Has your company taken advantage of the FAA’s streamlined process for PMAs on Non-Safety-Sensitive (NSS) parts, yet? If so, MARPA wants to hear from you.
As we have previously posted on this blog, the streamlined process—detailed in FAA Order 8110.119—involves following the MARPA 1100 Standard for PMA applications for NSS parts. The MARPA 1100 standard is available on our website. Applicants who follow the standard (and confirm that they meet the elements of the FAA Order) are entitled to expedited processing of their applications. The FAA has established a goal to turn-around NSS PMA applications that meet the MARPA standard within 30 days.
A 30-day turn-around would provide NSS PMA applicants with an improved ability to make commitments to customers about expected production and delivery times when those times hinge upon PMA issuance. This should also encourage companies to seek PMA for NSS parts.
The process does not alleviate the applicant of their obligation to ensure compliance with all relevant regulations (remember, you must certify compliance as part of your PMA application); but it does provide a standardized format that should make it easier for FAA ACO engineers to review and approve such applications, consistent with the FAA’s commitment to using risk-based tools to assign resources. This is particularly important as budgets for federal agencies continue to be scaled back.
As with any new initiative, there is likely to be growing pains and some resistance to the adoption and implementation of the streamlined process. We have received some reports from various corners about ACOs that were skeptical of, or unwilling to participate with, the streamline process.
In order to assist MARPA members navigating the streamlined PMA process, we are seeking to issue a set of Best Practices to help guide PMA manufacturers through the new procedure. For this we’d like to hear from you regarding your experiences using the streamlined process. What techniques have been helpful? How did you navigate the MOU process? How closely did you work with your ACO? Do you have any suggestions or words of caution for other PMA manufacturers seeking to take advantage of the streamlined process?
MARPA will compile these responses into a Best Practices guide that will be made available exclusively to MARPA members. We look forward to hearing about your experiences and helping the PMA industry benefit from this new process.
Email your responses to Ryan Aggergaard at Ryan@washingtonaviation.com.
MARPA has released the latest revisions of the MARPA 1100 Standard and MARPA Continued Operation Safety (COS) guidance. These revisions improve both documents.
The MARPA 1100 Standard is a streamlined program for Parts Manufacturer Approval applications. It reflects a standard mechanism for compiling applications for FAA PMAs for non-safety-significant (NSS) aircraft parts. These are parts whose failure would have little or no effect on the continued safe flight and landing of an aircraft.
MARPA continues to work with the FAA to help develop corollary FAA guidance to explain to FAA employees the public safety benefits of the program, and to advise FAA employees on how to handle PMA applications properly prepared under the MARPA 1100 standard. The program will benefit both the FAA and the PMA manufacturing community by allowing the FAA to more quickly approve applications for NSS PMA parts and to focus its limited certification resources on more safety-sensitive issues.
MARPA COS guidance is designed to help PMA manufacturers implement an effective COS program to satisfy the need for PMA holders to be responsible for the continued operational safety of their aircraft parts. The MARPA COS program uses three philosophies — problem prevention, part monitoring, and problem response — to support operational safety of a manufactured part.
Visit the MARPA website at http://www.pmaparts.org to learn more about the MARPA 1100 program for NSS parts, and the MARPA COS Guidance.
MARPA is pleased to announce the release of the MARPA 1100 Standard. This standard provides guidance in assembling a PMA application for a non-safety sensitive (NSS) aircraft part.
This guidance is meant to reflect a standard mechanism for compiling applications for FAA Parts Manufacturing Approval (PMA) for NSS parts. It includes the obligation to analyze the safety-sensitivity of such parts to demonstrate that they are NSS.
MARPA has been working with the FAA to help develop corollary FAA guidance to explain to FAA employees the public safety benefits of this program, and to advise the FAA on how to handle applications that are properly prepared under the MARPA 1100 standard. If the FAA concurs with the NSS analysis, then this means that the part is outside the main thrust of the FAA”s mission, because the part’s failure would not adversely affect safety. This means that the FAA may exercise discretion to rely on the statement of conformance form the applicant for purposes of making a finding of compliance (the FAA always retains the right to to examine the application themselves).
