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Streamlined Process for Parts Manufacturer Approval

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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 Updates FAA on Streamlined PMA

As regular readers of this blog undoubtedly know, two of MARPA’s many accomplishments over the last year were the development of the MARPA 1100 Standard and successfully assisting the FAA in its issuance of Order 8110.119: Streamlined Process for Parts Manufacturer Approval.  Last week, MARPA sat down with FAA staff to update them on the progress of the program and discuss feedback–both positive and negative–that we have received from our members regarding the implementation of this new program.

The MARPA 1100 Standard is a recommended format for demonstrating that a PMA part is appropriate for the streamlined approval process.  The goal of that process–outlined in Order 8110.119–is to allow approval of non-safety significant (NSS) PMA parts within 30 days of application by companies with safety records that demonstrate that the FAA may reasonably rely on their systems to ensure quality.

The experiences reported by members has varied.  Some members have reported great success with the streamlined process.  A solid relationship with their ACO proved to be of great benefit in drafting a Memorandum of Understanding (MOU) and initiating the streamlined process.  Continuous communication was also very important.

Each ACO is given a certain amount of discretion in the implementation of the streamlined process.  It is therefore important to work cooperatively and patiently with your ACO in developing an MOU that works for both of you and in commencing the streamlined process.

Some larger members originally reported that they would continue to rely on their ODA processes rather than taking advantage of the streamlined process.  However, as the benefits of the streamlined process became apparent, those members decided that they too would take advantage of the rapid turnaround for NSS PMAs.

Other members have reported that their ACOs have been resistant to implementing the streamlined process.  The FAA suggested a couple of reasons for this resistance.  One reason is that the purpose of the streamlined process is to more efficiently allocate resources.  If the applicant cannot demonstrate that establishment of an MOU and initiation of the streamlined process is going to result in resource savings, the ACO may be hesitant to travel down the streamlined path.  Another reason the ACO may hesitate to implement the process is that it may already have a turnaround time for PMA applications that is very near to the 30-day goal established by the streamlined process.  If there is no time or resource benefit to be realized, the ACO may view the process with skepticism.

It will be important in such cases for those companies seeking to implement the streamlined process to demonstrate to their ACO that use of the process will result in measurable time (and corresponding cost) savings.  Cooperation and a strong relationship with the ACO will help the applicant in moving the MOU and streamlined process forward.

One of the most frequent comments to both MARPA and the FAA has been that the MOU process is confusing or difficult to start from scratch.  Therefore, to better assist our members, MARPA plans to draft and make available guidance to assist businesses in developing their own MOUs.

The Streamlined Process for PMA is still in its infancy, and there will inevitably be growing pains.  MARPA wants to hear about all your experiences, both positive and negative, so that we can continue to refine the MARPA 1100 Standard, develop guidance to address challenges, and work with the FAA to present the PMA industry’s perspectives on the program.  If you have taken advantage of the streamlined process, if you have hit sticking points with your ACO, or if you have for any reason struggled to initiate the process, email your experiences to MARPA Associate Counsel Ryan Aggergaard at ryan@washingtonaviation.com.  MARPA will work diligently to address challenges in the streamlined process to ensure that the PMA community is best able to take advantage of this growing initiative.

MARPA Seeks Data for Streamlined PMA Best Practices Guide

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 Releases Latest Revisions of MARPA 1100; MARPA COS

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 Issues Streamlined PMA Program; FAA Expected to Follow with Related Order

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.

Streamlined PMA Guidance – Comment Deadline is Approaching

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:

http://pmaparts.wordpress.com/2012/01/26/faa-accepts-comments-on-streamlined-process-for-parts-manufacturer-approval-pma/

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

FAA Accepts Comments on Streamlined Process for PMA

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:

http://www.pmaparts.org/government/#STD

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