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MARPA Files Comments on FAA Geometry AC

MARPA recently filed comments on the FAA Engine and Propeller Directorate’s draft Advisory Circular 33-Geometry, discussing geometry and dimensional considerations for comparative test and analysis for turbine engine and APU replacement parts.  In a previous blog post we observed that AC identified a number dimensional and geometric factors that the FAA expects to be assessed in ensuring the integrity of dimensional characteristics for the purposes of showing similarity.

We requested feedback from our members describing to what extent the FAA’s expectations were reasonable and practicable, and identifying any issues with the proposed guidance on which MARPA should comment. We received several very helpful responses from our members that helped us shape our comments to the proposed AC. Among the issues members identified were:

    •  Possible confusion over availability of existing industry guidance;
    •  Apparent inconsistency with existing FAA guidance;
    •  Inaccurate implications that product testing is the only method available to collect data for lifing methods of life limited parts; and
    •  Issues regarding the specific practice of part selection for selective assembly components.

Feedback from our members is both helpful and valuable to our comments, as it helps us to identify issues that directly affect members’ businesses, and helps us to better focus our resources on those matters that are important to the PMA community.  The result is more detailed and on-point responses to the FAA to better help shape the guidance material that will ultimately be issued.

We greatly appreciate the feedback we received from our members on this Advisory Circular, and we hope that our members will continue to answers our requests for responses as additional guidance and rulemaking documents are issued.  Together we can work with the FAA to develop the best possible guidance for our industry.

Your Feedback Needed on Engine Endurance Test Draft AC

The FAA is currently seeking comments on its Draft Advisory Circular Engine Overtorque Test, Calibration Test, Endurance Test, and Teardown Inspection for Turbine Engine Certification (§§ 33.84, 33.85, 33.87, 33.93).

As the title suggests, the AC offers guidance on compliance with the engine overtorque, calibration, and endurance tests, and teardown inspection called out in Part 33 of the Federal Aviation Regulations.  Although the guidance is directed at engine manufacturers, foreign regulatory authorities, applicants for engine type design approval, and FAA designees, it also notes that parts manufacturer approvals “may require running certain endurance testing for compliance with § 33.87″ and refers to AC 33.87-2 for guidance on showing compliance by comparative test methods.

MARPA would like to know to what extent members anticipate this AC might effect them, and whether we should submit comments.  If you plan on submitting comments, or have already done so, we would would like your feedback so that we can incorporate member concerns into our comments.

Comments on the Draft AC are due next week, so if you have feedback for us please submit them to ryan@washingtonaviation.com soon!

New Guidance for PMA Via Tests and Computations or Identicality: Forthcoming

Today, the FAA announced the issue of AC 21.3o3-4.  The title of this AC will be “Application for Parts Manufacturer Approval Via Tests and Computations or Identicality.”

As of this time, the AC is not yet available to the public.  When it is available to the public, it is expected to be posted online at this location:

http://www.faa.gov/regulations_policies/advisory_circulars/index.cfm/go/document.information/documentID/1024227

Note: the issue date published on the FAA’s website is March 21, 2014; however the AC is not yet available through the FAA’s online advisory circulars, nor through the Regulatory and Guidance Library (RGL).  The note on the FAA’s website states “This document‘s content is not currently available.”

New Draft AC Could Affect Engine PMA Manufacturers

The FAA Engine and Propeller Directorate has issued a new draft Advisory Circular that could have a significant effect on companies seeking PMAs, STCs, or approval of repair or alteration of turbine engine and APU parts.  Draft AC 33-Geometry: Geometry and Dimensional Considerations for Comparative Test and Analysis for Turbine Engine and Auxiliary Power Unit (APU) Replacement, Redesign, and Repaired Parts is directed at applicants who use comparative techniques to reproduce dimensional characteristics of parts during the reverse engineering process.

