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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.
Jason Dickstein has written 307 posts for MARPA

Korea PMA Workshop – a Success!

MARPA and the Korean Trade Promotion Agency (KOTRA) delivered a PMA workshop in Seoul this week.  Hosted at KOTRA Headquarters in Seoul, the workshop provided an opportunity to begin educating the Korean aerospace community about the value of FAA-PMA parts.  It also afforded the PMA community an opportunity to begin strengthening business relationships  with the Korean aerospace industry.

The MARPA Perspective

MARPA’s President, Jason Dickstein, spent the first day of the workshop laying the goudnwork for understaing the PMA process.

The room was packed with about 60 participants from all sectors of the Korean aeroaspace community.  MARPA discussed issues like the parts approval process, the safety, reliability and economic advantages afforded by FAA-PMA, and strategies for partnering with US PMA companies in order to increase trade and increase the profis of both companies.

Three of our members attended the workshop.  Representatives from Heico, Jet Parts Engineering, and the Wencor Group joined us at the workshop and had an opportunity to network with potential suppliers from Korea’s manufacturing community as well as potential customers from MROs and airlines.  

The Government Perspective

We were honored to be joined by Ha Girl Chung, the Deputy Director of Aircraft Certification for Korea’s Ministry of Land, Infastructure and Transportation.  Mr. Chung was a key negotiator in the recently updated technical implementation procedures for the US-Korean bilateral aviation safety agreement.  He reviewed the elements of Korean law that permit the acceptance of US PMA parts in Korea, and he also explained Korea’s own ability to issue PMA for parts made in Korea.  

Privately, Mr. Chung told MARPA that Korea would like to begin issuing domestic PMA.  This was foreshadowed by last years update to the US-Korean technical implementation procedures, which left a specific reservation (a place holder) for US acceptance of Korean PMA parts. 

Mr. Chung poses questions Wencor’s Mark Powell

The Airline Perspective

Asiana and Korean Air Lines were both well-represented at the event.  Hoon Yong Kim, from Korean Air, delivered a presentation about his air carrier’s PMA policy.  He explained that his carrier does not currently use critical PMA parts, but that they would like to expand their current use of non-critical PMA (critical PMAs are less than 1% of all PMAs).  Mr.Kim said that they are particularly targeting interiors parts, right now, but they would like to increase both the quantity and the scope of the PMAs that they use.

What specific qualities does Korean Air seek?  Mr. Kim explained that parts partners need to hold FAA PMA (other nations’ systems are currently not on his radar) and they should be prepared to support Korean Air in cooperative analysis.  He described one situation where a supplier helped Korean Air perform a root cause analysis. Despite the fact that the root cause was unrelated to the supplier, the supplier provided continued engineering support.  During subsequent conversations, Mr. Kim confirmed that he is looking for companies that have established systems like MARPA’s Continued Operational Support (COS) program.

The PMA Perspective

All three of the MARPA members who were on hand had an opportunity to meet and speak with the attendees.  Steve Johnson from Jet Parts Engineering added some insightful questions to the workshop.  Joe DePaoli of Heico explained that his company and his peers from other PMA companies were interested in opportunities to work with Korean manufacturing companies with specialized technologies, and also with Korean manufacturing companies that are already making certain types of parts and who could use those skills to manufacture parts that could be approved under FAA-PMA.  

Mark Powell of the Wencor Group delivered the anchor presentation at the end of the workshop, and he summarized the process that helped to ensure that PMA parts met the highest standards.  

KOTRA

KOTRA and MARPA have begun a partnership to promote US-Korean aerospace trade with a focus around PMA parts.  MARPA members should expect – and should look forward to – future oppotunities to increase their trade with Korean businesses.

FAA Class on PMAs in Singapore

FAA will conduct a 3-day Parts Manufacturer Approval (PMA), Commercial Parts, and Standard Parts course at the Singapore Aviation Academy, September 28-30, 2015.

The course will be taught by FAA’s expert Robert Sprayberry. The course is a top-level study of the FAA’s approval/acceptance of articles (i.e. PMA process, commercial parts, and standard parts). It will provide instruction on relevant regulations and historical findings as well as include examples and descriptions from industry and FAA perspectives. The class will focus on analysis of relevant advisory circulars and orders.  Additionally this course will provide an overview of the history of the 14 CFR 12.8 and 12.9 for context.

There is still time to register for this course; registration deadline is August 31. For more information contact Diane Migliori @ 202 267-1029 or via email, diane.migliori@faa.gov.

Korean Opportunity

MARPA will present a workshop about PMA to Korean companies on August 24-25.  This workshop is being put on in partnership with the Korean Government (KOTRA and MOLIT).

We will be discussing issues that affect Korean-US business relationships and strategies for increased Korean-US trade.  MARPA members will be networking with existing and potential Korean business partners.

