The FAA is proposing changes to the Part 21 manufacturing rules. A number of these will impact PMA holders. It will be important for the PMA community to provide comments to this NPRM.
The proposed changes include:
With respect to the new permission for PMA holders to issue 8130-3 tags, the FAA confirms that the intent is to permit manufacturers to issue the 8130-3 tags, although the NPRM appears to be missing an explicit authority to issue such a release. Instead, the NPRM as drafted requires a procedure for managing the 8130-3 tags process; but subpart L continues to require application to the FAA for issue of an 8130-3 tag. This is something that will need to be changed if the FAA is to successfully implement this provision.
If the proposal becomes a regulation, the rules would include a requirement for supplier control and a parallel requirement for ensuring conformity of supplier products. This appears to suggest that supplier control must be supplemented with 100% conformity verification of incoming supply; but more importantly it would also mean that non-conforming supplier-provided-parts would represent a regulatory violation even when they are caught in the PMA holder’s incoming inspection! This seems to be inappropriate.
The proposed rule is scheduled to be issued in tomorrow’s Federal Register. An advance copy is available online today at https://s3.amazonaws.com/public-inspection.federalregister.gov/2014-04330.pdf.
One of the best classes I attended at the AVM PMA Summit in London last week was focused on management skills for an engineering environment.
George Ringger lead a session focused on the difference between decisions and goals in the manufacturing business environment. Ringger has taught at Embry-Riddle and advised business on manufacturing and continuous airworthiness subjects in both the quality and engineering disciplines, so he has seen what works and he has seen what does not work.
He began by explaining that a goal is something you are trying to achieve, and decisions are the choices we make as we try to meet our goals. Using this simple dichotomy as the basis, he laid out a very-effective system for effective and successful management in the modern aerospace workplace.
Ringer presented a case study in which the management goal was to reduce development costs. The business decided to go from three prototypes to one prototype. This should have saved 66% on the prototype costs, but the prototype failed and this resulted in a 12 week delay in the program while a second prototype was built.
Other examples of poor decisions can include using structural analysis when testing is faster and less expensive (or vice-versa). It is important to use the right approach to PMA development! because the correct choice can vary with the parrts.
In case study number two Ringger discussed a. PMA company that reverse engineered a nose landing gear bushing. In fact, the nose landing gear featured 12 bushings that were identical except for dimensions (particularly the materials were identical). By limiting the analysis to only one bushing, the company missed an opportunity to PMA all 12 of the bushings at the same time.
In case study number three, Ringger discussed a. PMA company that reverse engineered a part that perfectly matched the OEM part. But the customer had issues with premature failures on the OEM part, so the failure to engineer the part from the ground up meant that the PMA manufacturer failed to redesign the part and correct the features leading to customer disappointment. This shows that it is important to know what your customer’s concerns are and to choose a design method they permits you to meet the customer’s needs.
By using effective management, Ringger explained how to overcome limitations in order to develop an internal user-centric system. The purpose of this system is to ensure that your parts designs will meet customer needs and desires. He also discussed strategies for setting SMART goals. He discussed his SMART squared approach to goal setting in order to motivate engineers to make smart decisions and achieve results. Goals should feature these ten qualities:
In his program, Ringger explains how each of these elements help to ensure that you establish effective goals, make decisions that support your goals, and develop work assignments to support the decisions.
This was one of the best presentations I have seen for managing engineering staff. We have already reached out to Ringger to invite him to speak at the 2014 MARPA Conference in Las Vegas. Everyone who manages a technical staff should make plans to attend his session!
The FAA has issued two new PMA guidance documents for comment. One of these is a document affecting engine PMA applications (PS-ANE-33.3-05) and the other is a document affecting propeller PMA applications (PS-ANE-35.15-02). Each of them would require additional internal FAA coordination for certain engine and propeller PMA projects.