The AC is intended to provide guidance to help PMA (and other) applicants assess their reverse engineering methods to identify possible causes of dimensional inaccuracies, as well as helping applicants develop adequate criteria for determining dimensional similarity between the PMA design and the sample.  To that end, the draft AC identifies several dimensional and geometric factors that the FAA expects should be assessed in seeking to ensure the integrity of dimensional characteristics for the purposes of showing similarity.  These factors range from geometric relationships to precision and accuracy to influence on critical parts.

The background section of the draft AC states that because reverse engineering methods vary in their measurement techniques, interpretation and combination of data, and in dimensioning systems, they do not typically produce a design with the exact same dimensional properties as the type design part.  It further explains that because dimensional differences may exist, functional assessments–which may include both test and supplemental analytical data–will be necessary to safeguard type design functional properties, as well as capabilities of interfacing and higher level assemblies.  Such explanations help to illuminate the FAA’s expectations of an applicant in making showings of dimensional similarity.  MARPA would like feedback from our members describing to what extent such test data is currently available and practical within the industry.

Although this AC, like all Advisory Circulars, is neither mandatory nor regulatory, such guidance documents do sometimes become ingrained and relied upon in considering applications.  It is therefore important to review the draft and offer comments to the FAA to ensure the guidance reflects the realities of our industry.  MARPA will be closely reviewing the guidance and offering comments on behalf of the PMA community.  If you identify any particular issues within the guidance, please bring them to our attention so we can incorporate them into our comments.  Email your concerns to ryan@washingtonaviation.com.  We also recommend that members who identify concerns file their own comments on the guidance.  Comments are due July 3, 2014 and should be submitted to Mark Bouyer of the Engine and Propeller Directorate, at mark.bouyer@faa.gov

New FAA PMA Policy Documents have been Issued

In recent weeks the FAA has released final versions of two important pieces of guidance.  FAA Order 8110.42DParts Manufacturer Approval Procedures, which cancels revision C, was published on April 10, and FAA AC 21.303-2Application For Parts Manufacturer Approval Via Tests and Computations Or Identicality, was published on April 7.  Both of these documents have a direct effect on PMA producers.

MARPA submitted comments addressing issues in these guidance documents in September, 2013.  Among the issues MARPA noted was the intended use in Order 8110.42D of the FAA’s Risk Based Resource Targeting Tool (RBRT tool) to prioritize PMA projects.  MARPA observed that the RBRT tool as intended relied on subjective assessments of project risk that could result in unfair treatment of certain PMA projects.  The FAA agreed that the RBRT tool was not quite ready for prime time and has removed it from the Order.  MARPA will remain vigilant, however, as guidance for use of the RBRT tool will be addressed in a future Order.

MARPA also worked with its members to offer comments and feedback to the FAA regarding AC 21.303-2.  This new AC consists primarily of guidance to PMA applicants that formerly appeared in the now-cancelled Order 8110.42C.  MARPA offered comments addressing the expected sample sizes needed for PMA applications based on test and computation, origins of samples, and discretion for establishing sample sizes.  The FAA’s adoption of these comments should better help square the advisory guidance with the realities of industry sampling.

MARPA also commented that references to Order 8110.119 - Streamline Process for Parts Manufacturer Approval (PMA) should be included in both documents to encourage use of the Streamlined PMA process when applicable. We are pleased that the FAA agreed and adopted references to the Order in both guidance documents.  We are hopeful that the inclusion of references to Order 8110.119 in both Order 8110.42D and AC 21.303-2 will further promote ACO acceptance and PMA applicant use of the Streamlined PMA process.

Both of these guidance documents are now active.  Members should familiarize themselves with the guidance, as it will inform the nature of the application process and the relationship with the FAA and your ACOs.  In reviewing the two documents, if you notice anything troubling or that seems out of place, please bring it to our attention so that we can work with the FAA to find a solution.  Send your thoughts on Order 8110.42 revision D and AC 21.303-2 to ryan@washingtonaviation.com.