Registered attendees include personnel from airlines Asiana Airlines and Korean Air Lines (KAL).  This could be a great opportunity to network with some Korean customers and business partners.

We should be able to secure complimentary registration for any MARPA member who wants to attend.  If you have personnel in the Republic of Korea or elsewhere in northern Asia, then you should certainly have them on site for this meeting.

If you have personnel that you would like to register for the workshop, please let MARPA know ASAP as time is running short.

Yes, You CAN Sell FAA-PMA Parts into China!

Yes, China accepts FAA-PMA parts.

The United States and China signed a Bilateral Airworthiness Agreement (BAA) in 1991.  That agreement recognized that each authority (FAA and CAAC) had a system for production and airworthiness approval of civil aeronautical products, and that each system was sufficiently equivalent to the other to permit the authorities to accept certain approval decisions of the other.

The BAA is implemented through a Schedule of Implementation Procedures.  This schedule explains how international aerospace transactions will work.  It is meant to facilitate certain transactions and relationships.
The schedule covers, inter alia, Chinese acceptance of FAA Export Certificates of Airworthiness appliances, parts, and materials for which the FAA is the exporting authority.  The schedule explains that China will accept US export certificates of airworthiness for parts and materials when the FAA certifies that each article:

(a) Conforms to approved design data;
(b) Is properly marked; and
(c) Meets the special requirements of the importing country.

This is typically done through the issue of an FAA 8130-3 tag.

The special import requirements of China must be formally presented to the United States, and then the United States publishes those special import requirements in Advisory Circular (AC) 21-2.  The Chinese special import requirements apply to airframes, engines, propellers, and TSOA articles, but the only special import requirement that applies to FAA-PMA parts is that the part must be accompanied by an 8130-3 tag.  Since the 8130-3 tag is the medium for communicating the compliance, the 8130-3 for a FAA-PMA part can be safely annotated as meeting the special import requirements of China.

The Chinese have clarified in several places that they really mean it when they say that they are accepting PMA parts.

In order to ensure that there is no confusion, appendix D of the Schedule of Implementation Procedures specifies that the term ‘part’ means replacement and modification parts manufactured under any FAA production approval.  The appendix goes on to say that this includes replacement and modification parts manufactured by an FAA-PMA holder!

Some additional provisions are listed in the Schedule of Implementation Procedures , but none of them actually impose any additional obligations on someone who exports a PMA part to China, so long as that part already complies with US regulatory standards.

  • Critical components must have a part number and a serial number (this is already required under FAA Part 45 for FAA-PMA parts); and
  • All PMA parts must be marked with the part number and the manufacturer’s name or trademark (this is also required of all PMA parts under FAA Part 45 marking requirements).

China has also published their own advisory circular on the acceptance of FAA-PMA parts.  The advisory circular clarifies that FAA-PMA parts are acceptable for use on Chinese aircraft and reiterates that the parts should marked according to the requirements of FAA Part 45.

MARPA and Other Trade Associations Fight to Prevent FAA From Being Assigned Needless Tasks

Some of you may have heard that there is legislative language that would force the FAA to promulgate unnecessary regulations related to marking of “influencing parts.”  These would be defined as parts that can affect an engine LLP; there is no further refinement that would limit the scope of the term “affect.”

The proposed legislation would require the FAA  to issue regulations for marking these “influencing parts.” Ordinarily, you mark a part because the part marking is perceived to be useful; but it appears that the proposed markings would not be used for anything.  No guidance for what should be marked on new parts is indicated, so one cannot even guess at the purpose that such markings might achieve.

Under the proposal, the FAA would also be required to issue regulations for “post repair marking or identification on an influencing part [to reflect] the drawings and specifications used to gain the repair design approval issued by the Federal Aviation Administration.” What is wrong with this picture:

  • Remember that the description of the work performed is required to be on the approval for return to service and is typically included in the work order as well, so this marking requirement is generally redundant.
  • The FAA has no uniform identification system for drawings and specifications, and drawings and specifications are typically proprietary, so the reference would also be meaningless to third parties in many cases, thus the specific requirment provides no value.
  • Given the fact that hot section parts generally will lose markings due to the conditions inside the engine it appears that this requirement is not calculated to achieve anything useful for such parts.
  • Finally, marking engine parts in a way that will not be rapidly eradicated may require physical marking (like vibra-peening); such marking practices need to be researched for individual parts because of the possibility that they may undermine the strength or integrity of the part (thus wasting resources better spent on protecting safety).  So such marking requirements may actually undermine the safety of aircraft engines!

Perhaps the most important issue here is that anything that seemed good about this proposal already exists in FAA regulations and/or guidance.  The FAA has been diligent on the issues surrounding this proposal, and legislation is not needed.  Legislation of this sort would only serve to divert important FAA resources away from issues that really do affect safety.

