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Streamlined Program for PMA Applications of Non-Critical Articles Submitted by Experienced Applicants with a Qualifying Performance Record

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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.

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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