MARPA Comments on New FAA PMA Policy

In January, we wrote in this space about two new FAA Policy Statement proposals aimed at increasing coordination between FAA offices in the cases of certain engine PMA and propeller PMA applications.  MARPA is always on the lookout for those potential regulations and policies–whether large or small–that could effect our members.  In an effort to best support the industry, MARPA solicits feedback from members and files comments addressing the concerns of the PMA community with the FAA.  MARPA also works to support the FAA in order to provide industry’s perspective and needs in order to help develop the best rules, policy, and guidance possible.

Last week we filed comments on draft policy statements PS-ANE-33.3-05 and PS-ANE-35.15-02. These two statements were substantially similar in content, and therefore raised similar concerns.  The policy statements are intended to create a uniform policy describing the engine and propeller PMA projects for which an ACO is required to use the national certification project notification (CPN) database to alert the Certification Management ACO (CMACO) and Engine and Propeller Directorate (EPD) about the project.  The purpose is to enable the CMACO and EPD to provide relevant input when the PMA application is for a project the failure of which may result in a loss of thrust or power.

MARPA noted several possible issues with the proposed Policy Statements.  First, our comments noted that the policy as proposed could run the risk of burdening PMA applicants by delaying response time, as each FAA office took the opportunity to review the project.  MARPA also noted the risk that differences of opinion between offices could be hashed out using an individual PMA application as the mechanism.  This could also result in undue burden to the applicant.  Finally, MARPA noted that inquiries by FAA offices about certain PMA projects could inadvertently alert TC holders of possible competition in a particular part market, and give that TC holder the opportunity to lock up the market before the PMA package is ever approved; a clear unfair competitive advantage.

Finally, MARPA noted that a certain provision uniquely included in PS-ANE-33.3-05 (the engine-PMA Policy Statement) was needlessly critical of PMAs and potentially harmful to the PMA industry. The sentence in question reads “[f]ailure of some of these engine PMA parts has resulted in unsafe conditions and the issuance of airworthiness directives.”  MARPA explained that this sentence was inappropriate for two reasons.  First, it incorrectly implies that PMA parts are abnormally unsafe and that TC products do not have a history of resulting in ADs.  Second, the sentence in no way advances the purpose of the Policy Statement, which is to establish uniform standards for use of the CPN database.  For these reasons, MARPA recommended the deletion of the sentence.

MARPA will continue to work for its members to advise and cooperate with the FAA in crafting fair and effective policy.  Members comments on these issues are always welcome.

You can read MARPA’s comments in their entirety on the MARPA website under the Government Affairs tab at http://www.pmaparts.org/government/.

New Requirements for PMA Holders include Enhanced Supplier Requirements

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:

  • Require each production approval holder to identify an accountable manager who would be responsible for, and have authority over, their production operations and serve as the primary contact with the FAA;
  • Require each production approval holder to provide the FAA with a document describing how its organization will ensure compliance;
  • Permit each production approval holder to issue authorized release documents (8130-3 tags) for aircraft engines, propellers, and articles;
  • Permit production certificate holders to manufacture and install interface components;
  • Require production approval holders to ensure that each supplier-provided product, article, or service conforms to the production approval holder’s requirements;
  • Establish a supplier-reporting process for products, articles, or services that have been released from or provided by the supplier and subsequently found not to conform to the production approval holder’s requirements; and
  • Remove the requirement that fixed-pitch wooden propellers be marked using an approved fireproof method.

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.

New FAA Policy on Coordination of Engine and Propeller PMAs

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.

FAA Engineering and Production to Merge!

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:

  • Certification and Procedures Branch (AIR-110)
  • Technical and Administrative Support Branch (AIR-120)
  • Systems and Equipment Standards Branch (AIR-130)
  • Operational Oversight Policy Branch (AIR-140)
  • System Performance and Development Branch (AIR- 150)

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.

MARPA Seeks Your Input as We Work to Improve the Manufacturing Reporting Requirements

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.

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