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Aircraft Parts, aviation, FAA, FAA Design Approval, Manufacturing, PMA, Policy

MARPA and FAA Talk Policy

MARPA had a very good meeting today with Mark Bouyer and Ann Azevedo of the FAA’s Engine and Propeller Directorate (EPD).

The focus of the meeting was status on EPD policy that may affect PMA manufacturers.

Azevedo explained that she has responded to the comments on the Statistics Advisory Circular (AC), and hopes to have the final draft of that guidance available to the public by September.   The Statistics AC is meant to address FAA concerns that have been recognized in practice, such as misusing statistical methods to show equivalence, and underestimating the appropriate sample sizes.

Bouyer expects the Materials AC to go out for public comment this month.  The Materials AC will identify the essential data that is necessary when a PMA applicant is trying to replace the material used in the type design.  MARPA members should watch for this one, and be prepared to offer their comments.

The FAA had published the Geometry AC for comment.  This AC is meant to enhance awareness of how reverse engineering can introduce dimensional differences in replacement parts.  MARPA Board members have expressed that the draft of this proposed guidance appeared to be very helpful to the industy.

The Burner Rig AC, which was also previously out for comment, is expected to be issued by September. It is expected to provide a method for establishing functional equivalence for certain degradation modes in parts such as oxidation, hot corrosion, erosion, etc. The AC is expected to identify existing technology as a means of compliance.

Finally, the FAA is internally reviewing AC 33.8 with a plan to update and clarify the AC. The updates are intended to make the AC easier to use.

The FAA has been very active and diligent in preparing guidance.  In the immediate future (before the Conference), MARPA members should expect to see the release version of the Statistics AC and the Burner Rig AC, and they should expect to see the Materials AC go out for comment.

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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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