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FAA Updates PMA Order to Refine Part Marking Requirements

The FAA has issued a “Change One” to FAA Order 8110.42D.  This is the PMA order and this guidance remains quite important to any PMA applicant.  Thus any change can be cause for concern.

The recent “change one” appears to have made only one substantive change.  It is a change on Page 2-9 to the language addressing part marking.  This introduces the very reasonable guidance that was published as a FAA policy memo earlier this year.  We recently wrote about that useful guidance in this blog.

Part Marking, Better Explained

The policy memo clarified what the rules require.  The FAA rules require each PMA manufacturer to permanently and legibly mark each part (14 C.F.R. § 45.15(a)), but they do not require PMA drawings to specify details about the marking.  The FAA has internal guidance (Section 2-10 of FAA Order 8110.42D) that suggested that “the drawings must specify a permanent and legible method of marking.” The policy memo clarified that the drawings could merely explain how a marking is applied, without specifying the marking:

Policy and Guidance [from the memo]

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.

Order 8110.42 has now been updated consistent with the memo. The new language (section 2-10 which is found on page 2-9) says:

2-10 Article Marking Requirements. Check the article’s marking scheme specified in its design data. The applicant must specify a permanent and legible method of marking. 14 CFR 45.15(a) sets the marking requirements for PMA articles. These markings must identify the article as “FAA-PMA”, the article’s part number and the name, trademark or symbol of the manufacturer. The detailed marking scheme and methodology 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.

The flexibility associated with this new language 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 FAA-approved drawings, nor would they require associated FAA review and approval of such ministerial changes.  Likewise, this makes it easier for a company to change its identification protocols, such as a change from using the name of the company in its markings to using a trademark of the company in all of its markings.

Other Changes

What’s that?  You can’t find page 2-9?  That is because change one also introduced some new (non-substantive) errors into chapter two.  The chapter two pages after 2-8 are all mis-numbered and the word “Toleranc” [sic] is improperly spelled.

These minor formatting errors would not be as frustrating if the FAA would apply the same standards to their own work as they apply to the industry.  I have seen the FAA return FAA-PMA applications for spelling corrections before they will accept them for processing.

By all rights, the formatting errors should reflect “change two” but I will not be surprised if the FAA may simply corrects them under the same change number, in order to avert attention from the errors.

Compliance Advice

No one is required to change an existing drawing under this new guidance.

But for future drawings, you should strongly consider detailing the marking methods (e.g. peening / hot stamp / etc.) and locations in your drawings, consistent with the 8110.42 guidance; but the details of the marking should be cross referenced in a document that is not subject to FAA approval (e.g. “apply marking using  [method] in [place detailed in drawing]; mark according to internal company specification [xx-nnn]”).

This internal company specification can then detail the specific information for the part (like company name, part number identified according to company policy, and “FAA-PMA”).  Then, if the company chooses to make changes to the part markings, it can make company-wide changes for future production by simply changing the internal company specification and setting an effective date for the change.

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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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