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 311 posts for MARPA

Compliance with the New Part 21 Rules

As we discussed at the MARPA Annual Conference, Part 21 has been amended in some ways that will impact the PMA community.

The amendments can be found in the October 1 Federal Register.  There are three main amendments that drive change in a PMA company’s production quality system:

  • Change in the compliance statement;
  • Change in supplier management; and
  • Capability for PMA holders to issue 8130-3 tags  (without using designees).

MARPA has drafted compliance guidance that explains what the change are, and provides checklists to aid in compliance with each of the changes that significantly affect the PMA community.

The MARPA compliance guidance will be mailed to MARPA members with the next MARPA Supplement.  if you are a MARPA member and do not receive the MARPA Compliance Guide with the November 25 MARPA Supplement, then please contact the Association.

Opinions Sought on AC 33-8 (PMA on engine and APU parts)

What do you think of AC 33-8?

AC 33-8 is the “Guidance for Parts Manufacturer Approval of Turbine Engine and Auxiliary Power Unit Parts under Test and Computation.”  This guidance has been out in the industry for six years now.  A number of our members have reported that this guidance has been useful for them.

MARPA will be meeting with the FAA in four weeks and one of the topics will be AC 33-8.

Please get us your comments – positive or negative – on this document.  Let us know if it has been useful (and what has been useful, if possible).  Let us also know whether any of the AC language poses problems or could be improved.  Also, if you think that the guidance is  missing anything, then let us know what additional information could be useful in the guidance.  Please send your comments to us by email or leave a response in the blog comments.

PMA in China

One of our members recently reported that his company has been offering cabin interior PMA parts to several Chinese airlines, only to be told that they are already using CAAC PMAs for many of these cabin parts. CAAC PMAs are Parts Manufacturer Approvals issued by the Civil Aviation Authority of China.  CAAC PMAs are acceptable for installation on Chinese-registered and Hong Kong-registered aircraft but they do not appear to be currently acceptable for installation on any other aircraft.

Our member asked whether there is a master list of CAAC PMA parts that MARPA members could review.  This would help MARPA members know which parts have not been PMAed in China which in turn will help to reveal which FAA-PMA parts might be most valuable and useful to Chinese air carriers.


As far as we know, the master list of CAAC PMAs is only maintained as an advisory circular.  Because it is an advisory circular, it is not maintained in real time, but rather it is updated annually.  This link is to the 2015 revision of the CAAC PMA Catalog.


Hong Kong has a separate aviation authority.  Hong Kong’s Civil Aviation Department also issues its own PMAs.  Hong Kong has issued PMA authority to Taikoo (Xiamen) Aircraft Engineering Co. Ltd.  There is a Schedule of Implementation Procedures between China and Hong Kong under which each accepts the PMAs of the other.


Remember, the current US-China bilateral permits entry of US PMAs into China, but it is currently a one way only: it does not permit installation of Chinese PMAs onto US-registered aircraft. Without an explicit acceptance of CAAC PMAs through a US document (such as the US-Chinese bilateral agreement), CAAC PMAs are not currently eligible for installation on US registered aircraft as replacement or modification parts (under 14 C.F.R. 21.9).


There is a mechanism for Chinese companies to obtain US PMA.  Chinese companies wishing to set up final production sites in the US could apply for US PMA and could use that as a mechanism to create FAA-PMA parts that are accepted all over the world.  For many Chinese companies, the most efficient and effective way to accomplish this would be to partner with an existing FAA-PMA holder in the United States that has experience navigating the FAA regulatory system.

The 21st Century Model of Certification

I just got off the phone with senior leadership at the FAA and all I can say is “WOW.”

The FAA is talking very seriously about a new model of certification for the aerospace industry focusing on approval of design processes and risk-based oversight in order to better leverage the FAA’s resources to ensure safety of the growing aerospace marketplace.

I shouldn’t be surprised.  The models are there, and they’ve worked.  We’ve sat on Federal Advisory Committees that have made these recommendations to the FAA.  The industry has been talking about this for years.  But sometimes when you talk about projects for too long, you start to lose hope that they will ever come to fruition.

But this idea has the support of the FAA’s senior management and that is what will make the difference.

The new model of certification will likely rely on paradigms like:

  • Safety Management Systems (SMS)
  • A company’s library of FAA-approved or FAA-accepted methods to demonstrate compliance to the regulations
  • FAA Centers of Excellence that can assist with issues that go beyond the approved compliance libraries
  • Self-certification of compliance (following the successful model currently used for issuing TSOA)

Under this new paradigm, a company that specializes in PMAs for landing gear (for example) would have a library of compliance methods – test and procedures that are designed to show compliance to the regulations (including ways to demonstrate true identicality with an existing compliant design).  By following the compliance methods from the library, the company would be able to demonstrate compliance for future landing gear parts.  This would allow the company to more readily develop compliant designs that can be readily PMAed based on the methods that are already known to be sound.

This would involve a major restructuring of how the FAA oversees design approval.  Moving to a TSOA-like self certification should permit small businesses to react very nimbly to market forces and it allows the FAA to more readily focus its resources on real safety issues based on risk assessment.  This paradigm could be supported by FAA Centers of Excellence that would be able top provide support to the design approval community on technical issues.

This paradigm could also impose more responsibility on the design approval applicant.  It would likely be reflected in design systems that would be subject to FAA surveillance.  This would replace the current model in which designs are reviewed.  It would be analogous to the modern approval to production quality systems, in which the FAA approves  system rather than approving each individual part and product that comes out of the system.

For PMA companies, this could help companies bring part to market faster, when those parts fall within the compliance library, because it would limit the FAA’s involvement in projects where compliance can clearly be shown based on known and accepted methods.

We are currently working with the FAA on a presentation (“challenge session“) about this new paradigm; we hope to add this to the program for the 2015 MARPA Conference.

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 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,

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!


Get every new post delivered to your Inbox.

Join 86 other followers