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Aircraft Parts, aviation

FAA Working on PMA Policy

John Milewski spoke at the MARPA Conference in October about his efforts to update the FAA guidance that affects the PMA community. We caught up with him at the PMA Summit to follow-up on some of the issues facing the PMA industry.

Rev D of the PMA Order (FAA Order 8110.42) is in the works.  Under the new guidance, A major change in the PMA includes a change in the basis of the PMA. it will also reflect the extraction of the applicant guidelines which will be placed into an Advisory Circular (AC).

FAA is developing a separate AC to clearly distinguish applicant responsibilities from FAA responsibilities. The AC will clearly delineate the application obligations of the private sector seeking PMAs.

FAA is promoting the creation of a compliance  table listing regulations and showing methods of compliance.  These sort of tables have represented a “best practice” among PMA applicants. Applicants will be encouraged to include such tables in order to clarify for FAA engineers which regulations apply, and how the applicant is showing compliance.  This permits reviewing officials to more quickly zoom in on potential issues and rapidly determine whether technical issues appear to have been adequately addressed in the PMA application.

Milewski indicated that Industry should expect the opportunity for public comment on a draft of FAA Order 8110.42D in February of 2012.

At the PMA Summit in London, there were a number of questions for John Milewski. Two that caught our attention were the following:

  • Can you rely on the PMA database found on the FAA’s RGL to identify eligibility for installation for PMA parts?  The PMA database found on the FAA’s RGL is not an official list and it can be out of date and incomplete.  Therefore it is better to rely on the PMA Supplement, which can be obtained from the PMA manufacturer. The FAA-issued PMA Supplement includes an eligibility column on which the installer may rely to identify eligibility.
  • Can you sell detail parts from a PMA?  Yes, but they are only applicable for installation on the PMA part.  FAA-DER Darren Lovato recommends a restrictive warning in the remarks block on the 8130-3 (explaining the installation limitations).  Of course, an air carrier can accept the detail part as a stand-alone replacement part if their own system has reviewed the data and accepted it (e.g. through an engineering order).
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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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