code (which is mrpmrpa).

You can also call the hotel directly at (800) 750-0980. Make sure to ask for the “MARPA” rate in order to get our discounted rate!

U.S. Government Almost Ready to Publish Export Reform

MARPA has reported on, and vocally supported, the Administration’s plans to revise the U.S. export rules in a way that makes it less complex to export aircraft parts.

The Hill Reports that the Administration is getting ready to publish the first of these export revisions.

Those of you who’ve seen me speak on export law in the past year know that I have been predicting that the Administration will take far less than the normal 18 months to publish the final rule in the export reform provisions.  While most people deride election cycle politics for its emphasis on form over substance, and a tendency for both parties to block partisan gains that might help the other earn votes, this is one situation where election year politics work in our favor.  The Administration would like to be able to take credit for making it easier for businesses to export products, in order to show that they are not anti-business.  The export reforms will do just that.

If the final rule looks like the proposal, then it will ease unnecessary burdens on the export of many dual-use aircraft parts.  With many dual-use aircraft parts (replacement parts that can be installed on both civilian and military aircraft), their precise placement into BIS or DDTC jurisdiction can be ambiguous, and can be based on facts that are not readily available to many exporters.  For example, the mechanism for obtaining a license to export a replacement part that is listed on both a military engine design and a civilian engine design (approved by the FAA) is very ambiguous, because it can be unclear whether the FAA exception applies [originally published in the 1979 Export Administion Act section 17(c), the exception has been turned into a rubik's cube with contradictory guidance].

The proposed rule would move all of the dual use aircraft parts into BIS jurisdiction, leaving only parts with a clear defense mission in the jurisdiction of DDTC.

This is important to exporters because (1) many BIS exports do not need a license while nearly all DDTC exports require a license, and (2) even if a license is necessary, it is far quicker and easier to obtain a license from BIS than it is from DDTC.  It is also useful because there has been a lot of confusion about which agency’s rules must be followed for certain aircraft parts, and the reform would make the pathway to compliance much more clear.

MARPA Annual Conference Hotel Information – Reserve Your Room Before They Sell Out

The MARPA 2012 Conference will be held October 3-5, 2012 at the Renaissance Las Vegas Hotel.  Please make your reservations early for the Conference: the hotel has sold out early for the past several years and we expect the hotel to sell out again this year.

We have negotiated a room rate of $129.00 per night (not including taxes) for single/double occupancy. This rate applies on a limited basis for rooms up to three days before and after the event, for those who wish to extend their stay.  This is the lowest rate available to any group at the Conference Hotel during this time period!

In order to qualify for this special rate, you must book your room by Monday, September 3, 2012. Click here for a link to the hotel for the MARPA room block. Clicking this link should automatically reference the 2012 MARPA discount code (which is mrpmrpa).

You can also call the hotel directly at (800) 750-0980. Make sure to ask for the “MARPA” rate in order to get our discounted rate!

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