Under the new policy, when an Aircraft Certification Office (ACO) accepts an application for a PMA for an engine part or a propeller part, where a failure of that part could result in the total loss of thrust or power, the ACO is required to coordinate the project with the office that manages the type certificate and the Engine and Propeller Directorate. Coordination is accomplished by entering the project into the national certification project notification (CPN) database.
While better management of coordination should be a good thing, the reason for such coordination is to obtain more input from the other offices. There are two possible concerns associated with that additional input that should be addressed but that are not raised in this guidance: (1) decreased FAA efficiency in turning projects, and (2) increased potential for release of sensitive business data.
The guidance asserts that the CPN process should not add burden to the PMA applicant. This does not consider, however, whether the process may add additional lag time in processing the PMA applications. If the certificate management office and the Directorate request additional time to study the project and add their comments, then this could slow down the turn-around-time for reviewing packages. We have been made aware of instances where local offices disagreed with a directorate about a technical matter, and the PMA applicant was the real victim, as the two FAA offices brought the application to a stand-still while they hashed out their differences.
In addition, PMA applications are often considered to reflect sensitive company data, because they reveal the company’s business plan. If a certificate management office starts asking questions about a part, even without revealing which company has filed the PMA application, it could still alert a type certificate holder to the potential for competition and the type certificate holder may take action to protect their market in that part before the PMA part is approved (which would be unfair).
But one positive aspect of such coordination is that the certificate management office or the Directorate may have useful information not readily available elsewhere. For example, they may have service information that helps to show where the original type certificated part was not performing as expected. This information could give the PMA applicant an opportunity to improve the part so that it meets customer expectations.
The FAA has opened these two policies up for comment through March. MARPA members who want MARPA to comment on either of these draft policies should let us know by the end of February.
Today’s Federal Register announced that some of the manufacturing policy-makers at FAA Headquarters will merge into a single unit. The engineering division and the production division are currently separated into two different offices, and they will become one office effective February 9.
Today, in addition to the office of the director, there are five different offices/divisions within the FAA’s Aircraft Certification Service:
This change will merge AIR-100 and AIR-200 into a single division, which will be known as the Design, Manufacturing, and Airworthiness Division, and will bear the mail-stop code AIR-100. The new division will feature five branches:
The Aircraft Certification Service (AIR) Organizational Design Concept (AODC) has been working for several years on ways to better organize Aircraft Certification. AODC identified some overlap in certain functions being performed by AIR-100 and AIR-200. The merger allows the two divisions to reduce some duplication in those administrative functions.
David Hempe, who leads AIR-100 today, will continue to lead the merged division.
This could be your chance to affect the rewrite of an important engine certification rule! The FAA has asked the Aviation Rulemaking Advisory Committee (ARAC) to look into engine endurance testing pursuant to 14 C.F.R. 33.87.
An engine endurance test is an accelerated severity test intended to demonstrate a minimum level of engine operability and durability within the approved engine ratings and operating limitations. The test running conditions cover the declared engine rating and operating limitations, but are not intended to precisely simulate the expected in-service operation.
The FAA has found that applicants need to modify their engines in order to meet the testing requirements of section 33.87, but that these modified engines are no longer accurate representations of the type design. Thus, there is a worry that modern engine technology has progressed to the point where section 33.87 no longer meets its intended function.
Dorina Mihail of the FAA Engine and Propeller Directorate is looking for engine technical experts to serve on the working group examining this rule. The FAA must receive all requests by February 11, 2014, so if you are interested in having MARPA promote your application to the working group. then please contact us before then.
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.
The PMA industry has an opportunity to affect the FAA reporting rules for manufacturers!
Design approval holders are required to report certain occurrences to the FAA under 14 C.F.R. 21.3. That rule requires reporting to the FAA of any failure, malfunction, or defect in any product or article that could lead to (or that results from) any occurrence on the FAA’s list of occurrences found in section 21.3(c).
