EASA has issued an Advance Notice Of Proposed Amendment on Volcanic Ash.
Ordinarily, this might be of little interest to the PMA community, but the A-NPA is specifically seeking guidance on how to address PMA parts in engines, and whether they affect engines exposed to volcanic ash.
This could represent an opportunity to explain to EASA how it is that PMA parts support aircraft engine safety. Or it could be used as an opportunity for foes of PMA to defame the PMA industry. We’d like to see this used as an opportunity for sharing positive and useful information.
MARPA Members with data that helps to show the effect of PMA parts in an engine that is subject to volcanic ash exposure should share that data with EASA. MARPA would appreciate copies of any data or arguments that our members have in order to support MARPA comments on this subject.
Advance Notice Of Proposed Amendment (A-NPA) 2012-21, Possible courses of action for EASA to address the issue of ‘Volcanic ash ingestion in turbine engines’ (28 November 2012) can be found online at http://hub.easa.europa.eu/crt/docs/viewnpa/id_189.
MARPA has filed comments in response to the FAA Notice of Proposed Rulemaking concerning repair stations and their ratings. Although the ratings proposal was the centerpiece of this proposed rule, many of the proposals that caused the most concern were those unrelated to the ratings element of the proposal.
This is a proposed rule that could have a significant effect on the MARPA Community. Some of the regulatory proposals, for example, could inhibit PMA growth if they are fully implemented.
Issues addressed by the wide-ranging comments from MARPA included:
A complete set of the MARPA Comments can be found on the MARPA website.
The Occupational Safety and Health Administration (OSHA) has been supporting clean-up efforts in the wake of Hurrican Sandy. MARPA members who are affected, and who may still be in clean-up mode, should pay heed to the OSHA guidance about protecting employees from hazards.
With the passage of time, it is easy to forget about the hazards that remain in the wake of the storm. It is particularly important to remember that new hazards can also arise, like contamination hazards. Businesses should be cognizant of these hazards and should take steps to prottect employees from the hazards,
Common hazards include downed electrical wires, carbon monoxide and electrical hazards from portable generators, fall and “struck-by” hazards from tree trimming or working at heights, being caught in unprotected excavations or confined spaces, burns, lacerations, musculoskeletal injuries, being struck by traffic or heavy equipment, and encountering contaminated water during flood cleanup.
Protective measures involve evaluating the work area for all hazards; assuming all power lines are live; following safe practices when doing tree work; using fall protection and proper ladder safety when working at heights; task specific exposure monitoring; and utilizing proper precautions for traffic work zones.
OSHA has emergency aid for both employees and businesses. Click here for a list of emergency aid available to those affected by the storm.
MARPA’s sympathies go out to our affected members. If there is anything that the Association can do to assist, please feel free to contact us!
If you need to contact OSHA for an emergency situation, please call the toll-free hotline 1-800-321-OSHA.
As previously mentioned on this blog, the FAA’s proposed Aviation Repair Station rule is very likely to have noticeable secondary effects on other companies, including PMA parts manufacturers. On November 5, MARPA and other members of the aviation community, as well as representatives from the FAA, met for a Small Business Administration roundtable to discuss the proposed rule.
The FAA, although not able to take comment at the meeting, offered a presentation on the purpose and intent of the rule and were available to attempt to answer any questions posed by attendees. The FAA explained that the purpose of the rule is to align FAA regulations with current industry practices and aircraft technology. The FAA also stated that they believe they have addressed the numerous comments that resulted in the rejection of similar proposed rules in 1999 and 2006.
Industry attendees expressed a number of concerns with the proposed rule. One concern is that due to the slow nature of the rule-making process, current industry practices have already moved beyond that which is contemplated by the proposed rule. There also appears a risk of creating confusion as the rule introduces inconsistent terms to the regulations.
The rule may also create significant adminstrative burdens. It would require that each of approximately five thousand repair stations renew their certificates with 24 months of the rule becoming effective. There is some doubt as to whether the FAA has the resources to process so many renewals in such a limited time frame, particularly faced with the reality that most applications would occur toward the end of the 24-month window.