Several trade associations have banded together to write Congress about the impracticality of this proposal.  The letter is being transmitted to Congress today.

Special thanks go out to Daniel Fisher, the Vice President of Legislative Affairs for ARSA, who alerted us to this legislative issue and who led the effort to send a letter to Capitol Hill on this issue.

MARPA Efforts to Increase PMA Sales to Southeast Asia and China

MARPA is organizing the first-ever PMA Trade Mission to Singapore and China (Hong Kong, Guangzhou, Shanghai and Beijing) for November 3-13, 2015.

The purpose of this trade mission is to introduce air carriers and MROs in Southeast Asia and China to the concept of PMA, and to the significant advantages that they can recognize by doing business with PMA manufacturers from the United States.  We hope that this will help increase PMA sales into these regions.

The mission will begin for MARPA at MRO Asia in Singapore, November 3 through 5.  We are planning to set up a few pre-scheduled meetings as well as allowing members to interact with the MRO attendees.  After MRO, we will fly to Hong Kong to meet with air carriers on Friday.  We plan to transfer to Guangzhou over the weekend in order to meet with Gameco and China Southern on Monday.   Then we will spend Tuesday-Wednesday in Shanghai and Thursday-Friday in Beijing meeting with air carrier and MRO sales targets.

If you aren’t yet selling into Asia, then this is a wonderful way to start meeting potential customers.  If you already have business in Singapore, China and Hong Kong, then you won’t want to miss this exceptional opportunity to renew acquaintances and build more business.

Tails at Beijing Airport

Tails at Beijing Airport

MARPA has been planning this 2015 trade mission since late 2014, and we’ve enjoyed incredible support from our US government contacts.  This trade mission is undertaken in partnership with the US Department of Commerce, and we are being assisted by the International Trade Administration and the Commercial Foreign Service officers in the embassies and consulate offices.  This is a valuable membership benefit that is available to help MARPA members increase their export business so make sure you take advantage of it!

If you are interested in participating or want more information, then please contact the Association.  We’d love to hear from you.

We hope to soon be able to offer a specific itinerary and price for the mission.  Once this is announced, we will take firm commitments from members on a first-come-first-served basis until the program is full.

Wondering if you can sell PMA parts into China?  Tomorrow we will start addressing the legal standards for PMA acceptance in China!

New FAA Draft Policy: Structural Certification Criteria for Antennas, Radomes, and Other External Modifications

The FAA has published new draft guidance for public comment. The policy statement identifies acceptable means of compliance for certification of external modifications to Part 25 aircraft. Such modifications can include antennas, radomes, cameras, and external stores.

The draft policy explains that there has been a significant increase in the number of structural certification projects involving external modifications, especially large antenna installations. It provides guidance on selection of certification requirements within the context of the certification basis of the modification. The directions in the policy statement are each linked to existing regulations, so no new regulatory obligations are meant to be imposed.

Comments are due to the FAA by July 6, 2015.

You can email comments to:jan.thor@faa.gov

Comments can also be delivered by mail or hand to:
Federal Aviation Administration
Transport Airplane Directorate
Transport Standards Staff, ANM-110
1601 Lind Avenue SW
Renton, WA 98057

Please send a copy of your comments to MARPA, so that the Trade Association’s response can support your concerns. Please also let the Association know if this is guidance that is important to your business.

New Draft FAA Guidance: Non-TSO Functions in Seats

The FAA has published new draft guidance for public comment.  The policy statement clarifies the non-TSO function language in TSO C127B, which was added in 2014.  Non-TSO functions are those that go beyond the minimum standards of the seat TSO, like reading lights or in-flight-entertainment.

The draft policy explains that non-TSO functions in aircraft seats should be declared, in order to signal to the installer that the substantiation and design control for the added functionality may need to be addressed by a separate design approval, because it may not have been an FAA-approved design element in the TSO design approval.  It also provides additional guidance on what functions are non-TSO functions.

Comments are due to the FAA by July 20, 2015.

You can email comments to: robert.a.rouza@faa.gov

Comments can also be delivered by mail or hand to:
Federal Aviation Administration
Design, Manufacturing & Airworthiness Division
Systems & Equipment Standards Branch, AIR-130
470 L’Enfant Plaza, SW, Ste. 4102
Washington, DC 20024

Please send a copy of your comments to MARPA, so that the Trade Association’s response can support your concerns.  Please also let the Association know if this is guidance that is important to your business.

MARPA Founder Jim Reum; Dead at 83

It is with great sadness that we report that Jim Reum passed away on Sunday, June 14th due to complications resulting from an automobile accident. He was 83 years old.

