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DRAFT Materials Advisory Circular – Extension of the Comment Period

Many of our members have been communicating with us about their concerns over the proposed Materials AC. We had previously asked the PMA community to send us their comments and concerns so we could assemble them into a single missive to deliver to the FAA.

We’ve heard from a number of you that the large volume of material and the highly technical nature of the proposed AC has made it slow going to put together your comments.  With this in mind, MARPA asked the FAA last week for a extension of time to file comments on this draft.

We received the answer today, granting that extension.

Dear Mr. Ryan Aggergaard,

This e-mail is in response to your request to grant a 90 day extension to comment on the FAA public draft Advisory Circular 33.15-3, titled “Parts Manufacturer Approval (PMA) Metallic Part Material Compliance Using Comparative Test and Analysis Method for Turbine Engines or Auxiliary Power Units”.

The FAA will consider comments after the comment period has closed if it is possible to do so without incurring expense or delay.

We have determined there will be no incurring expense or delay, and will grant the MARPA members and the MARPA Technical Committee an extension from July 20, 2016, to October 18, 2016.

Please feel free to contact us if you have any questions or concerns.

Sincerely,

Judith Watson

Please do not wait until October to review this AC and develop your comments.  The earlier you can provide your comments and concerns to the FAA (and to MARPA), the better able we will be to address them in a positive and productive way with the FAA.

Challenges Apparent in Reconciling Performance Based Regulations and Emerging Technologies

MARPA had the opportunity this week to attend the 2016 FAA-EASA International Aviation Safety Conference that was held in Washington, DC. The conference provides an opportunity for the regulatory agencies and industry to get together to discuss emerging issues in aviation safety and strengthen the cooperation between both the regulators themselves as well as the regulators and industry.

One notable panel discussed performance-based regulations (PBR) and their development, implementation and oversight as a part of the ongoing safety management adoption. The goal of PBR is essentially to retain the high level requirements and clearly establish what those high-level regulations are trying to achieve, while clearing out more detailed prescriptive regulations. Those detailed regulations would then be replaced by industry consensus standards.

In theory, this should clear the way for innovation by focusing more on ensuring a satisfactory outcome (that complies with the regulations) is the result, rather than focusing on prescriptive compliance-based rules. (How this exactly squares with a safety management system focused on systems and processes rather than the outcome per se is a conversation for another day.)  Performance-based regulations can free the hands of regulated parties and avoid the trap of innovation stagnation in which companies are forced to design or produce in only limited ways in order to comply with the regulations.

Although moving to a PBR approach may be a laudable goal, the next panel demonstrated how challenging it may be for regulators to break free of deeply ingrained compliance-based approaches to oversight.  Relevant to PMA manufacturers, the “fast-moving technologies” panel spent a significant amount of time discussing certification of projects using additive manufacturing techniques.

In theory, a PBR approach would be ideal for approving parts manufactured using emerging technology like additive manufacturing (AM).  If a part can be produced using AM techniques (like 3D printing) that meets all the design requirements (dimensions, material composition, durability, etc) of a part that is traditionally machined, an outcome-focused approach like PBR claims to be should have no problem approving that part. Conversely, if a 3D printed part cannot be made to conform to the approved design, our quality assurance systems reject the part and we go back to the drawing board.

However, it became clear during that panel that we can expect to see more of the same compliance based review of processes in seeking to obtain approval of parts manufactured using emerging technologies like AM.  Of course to borrow from Captain Renault I was shocked, SHOCKED to find that the OEM panelist expressed skepticism that “sub-tier” suppliers or those in the aftermarket were capable of producing approved parts using these methods. But of greater concern was his statement that the regulators might also question that ability.

Part of this concern on the part of the regulators arises from the fact that the regulators themselves do not fully understand technologies like AM yet. The FAA is currently working with industry to determine what controls will need to be in place and what the oversight requirements will be with respect to AM. It will therefore be very important for any PMA manufacturer seeking to use new techniques to manufacture parts to engage the FAA early in the process and demonstrate to the FAA its competence with the technique. This may involve educating the FAA in some cases (and refuting the implications of some larger OEMs that only they know the “special sauce” of new technology).

This much was supported by FAA AIR-1 Dorenda Baker, when she explained that the key to getting approval when relying on new technology is ensuring an understanding on both sides. The FAA needs to be brought into the process very early on. When the FAA is brought in at the last minute, problems and confusion can arise, because what might seem clear to the applicant, who has been working with the technology for months or even years, can seem confusing to the regulator seeing it in action for the first time.  Ms. Baker explained that we don’t want questions being asked for the first time, or engineers trying to understand new processes, at the time of certification. We, as applicants relying on new manufacturing techniques, need to engage the FAA early and often.

Of course this is somewhat inconsistent with a performance-based approach. As we mentioned above, if the goal of PBR is to ensure an outcome that satisfies high-level regulations, it should be less important how we get to the result than that we obtain a satisfactory result. A need on behalf of the regulator to understand fully the processes by which we obtain the result is more consistent with systems oversight (their stated goal) but doesn’t square perfectly with a PBR approach.

Nonetheless, it thus becomes clear that the PMA industry will have to fight this battle of fast moving technology on two fronts: First, we will have to (again) battle against an OEM-driven (mis)perception that only OEMs are capable of understanding and safely applying emerging technologies like additive manufacturing. Second, we will have to work very closely with the regulators to continuously demonstrate our competence and expertise in applying these technologies, and in effectively implementing systems that consistently produce the desired outcome.

There is a lot happening right now; from fundamental shifts in the role regulators play to the way we design and manufacture parts. By frequently engaging with the regulators we are able demonstrate our competence and abilities (simultaneously refuting any implications by competitors to the contrary) and keep the regulators closely engaged so that the certification process moves smoothly and we are able to nimbly adapt to changes as they happen.

MARPA will continue to keep you updated as old regulations change and new regulations emerge.

EASA is Moving

By Monday, the European Aviation Safety Agency (EASA) will have a new location. The new location is closer to the main Koln train station (same side of the river). As of June 6, 2016 EASA will be operating from their new Headquarters located at:

Konrad-Adenauer-Ufer 3
D-50668 Cologne, Germany

The post-office box as well as all telephone numbers remain the same:

Postfach 10 12 53
D-50452 Cologne, Germany

Tel: +49 221 8999 000
Email: info@easa.europa.eu

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.

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.

CHINA

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

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.

ACCEPTANCE OF CHINESE PMAs

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).

FAA PMA FOR CHINESE MANUFACTURERS

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

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.

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