The current rule was originally designed to provide the FAA with information that the FAA needs in order to be able to take appropriate mandatory safety actions, like issue Airworthiness Directives (see Reporting Requirements for Manufacturers; Failures, Malfunctions and Defects, 35 Fed. Reg. 3154 (February 18, 1969)). But the rule has been accused of being both overbroad (it requires reporting of occurrences that would never be used by the FAA in relation to mandatory action) and under-inclusive (it also fails to require reporting of unlisted occurrences – and some unlisted occurrences could be safety issues about which the FAA ought to be receiving reports).
The FAA’s Part 21 Aviation Rulemaking Committee (ARC) will be proposing sweeping changes to the FAAAA’s manufacturing rules, including changes that implement design organizations (comparable to the European DOA Part 21 subpart J regulations) as well as changes that would more clearly implement Safety Management Systems (SMS) requirements for manufacturers. Part of this process is expected to include changes to 14 C.F.R. 21.3 in order to correct some of the existing issues, better synchronize the data requirements with the new SMS obligations, and make the rule more responsive to the FAA’s evolving data needs.
The sub-team working on 21.3 kicked off their first meeting yesterday. The group highlighted the belief that the current 21.3 too often requires reporting of occurrences with low associated risk, and this can mask the higher risk occurrences in a way that undermines safety. They also discussed high risk occurrences that may not meet the 21.3 list criteria and therefore may not be reported to the FAA. As a consequence, the group discussed two different options – one was changing the list and the other was removing the list entirely and replacing it with a reporting criterion that would more accurately influence reporting to the sort of reports that are most useful to the FAA in pursuing its safety mission. The argument in favor of the latter option was that today’s aircraft design and safety management practices have evolved such that the 21.3 list of occurrences is no longer the most efficient way to describe reportable items.
MARPA is an active part of this group. If you have thoughts about 21.3, please share them with your trade association, so we can make sure your good ideas are considered! This can include examples of how you have implemented reporting in your facility, examples showing when 21.3(c) is too broad or when it is too narrow, and thoughts about the best way to improve the reporting regulation.
In mid-December the Commodity Classification Standards Board (CCSB) issued a Notice of Proposed Amendment to the National Motor Freight Classification. Specifically, the proposed amendment seeks to make certain reclassifications relating to helicopter rotor blades and leading edge coverings, and make clarifications regarding aircraft propeller blades. Those companies that manufacture and ship rotorcraft blades and leading edge coverings may wish to review the proposed amendment to determine the potential cost effects of the proposed reclassifications.
The National Motor Freight Classification is a voluntary standard that assigns classes based on a product’s transportation characteristics, and provides a comparison of those products when they are shipped via motor carrier. The transportation characteristics of a product are determined based on its dimensions, density, ease of handling, and potential liability due to damage or other factors. Products once classified are assigned a class name (e.g., Class 50; Class 100; Class 300) with higher class names generally having a greater cost to ship.
The provisions pertaining to leading edge coverings and rotor blades were initially developed in the 1950s. Leading edges were assigned item number 12110 and rotor blades 12130, and freight classes 70 and 100, respectively. In the intervening years, technological advances in manufacturing and materials have resulted in leading edges and blades becoming longer and less dense. The effect of these advances is that the original freight classes assigned to the item numbers no longer accurately reflect the shipping characteristics of leading edges and blades of increasing length.
The proposed amendment suggests that as edges and blades grow longer and less dense, the costs of handling, practicalities of stowing, and potential liability due to damage increases, and therefore items of increasing length should be assigned differing freight classes to reflect the varying transportation characteristics. The amendment therefore makes two proposals: First, it would cancel item number 12110 pertaining to leading edges and redefine item 12130 to include both rotor blades and leading edges. This is due to the understanding that leading edges and rotor blades have similar transport characteristics.
Second, the amendment would assign different freight classes to blades of increased lengths as follows:
|Greatest Dimension||Proposed Class|
|Exceeding 288 inches||300|
|Exceeding 192 inches but not exceeding 288 inches||175|
|Exceeding 96 inches but not exceeding 192 inches||100|
|Not exceeding 96 inches||92.5|
These proposed classes greatly exceed the current freight classes assigned to leading edges and blades, and as such have the potential to substantially increase transportation costs. It should also be noted that the proposed classes exceed the class suggested by CCSB’s own density guidelines.