This benefits the FAA, because it allows FAA employees to devote more time to critical safety issues, and potentially decreases the amount of time spent processing PMA applications that are not safety sensitive. For applicants, the program provides a streamlined process for developing the application, and it also sets a goal of a 30-day turn-around time from application to PMA supplement issue.
The FAA plans to limit expedited treatment under this program to PMA applicants with a history of PMA applications, as those without a history are more likely to need a more complete PMA-application-package review by the FAA. Details on what this means are found in the standard.
PMA applicants who are not yet eligible for expedited treatment under this program are encouraged to use it to build their program, so that they will be able to easily move into the streamlined program for NSS parts when the applicant is eligible for the program. In addition, they may find that the additional documentation and rigor recommended by the standard reflects a useful way to prepare a PMA application for NSS parts.
The standard was developed through an industry collaborative process that included making it available for comment, and revising the drafts to reflect member and government comments. Recommendations on the standard are appreciated, and should be sent to MARPA for disposition in the second edition.
MARPA is also currently working on revisions to the MARPA Continued Operational Safety (COS) guidance, and plans to release the next revision to that guidance, soon. Members who are interested in working on this guidance should contact the Association.
Don’t forget that the deadline for submitting comments on the FAA’s DRAFT Order “Streamlined Process for Parts Manufacturer Approval (PMA)” is just a week away (March 20).
This DRAFT order would recognize the MARPA standard for preparing packages for certain non-complex PMAs, and would provide a mechanism for potentially obtaining expedited review of such packages. This is a win for industry, because it should speed up the review process for certain non-complex PMAs; it is also a win for the FAA because it should free-up valuable staff resources to focus on more complex PMA packages whose safety-sensitivity causes them to require more staff review resources.
You can access the draft standard directly here:
http://www.pmaparts.org/gvt/MARPA1100_draft.pdf
You can access the FAA’s draft Order directly here:
http://www.faa.gov/aircraft/draft_docs/media/airOrder8110spma.pdf
You can access the draft standard directly here:
http://www.pmaparts.org/gvt/MARPA1100_draft.pdf
You can access the FAA’s draft Order directly here:
http://www.faa.gov/aircraft/draft_docs/media/airOrder8110spma.pdf
For more details on this DRAFT guidance, you can review or prior post on the subject:
You can access the MARPA standard directly, here:
http://www.pmaparts.org/gvt/MARPA1100_draft.pdf
You can access the FAA’s DRAFT Order, here:
http://www.faa.gov/aircraft/draft_docs/media/airOrder8110spma.pdf
The FAA has released for a comment an Order pertaining to a fast-track PMA approval process for non-complex parts. The Order is entitled “Streamlined Process for Parts Manufacturer Approval (PMA).”
The purpose of the order is to create a streamlined process for the review of applications for non-complex PMAs in order to reduce FAA workload on such projects. Applicants who want to take advantage of this program would have to provide information that is not required by the regulations and meet requirements that are not required by the regulations, in order to facilitate the expedited review process.
This program will permit the FAA to focus their review efforts on the parts that are more complex and the parts that are more likely to directly affect airworthiness of aircraft. This new focus would permit the FAA to better use its limited resources to maximize their ability to support aviation safety.
This Order references the MARPA standard, which is known as the “Streamlined Program for PMA Applications of Non-Critical Articles Submitted by Experienced Applicants with a Qualifying Performance Record.”
The September draft of the MARPA standard found on the MARPA website is the latest version that we’ve published. It was not “finalized” but we have had no adverse comments on the September draft. We did not want to finalize our standard until the FAA Order came out for comment to make sure we were consistent with the post-comment Order. There are some inconsistencies to hammer out (for example, the draft standard permits the FAA to decide what is a reasonable minimum experience based on the experience of the personnel involved, while the draft Order sets a hard standard of four years, so we will want to modify the standard to reflect the FAA’s standards, even if we just say that the FAA’s minimum standards always apply).
You can access the draft standard directly here:
http://www.pmaparts.org/gvt/MARPA1100_draft.pdf
You can access the FAA’s draft Order directly here:
http://www.faa.gov/aircraft/draft_docs/media/airOrder8110spma.pdf
Also, FYI, I have updated the discussion of the standard on our website and included a link to the FAA’s draft Order:
