MARPA President Jason Dickstein met with Roger Simon (EASA Design Organization Manager) and Jan Novak (EASA Rulemaking Officer – Initial Airworthiness Product Safety Department) for a candid discussion about where Europe is going in terms of supporting an aftermarket aircraft parts industry.
It should go without saying that EASA is quite concerned about maintaining the integrity of their system, and maintaining their high airworthiness standards. Against this framework, EASA would like to encourage the development of a vigorous aftermarket aircraft parts manufacturing industry (similar to the PMA industry in the United States).
The EASA team explained that EASA had previously looked at the idea of a separate rule for manufactyring aftermarket parts, like the separate PMA rule in the US FAA regulations. The proposal would have envisioned two separate approvals: a parts design approval and a parts production approval. This idea has been abandoned in favor of working within the existing regulatory framework.
EASA has always taken the position that it is possible to produce independent aftermarket parts under the existing EASA regulations that are used for producing aircraft and engines. The problem has come with an interpretation that appears to require recertification of the entire product (aircraft), including systems and airworthiness elements that could not reasonably have been affected by the aftermarket part.
EASA has expressed interest in developing guidance that would permit parts manufacturers to limit their airworthiness showings to a more reasonable set of items of proof (limited to those airworthiness regulations likely to be affected by the part in question). The guidance would interpret the existing regulations.
One of the issues we discussed with EASA was over Continued Operational Safety (COS). They seemed impressed with the association’s COS efforts, and with the fact that COS lays a foundation for copmanies to eventually implement effective Safety Management Systems (SMS). We are hoping that EASA will adopt similar COS standards for the aftermarket manufacturing community.
Another concern raised by EASA during the meeting was over intellectual property. EASA asked about the persistent OEM concern over misuse of data and the aviation authority’s role in policing intellectual property infringements. It was a wonderful opportunity, as it allowed MARPA to discuss some of the limits of intellectual property law, and to debunk some of the myths about “proprietary information.” We had a very productive discussion with EASA, and we are looking forward to continuing our discussions!