Last month MARPA attended the Certification Management Team (“CMT”) meeting in Ottawa. For those unfamiliar, the CMT is a quadrilateral group comprised of the FAA, EASA, Transport Canada, and ANAC Brazil that works to optimize the certification process under the bilateral agreements among the partner agencies. The decisions that come out of this group can have a significant effect on PMA manufacturers by establishing policies that determine how PMAs are accepted in other jurisdictions.
One of the most important things to come out of last month’s CMT meeting was the signing of a new Technical Implementation Procedures document (“TIP 6”) to the US-EU bilateral agreement. The TIP is the document that implements the terms of the bilateral agreement between the FAA and EASA. It includes provisions of considerable importance to PMA manufacturers, such as the conditions under which FAA-approved PMA parts can be accepted into the EU without further showing versus when a PMA will need to get an STC before it can be sold in Europe. Understanding the contents of the TIP, knowing where specific PMA-related provisions are, and being able to identify and explain those provisions to a person can be a vital tool when faced with a potential customer or a regulator who thinks “PMAs aren’t accepted” in X country. (Hint: PMAs are nearly always accepted in EASA member states without further showing under the terms of the bilateral.)
MARPA will be doing a full analysis and breakdown of TIP 6 and its PMA-related provisions in the coming weeks. In the meantime, you can find the new TIP 6 here. The TIP was signed on September 22, 2017 and has a six-month adoption period, meaning this latest revision is not effective until March 22, 2018. The FAA and EASA have asked for industry’s comments on the document to ensure that it is workable and that there are not any unintended consequences (as happened with the adoption of the Maintenance Annex Guidance revision 6 or “MAG 6”).
MARPA has already identified a significant potential problem that would require a “critical” PMA to receive a validated EASA STC before being accepted in the EU. PMA parts are generally not eligible for FAA STCs because they do not constitute a major change to type design. Thus there would not be an FAA STC (the certifying authority) for EASA to “validate” and thus issue a validated STC for a critical PMA to be accepted in Europe. This could have the effect of foreclosing all “critical” PMAs from entering the EU because there would be no way for the “critical” PMA to get an EASA STC.
MARPA has committed to getting comments on TIP 6 back to the FAA before the New Year, so we ask each of our members to review the new document and let us know if you see any issues that would adversely affect your PMA business.
Another important area of the CMT in which MARPA is looking out for the PMA industry’s interests is on the CMT’s Certification Authorities for Propulsion Products (“CAPP”) group. This group is currently evaluating what constitutes complete Instructions for Continued Airworthiness (“ICA”) and to whom those ICAs (and revisions) should be distributed, as well as whether fees can be charged and what those fees can be. Members of MARPA’s technical committee are deeply involved with the CAPP to ensure that the rights of PMA manufacturers–and those customers who use PMA in their repairs –are protected.
These are just two more of the many areas in which MARPA is working to protect and advocate for the PMA industry’s rights. If you would like to see more ways that MARPA is working for the PMA industry, or get involved yourself, we encourage you to come see us next week at the 2017 MARPA Annual Conference in Orlando. We look forward to continuing to work hard for the PMA community, and we hope to see you there.
Comments on TIP 6? Email them to MARPA VP of Government and Industry Affairs Ryan Aggergaard at firstname.lastname@example.org.
Want to join MARPA or get more involved? Email MARPA Senior Program Manager Katt Brigham at email@example.com for more information.