This year, MARPA will be attending the 58th Annual Air Carrier’s Purchasing Conference. As a benefit to our members, MARPA plans to feature member-company literature in our booth to allow you to make connections with the large number of air carriers and suppliers registered for this event. This is just one of the benefits of MARPA membership. ACPC offers an excellent opportunity to have your company’s materials available during the Aviation Networking Forum.
In order to help us feature member companies in the MARPA booth, members must ship their literature to us at MARPA headquarters. To ensure we are able to showcase your literature, you must follow these steps:
1. Act quickly! ACPC runs September 13 – 16, 2014. You should plan to have your literature arrive absolutely no later than Wednesday, September 10th.
2. Ship your package to:
2233 Wisconsin Ave, NW
Washington, DC 20007
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 a description of the contents of your package so we know what to look for.
Are you planning to attend ACPC? Would your company like MARPA to target specific fleets or Air Carriers for our Airline Round Table Session selections? Contact MARPA today to let us know! MARPA is excited to be able to offer opportunities like this to its members. If you have any questions or comments, please contact Katt at (202) 628-6777 or by email at email@example.com.
The FAA has released Notice 8110.116, which stresses the importance of writing clear notes in the Type Certificate Data Sheet (TCDS), and of ensuring that those notes are consistent with FAA policy. This new guidance can be very valuable to everyone in the industry. The value to TC applicants and holders (who create draft TCDS for FAA adoption) is obvious, but less obvious are the subtle and not-so-subtle admonitions against using the TCDS for anti-competitive effect.
One valuable element of this guidance is that it stresses certain things that should not appear in the TCDS. For example, in paragraph 6(a)(6), the guidance advises against language that limits work to a scope narrower than permitted by the regulations:
(6) Do not include requirement that is non-regulatory in the notes. For example: “This aircraft shall be maintained in accordance with the BHT-427 Maintenance manual.” This note implies that BHT-427 is the only source for maintaining the aircraft, and conflicts with 14 CFR 43.13(a) which states “Each person performing maintenance . . . shall use methods . . . or other methods acceptable to the administrator.”
This admonition is consistent with FAA guidance that has prohibited language limiting operators options in seeking repairs. E.g. PS-AIR-21.50-01: Type Design Approval Holder Inappropriate Restrictions on the Use and Availability of Instructions for Continued Airworthiness (March 23, 2012). In the past, there have been problems with manufacturer’s guidance that seeks to limit operators’ repair options, which in turn has had an adverse effect on independent repair stations who are qualified by the FAA to perform the same repairs. Other language in the guidance highlights the prohibition against anti-competitive statements by stating:
Avoid language promoting a TC holder or their suppliers as the sole source for maintenance or overhaul.
It is contrary to 14 CFR parts 43 and 21 to include a note that all repairs or modification schemes must be approved by the TC holder prior to FAA approval.
In a similar vein, the guidance also forbids use of notes that could be interpreted as statements of FAA General Policy. The obvious reason for this is because the TCDS should not be used as a vehicle for establishing FAA policy. The example that is given is useful in its own right, because this is clearly not a statement of FAA policy, despite the fact that some government prosecutors have tried to promote similar policies:
(8) Avoid notes that can be interpreted as FAA general policy. For example: “Reuse of parts and assemblies that have been involved in an accident is not permitted unless approved by FAA Engineering.”
In subsection 6(a)(10), the FAA advises against the use of brand names, but in subsection (11), the FAA requires that when a specific brand name is used, then the note must also advise of the possibility of using FAA-approved alternatives:
(11) If a specific brand name material needs to be listed, then you must state that an equivalent material is also may be approved. For example: “SOHIO BIOBOR JF biocide additive is approved for use in fuel at a concentration not exceeding 270 PPM. Use of other, equivalent material, may be approved by the FAA.”
Aviation is a competitive industry, but some companies have attempted to use FAA-approved and FAA-acceptable documents as levers to inhibit competition. The FAA has repeatedly asserted that its job is safety – not competition – and that it will not allow its approvals to be used as independent inhibitors of competition where no safety interest is served. While the main purpose of this new guidance is to standardize the layout of TCDSs, it also includes important admonitions that should help prevent anti-competitive behavior.
Don’t forget to register today for the 2014 MARPA Conference! The Early Bird discount expires tomorrow, August 15th, so register today and save!
The 2014 MARPA Conference has a lot of opportunities to offer! Join Keynote speakers Ahmad Zamany, VP of Technical Operations at Copa Airlines, and Mike Arata, Director of Engineering at United Airlines! Learn about the newest developments in international PMA markets like Japan, Latin America, and Europe. Dive into recent COS updates and Part 21 regulatory changes to educate your company. Find the financial stragegy you need to guide your company through the PMA landscape. The Conference Agenda is packed with the speakers you want to see, and with networking opportunities! Your customers will be there… why won’t you?
To register, just click here for a registration form and hotel information. If you have any questions, contact MARPA by calling (202) 628-6777. We look forward to seeing you in Las Vegas.
The MARPA Conference is coming soon!
Since 2001, MARPA has hosted annual conferences that bring together experts and leaders within the PMA industry and regulatory realm to tackle key issues facing the modification and replacement parts arena. The 2014 MARPA Conference will be held from October 1-3, 2014 at the Renaissance Las Vegas.
Be sure to register this week, before the Early Bird discount expires this Friday, August 15th! Registration forms can be found at the link below, or you can contact MARPA with any questions.
For more information about the MARPA Conference including agenda, registration information, and accomodations, please click this link or visit us at http://www.PMAparts.org. We look forward to seeing you at the Conference!
Do you have a topic for the MARPA Technical Committee’s next meeting? We are now collecting items for the agenda for the October meeting!
