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Aircraft Parts, Continued Operational Safety, FAA, FAA Design Approval, FAA Production Approval, Manufacturing, PMA, Policy

Anti-PMA Rhetoric is Wrong; PMA Parts are Valid, Says FAA

The FAA has issued a special bulletin reminding the industry that PMA parts are perfectly valid for use, and that competitors’ rhetoric questioning FAA-approved PMA parts is contrary to FAA technical findings.

The FAA announcement came in the form of a Special Airworththiness Information Bulletin, or SAIB. The FAA uses SAIBs as a mechanism for communicating safety information that is valuable, but that falls short of the requirement for issuing an Airworthiness Directive. SAIBs are meant to alert, educate, and make recommendations to the aviation community. Normally, SAIBs are issued about specific technical concerns that the FAA has identified.

It is highly unusual for the FAA to answer an industry marketing campaign with a SAIB, but that is what we seem to have here in the August 8th SAIB addressing PMA parts. Various manufacturers have made a variety of commercial statements designed to undermine public confidence on PMA parts.The FAA specifically notes that “some engine manufacturers responded to the FAA’s approval of PMA and STC for parts involving their type design engine models by telling customers that support of their products could be limited if such parts are installed.” The FAA explains that some manufacturers “have included language in the FAA-approved airworthiness limitation section (ALS) of their engine instructions for continued airworthiness (ICA) stating that the ICA was developed only for use with their parts.”

By issuing this SAIB, the FAA has said “enough is enough.” The SAIB makes it clear that when the FAA approves a PMA part, they expect that the industry will treat that approval with the respect that a decision of the FAA deserves, and that furthermore such parts are entitled to the full recognition of the FAA’s approval, and it is not up to the engine manufacturer to say that installation of a PMA part is wrong or invalid.

The FAA draws four important conclusions in thie SAIB:

PMA Parts are Valid Replacement Parts

FAA-approved TC/PC holder, PMA, and STC parts are interchangeable within the certificated product since they are approved only after a full demonstration of compliance to the applicable requirements of Title 14 of the Code of Federal Regulations (14 CFR). A PMA or STC part, when FAA-approved for installation on a certificated product, is a valid replacement part to the TC/PC holder part according to 14 CFR.

Installation of PMA Parts Does Not Change the Life Limits for the Other Parts In the Assembly

Unless stated otherwise as a limitation to an STC, the FAA has determined and the applicant has shown that FAA-approved life limits established for the TC/PC holder parts remain unchanged for those TC/PC holder parts when PMA or STC parts are installed elsewhere within the product. For example, the life limit for a TC/PC holder disk is unchanged and remains in effect when PMA blades are installed in that disk.

A PMA Holder Has Shown that the ICAs are still Valid OR Has Provided a Supplemental ICA for any Differences

The FAA approves the content of an ALS and ICA based upon its review of the substantiating data provided by an applicant. Applicants for PMA or STC parts are required to assess the ICA requirements. A PMA or STC applicant either shows and states that the product’s ICA are still valid with their part installed or provides a supplemental ICA for any differences.

PMA Holders Remain Responsible for Continued Operational Safety

TC/PC holders, PMA holders, and STC holders are responsible for the COS support in accordance with the applicable standards for their parts and products which they have designed and produced.

MARPA has been supporting the PMA community’s COS Obligations by publishing recommended guidance to help companies develop their own COS programs. At this year’s 2008 MARPA Annual Conference (held October 14-16 in Las Vegas), the Association will feature a COS workshop to assist companies in developing FAA-compliant COS programs.

The full text of the FAA’s Special Airworththiness Information Bulletin is available for review.

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About Jason Dickstein

Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.

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