The FAA has clarified the PMA marking requirements as they apply to PMA drawings. The clarification opens up a new mechanism for companies to streamline their processes.
An FAA policy memo explains that an “an external QMS auditor interpreted that the marking requirements … be marked or stamped on the drawings.” The FAA memo explains that this is not correct.
The regulations require that a manufacturer must permanently and legibly mark each part (14 C.F.R. § 45.15(a)). The FAA’s internal guidance (Section 2-10 of FAA Order 8110.42D) suggests that “the drawings must specify a permanent and legible method of marking.” The policy memo clarifies that the drawings could merely explain how a marking is applied, without specifying the marking:
Policy and Guidance
The method of the article marking in Section 2-10 is required to be in the design data for PMA articles. The PMA holder/applicant can develop a process on how to comply with “The drawings must specify a permanent and legible method of marking.” This is independent of the required PMA article marking in accordance with 14 CFR 45.15(a).
The detailed methodology of the marking can be identified in their quality control document, a controlled process specification, an engineering order, or other acceptable means as long as it has traceability, and is referenced in their PMA application package, which contains of the design data and drawings.
The flexibility associated with this interpretation means that a company could specify the mechanism for marking (e.g. by cross referencing a company policy document) and then if the company changes its corporate name, a mere change to the internal marking policy document could change the marking on future parts subject to the internal marking policy. This could make name changes and other organic corporate changes much easier, as they would no longer require changes to the drawings, nor would they require associated FAA review and approval of such ministerial changes to the drawings.