The MARPA Technical Committee addresses technical issues facing the industry. The Committee review proposed FAA Publications (like advisory circulars and orders) and offer technical advice to improve those proposals. Technical Committee members meet with the FAA to discuss policy issues. Technical Committee members also sit on FAA Advisory Committees and Working Groups in order to develop policy that affects the PMA community.
Appropriate topics for the MARPA Technical Committee Agenda include aviation/manufacturing policy issues, amendment of current aviation/manufacturing policy documents, and new technologies that affect the aviation manufacturing industry. Any technical issue that could affect safety is fair game. MARPA is not just focused on FAA and EASA compliance issues – issues before other agencies (in the US or around the world) are also welcome.
The Technical Committee will meet on October 1, 2014 at 11:00 am. The meeting will take place at the Las Vegas Renaissance Hotel at 3400 Paradise Road
Las Vegas, Nevada 89169 (in conjunction with the MARPA Annual Conference – this occurs during the Workshop Day).
All MARPA members are welcome to attend the Technical Committee meeting.
Please send you Technical Committee Agenda items to Jason Dickstein.
Dear MARPA Members:
MARPA will be “meeting” with the Engine and Propeller Directorate via a telephone conference on August 7, 2014 at 13:00 Eastern Time. Association members are invited to participate. If you are a MARPA member and would like to participate, please contact Katt Brigham by email or by phone!
We will be discussing the Engine and Propeller Directorate’s future work plan for policy guidance affecting PMAs, and will also receive status updates on current projects. MARPA plans to share trends in the industry that could require FAA attention, as well as information on “lessons learned” in the realm of Continued Operational Safety (COS).
This informal working meeting is part of a series of meetings between MARPA and the FAA that are intended to promote communication in an effort to manage safety in a proactive, efficient, effective manner. It is an excellent opportunity to let the Engine and Propeller Directorate know whether their existing policy is effective in supporting safety. Nothing said by the FAA is intended to bind the FAA to any particular course of action. Participants are asked to respect the FAA’s standards reflecting ex parte communication.
Do you have manufacturing designees in your facility? If so then they should be going through the process of obtaining new designee numbers.
The FAA is switching all FAA-designees over to their new DMS system and all designees are being given new, unique, nine-digit identification numbers known as “designee numbers.” The DMS was announced in Order 8000.95,which is the FAA’s Order on Designee Management Policy.
DMS will collect, store and process data and information associated with designees and the designee management processes in accordance with FAA recordkeeping requirements. See Designee Management Policy, FAA Order 8000.95 (April 11, 2014). Designees should note that there is an explicit disclaimer of privacy, so designees are surrendering any expectations of privacy that they may have with respect to information stored in this system.
Manufacturing DARs are first to go through this process and many of them have already received their new numbers. The deadline for completing this process is ten days after the notification (which should have been received in June or early July), so if your manufacturing DAR is not yet registered properly in the DMS system, then please make sure he or she gets registered appropriately, ASAP; failure to renew through the DMS system could mean that the DAR loses his or her designee privileges!
The FAA intends for ALL manufacturing designees to be converted over to the DMS system by September. To that end, all new manufacturing DAR and DMIR applications after May 7, 2014 are being processed through the DMS.
We are just over two months away from the 2014 MARPA Conference! MARPA is thrilled to see that PMA manufacturers, air carriers, and regulators from all over the world are joining us this year in Las Vegas. Part of what makes the annual MARPA Conference an important event to attend is hearing from leaders in our industry first-hand.
This year, Daisuke Umezawa, Japan Civil Aviation Bureau (JCAB)’s Director, Airworthiness Standards and International Affairs Office Airworthiness Division, will be joining us to discuss Japan’s consideration of establishing a Japanese PMA framework, and the possibility of working with FAA regulators to accept JPMA articles. This is a very exciting prospect for the future of PMA, and we think you’ll enjoy hearing his insights regarding possible developments.
At the invitation of MARPA member Jay Kato, MARPA visited Japan to attend the 2013 Aerospace Industry Exhibition Tokyo (ASET 2013). This visit was an opportunity to introduce ASET 2013 attendees to information about the PMA marketplace and about our membership. Many Japanese companies are very interested in the potential offered by PMA, and bring new opportunities as potential partners and suppliers. Mr. Umezawa visiting our event is an excellent chance to continue to both learn about and to share with the JCAB.
We’ve got an exciting line-up of keynote and other speakers on the agenda, and you will hear more in the weeks ahead. You can find the Conference agenda and other information on our website.
We hope to see you in Las Vegas this October. Register today!
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 firstname.lastname@example.org soon!
MARPA is proud to announce that Mike Arata, Managing Director of Engineering at United Airlines, will serve as day two keynote speaker for the 2014 MARPA Conference.
Mr. Arata has held various positions at United over his 22 year career. He hired into United in San Francisco as a Liaison Engineer upon his graduation from college. He later transferred to Chicago, where he continued to work with Liaison Engineering in the lead engineer role. He ventured out of engineering for a few years and worked with the Chicago Line Maintenance team as an Area Manager responsible for the day to day maintenance activities of running a large hub maintenance station. Prior to his current role of Managing Director, he held the title of Senior Manager of Liaison Engineering.
In his current role, Mr. Arata is responsible for the compliance, configuration control, and modifications technical program requirements for the fleet. Mr. Arata’s engineering team consists of over seventy engineers that work in the following four disciplines: Avionics, Systems, Powerplant Engineering and Cabin Systems
Beyond United, Mr. Arata holds the Chairman role on the A4A Engineering Maintenance and Material Council. He also serves on the advisory board for Penn State University.
The MARPA Annual Conference will take place October 1-3, 2014 at the Renaissance Las Vegas Hotel. More Conference information is available online at: www.pmaparts.org/annualconference.