The rule creates additional administrative burdens on the repair station side, as supervisory personnel will be required to be on hand to oversee work performed, changes to capabilities lists will have to be approved by the FAA or through self-evaluation, and substantial new employee training requirments are implemented.
Additionally, the new “Component Rating” propsed by the rule poses a particular threat to PMA manufacturers. Repair stations will be expected to maintain a component capabilities list in their operations specifications. Because of the burdens associated with amending and updating op specs, many repair stations may have difficulties in efficiently updating their components capabilities lists. This is especially troubling for PMA. Even though a PMA part is most likely maintained in the exact same way as its OEM corrollary part, a repair station may still be required to call out that specific PMA part number in its op specs in order to perform maintenance. Given the smaller population of PMA parts, many repair stations may not be willing to go through the op spec amendment process to add the PMA part to their capabilities list.
The cumulative effect of these additional burdens may have the result of decreasing the number of repair stations allowed to repair PMA parts even though they are technically proficient. Smaller repair stations may also find themselves priced out of business by the addtional financial costs associated with the new administraive burdens.
The FAA will accept public comments on the proposed rule through November 19, 2012. Comments should reference FAA Docket Number “FAA–2006–26408.”
The U.S. Commerce Department will hold a webinar on November 29 to discuss the effect of European Evironmental Regulations on U.S. Aerospace companies.
The European Union has a regulation called the REACH regulation. REACH stands for Registration, Evaluation, Authorisation & restriction of CHemicals.
REACH imposes certain obligations on companies that manufacture certain chemicals in Europe, and on companies that import certain chemicals into Europe. Under REACH, the continued marketing of substances of Very High Concern (SVHCs) requires an authorization. Businesses active in the aerospace marketplace use a number of substances that are being considered for SVHC classification, and unauthorized import into Europe of such substances could violate REACH.
For more information, see the notice on the Commerce Department website.
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.
It is with great sadness that we report that retired MARPA President Gloria Nations-Powell passed away quietly after suffering a stroke at her Arizona home on November 3. She was 75.
Gloria was the Association’s second President, having served from 2004-2007 in that role. Before that, since the Association 1999 inception, she had served as the Association’s Secretary.
Gloria was introduced to the Association through her husband, George Powell, but she was no stranger to the world of aircraft parts manufacturing, having worked for OEMs before manufacturing PMA parts at Vision Air.
Gloria’s warm and pleasant personality helped endear the Association to the industry and the authorities. You could always count on Gloria to brighten your day with a smile and a kind word.
She helped keep the Association together during a crucial time in the Association’s history, and laid the foundation for future growth.
There will be a visitation from 4:00 pm to 7:00 pm on Tuesday, November 6, 2012 (today) at Ruffner Wakelin Funeral Home 303 S. Cortez St. Prescott AZ 86303
The Funeral Service will be held 9:00 am to 10:00 am on Wednesday, November 7, 2012 at Ruffner Wakelin Funeral Home 303 S. Cortez St. Prescott AZ 86303
The cemetery is Heritage Memorial Park at 12000 E Heritage Memorial Lane Dewey AZ 86327
Additional funeral information can be found at the Ruffner Wakelin Funeral Home website at the link below.
Please join MARPA in mourning the loss of this important industry leader.
The Small Business Administration roundtable to discuss the FAA’s proposed Aviation Repair Station Rule – postponed due to the effects of Hurricane Sandy – has been rescheduled for Monday, November 5, 2012, from 2:00 p.m. – 3:30 p.m.
The proposed rule, which the FAA claims is necessary to keep pace with current industry standards and practices, is expected to have a secondary effect on repair station customers and business partners. This includes PMA part manufacturers. The SBA has recognized that there is significant small business interested in the proposed rule, and will typically write and file comments in response to industry concerns.
Those interested in attending the roundtable should RSVP to Bruce Lundegren via email. A dial in conference call option may also be available with advanced request. If you wish to dial in, contact Bruce Lundegren so that SBA can make the appropriate arrangements.
SBA Contact Information:Bruce E. Lundegren, Assistant Chief Counsel, SBA Office of Advocacy U.S. Small Business Administration 409 3rd St. SW, Washington, DC 20416 tel: (202) 205-6144 email: email@example.com