Jim Reum

Jim Reum chaired the first MARPA Board meeting in 2000

Jim was one of the original three founders of MARPA.  The idea of MARPA started when he was a delegate on the FAA’s Part 21 ARAC Working Group (parts and production approvals).  As those meetings conrttinued, he and others recognized that there was a need for a permanent voice for PMA in Washington, DC.  Over lunch during a break from the working group meetings, he agreed to start MARPA with George Powell and Jason Dickstein.  As it is with many great foundational documents, the agreement to form the trade association was written on a placemat from a Washington DC Irish Bar.

Jim served as the original Chairman of the Board of Directors of MARPA and he established a tradition of strong support for MARPA among the Heico family of companies.  He introduced other companies to the MARPA community.  He helped to set the pattern of strong MARPA support for safety and for FAA compliance programs.  He believed that MARPA should always stand for the highest ideals of safety and compliance, and he was always generous with his time in these pursuits.  Even after leaving the Board, he continued to serve  as a mentor to the MARPA community.

I will always remember Jim for his patience in teaching me how things really work.  He would take me through the Jet Avion facility and explain how things were built, and would unselfishly detail the innovations in production and testing of which he was most proud.  He understood that a lawyer needs to understand the technical side of PMA, if that lawyer is going to adequately represent the industry.

In those days, we fought shoulder-to-shoulder just to convince the industry that PMA parts were safe and acceptable.  Jim was always happy to share the industry’s safety data; and he was always willing to give anyone a tour of the Jet Avion/Heico facilities.  After a tour of those facilities with Jim,  it was easy to understand how much effort went into compliance and safety, and to trust PMA.

Heico’s President Eric Mendelson eloquently eulogized Jim in an address to the Heico staff:

Jim was an incredible friend to HEICO and mentor to our team members for the last 25 1/2 years. We will miss him greatly. Our values and quality focus exist as a result of Jim’s efforts and beliefs and HEICO has lost a truly incredible human being. HEICO wouldn’t be the company it is today without Jim Reum.

After a long and distinguished career in the aviation industry with General Electric, United Airlines, Aviall, and Chromalloy, Jim joined HEICO as a consultant in 1990. His initial project was to recommend where HEICO should focus its efforts, after successfully saving the worldwide narrow-body fleet from grounding after an OEM-redesign of the JT8D Combustion Chamber.

Jim recommended that HEICO “become the NAPA of the Aerospace Parts Industry” and then came out of retirement to become EVP-COO of our Flight Support Group in order to help HEICO achieve his vision. Along the way, Jim created the quality technical focus for which HEICO is known, and helped to instill our values which have permitted HEICO to become the company that it is today.

Those who were lucky enough to work with Jim until he retired from full-time service on his 70th birthday in 2001, and then again as an EVP until his passing, remember his kind and patient temperament combined with his incredible judgement, knowledge, passion, dedication, loyalty, humility, and respect for people. He gave so much of himself and so many of us at HEICO received opportunities to grow as a result of his unwavering confidence and support.

Jim’s passing has created a permanent void in our hearts, but his spirit lives on in all of us, and for that we can be very proud. Jim frequently commented that “HEICO is the highlight of my career.” Words can’t express the love that Jim felt for HEICO and our Team Members.

Our thoughts and prayers are with his wife Ann and son Rex and their entire family. The Reum Family can take great comfort in knowing the outpouring of gratitude and collective appreciation for sharing Jim with us and for letting us learn so much from such a fine human being.

There will be a Memorial Service for Jim at 11am on Saturday, June 20th:

2005-10 Powell Dickstein Reum

MARPA Founders in 2005. From Left to Right, George Powell, Jason Dickstein, Jim Reum.

Covenant Village
9215 West Broward Blvd
Plantation, FL 33324

Flowers and Cards may be sent to:

Reum Family
c/o Jim Reum Memorial Service
Attn: Chaplin Rocky Cook
9215 West Broward Blvd
Plantation, FL 33324-2404

New Draft FAA Guidance: replacing vacuum-driven attitude instruments with electronically-driven replacement indicators

The FAA has published new draft guidance for public comment.  The guidance is meant for instruments and indicators designed for small (Part 23 or CAR 3) aircraft.  It is a policy statement that describes acceptable compliance methods for replacing vacuum-driven attitude instruments with electronically-driven replacement indicators. Electronically-driven attitude indicators include indicators that use electrical power to (1) excite an internal gyro, or (2) replace the operation of the gyro with microelectronics.

The policy notes that electronically-driven attitude indicators may replace the existing attitude indicators used in VFR or IFR airplanes.

Comments are due to the FAA by August 21, 2015.

You can email comments to: leslie.lyne@faa.gov

Comments can also be delivered by mail or hand to:
Federal Aviation Administration
901 Locust St
Room 301, ACE-114
Kansas City, MO, 64106

Please send a copy of your comments to MARPA, so that the Trade Association’s response can support your concerns.  Please also let the Association know if this is guidance that is important to your business.

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