As regular readers of this blog undoubtedly know, two of MARPA’s many accomplishments over the last year were the development of the MARPA 1100 Standard and successfully assisting the FAA in its issuance of Order 8110.119: Streamlined Process for Parts Manufacturer Approval. Last week, MARPA sat down with FAA staff to update them on the progress of the program and discuss feedback–both positive and negative–that we have received from our members regarding the implementation of this new program.
The MARPA 1100 Standard is a recommended format for demonstrating that a PMA part is appropriate for the streamlined approval process. The goal of that process–outlined in Order 8110.119–is to allow approval of non-safety significant (NSS) PMA parts within 30 days of application by companies with safety records that demonstrate that the FAA may reasonably rely on their systems to ensure quality.
The experiences reported by members has varied. Some members have reported great success with the streamlined process. A solid relationship with their ACO proved to be of great benefit in drafting a Memorandum of Understanding (MOU) and initiating the streamlined process. Continuous communication was also very important.
Each ACO is given a certain amount of discretion in the implementation of the streamlined process. It is therefore important to work cooperatively and patiently with your ACO in developing an MOU that works for both of you and in commencing the streamlined process.
Some larger members originally reported that they would continue to rely on their ODA processes rather than taking advantage of the streamlined process. However, as the benefits of the streamlined process became apparent, those members decided that they too would take advantage of the rapid turnaround for NSS PMAs.
Other members have reported that their ACOs have been resistant to implementing the streamlined process. The FAA suggested a couple of reasons for this resistance. One reason is that the purpose of the streamlined process is to more efficiently allocate resources. If the applicant cannot demonstrate that establishment of an MOU and initiation of the streamlined process is going to result in resource savings, the ACO may be hesitant to travel down the streamlined path. Another reason the ACO may hesitate to implement the process is that it may already have a turnaround time for PMA applications that is very near to the 30-day goal established by the streamlined process. If there is no time or resource benefit to be realized, the ACO may view the process with skepticism.
It will be important in such cases for those companies seeking to implement the streamlined process to demonstrate to their ACO that use of the process will result in measurable time (and corresponding cost) savings. Cooperation and a strong relationship with the ACO will help the applicant in moving the MOU and streamlined process forward.
One of the most frequent comments to both MARPA and the FAA has been that the MOU process is confusing or difficult to start from scratch. Therefore, to better assist our members, MARPA plans to draft and make available guidance to assist businesses in developing their own MOUs.
The Streamlined Process for PMA is still in its infancy, and there will inevitably be growing pains. MARPA wants to hear about all your experiences, both positive and negative, so that we can continue to refine the MARPA 1100 Standard, develop guidance to address challenges, and work with the FAA to present the PMA industry’s perspectives on the program. If you have taken advantage of the streamlined process, if you have hit sticking points with your ACO, or if you have for any reason struggled to initiate the process, email your experiences to MARPA Associate Counsel Ryan Aggergaard at firstname.lastname@example.org. MARPA will work diligently to address challenges in the streamlined process to ensure that the PMA community is best able to take advantage of this growing initiative.