A final element of the proposal would also specifically exclude rotor blades and edges from category 12280 pertaining to aircraft propeller blades to avoid confusion or ambiguity.
Persons with information regarding the transportation characteristics of rotor blades and leading edge coverings are invited to submit a written statement to CCSB prior to their meeting on Tuesday, January 28, 2014. Information regarding this proposal may be found at CCSB Docket 2014-1. Manufacturers should take the opportunity to review the docket and data therein to determine what potential effects such reclassifications would have on their shipping and transportation costs, as well as to determine if the proposed classes are reasonable based on the transport characteristics of the articles.
As many of you know, MARPA has been an active participant in the FAA’s efforts to develop both Design Organization and SMS regulations that would apply to the manufacturing community. This gives our members an exceptional opportunity to influence the regulations so that they will make sense and preserve safety.
The FAA is working on regulations that would require most design approval holders to be Design Organizations, which would be similar to EASA DOAs (under EASA subpart J in Europe). FAA Engineering Division Manager Dave Hempe will be at the MARPA Annual Conference to talk to companies about the costs and benefits of such a requirement.
The smallest companies (including many PMA companies) could be excepted from those design organization rules. But even those excepted companies will likely have to met some standard; the lower risk posed by excepted companies would mean that the standards applied to them could be lower.
This raises the question “how much of an organization SHOULD a small company be required to have as a minimum FAA standard?” We will be looking to the PMA community to help answer this question!
Soon, we will be soliciting volunteers for a limited engagement subcommittee that will be tasked with recommending those minimum standards. We anticipate that volunteers will be expected to commit to participate in between one and three one-hour-long telephone conferences – there will be no live meetings and no travel required. The purpose of those calls will be to solicit input about minimum standards that could apply to all design approval applicants and holders (even the smallest ones).
We really are going to need your help on this so please consider donating your time in order to register your opinion about what is reasonable for your business to do.
We will be publishing more details soon, but please contact us if you think you would like to participate!
Last week MARPA filed comments with the FAA in response to two policy documents that directly affect PMA manufacturers. As we previously explained on this blog, both of these documents speak directly to the PMA approval process.
Draft revision D to FAA Order 8110.42 Parts Manufacturer Approval Procedures. Two notable changes made in the revision was the removal of guidance to PMA applicants (released as a stand-alone document as draft AC 21.303-PMA) and the inclusion of a section directing ACOs to apply the FAA Risk Based Resource Targeting (RBRT) tool. It also made certain technical changes to the Order to update citations and keep up with rule changes.
MARPA observed that the inclusion of RBRT in the Order creates the risk of unequal treatment across—or even within—different offices. This is because the RBRT tool attempts to create the appearance of objectivity by assigning numerical values to what are essentially subjective evaluations by FAA personnel. Because the tool offers no metric, rubric, or guidance to aid FAA personnel in assigning values, it is possible for even identical projects to be assigned different risk values based on the subjective assessments of personnel. The ultimate result is that highly similar projects could be allocated markedly different resources.
Draft Advisory Circular 21.303-PMA updates the FAA guidance to applicants for PMA of articles submitted on the basis of test and computation or identicality without a license agreement. This guidance is for the most part a recast of the guidance that formerly appeared in Order 8110.42C. MARPA offered suggestions for improving the guidance related to sample sizes required for test and computation analysis, as well as general comments seeking to clarify the guidance.
In both documents, MARPA commented that the FAA should include a section describing use of the Streamlined PMA application process.
We plan to meet with representatives from the FAA in person to further discuss these comments. FAA personnel will also be at the MARPA Conference in Las Vegas, October 23-25, and available to discuss PMA guidance and other initiatives. MARPA will continue to work with the FAA to ensure that the guidance enhances safety while limiting burden to our members and the industry.