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MARPA Joins Industry Groups Securing Reissuance of FAA Notice 8900.380 Policy

On August 2 MARPA joined a petition signed by 12 other industry groups seeking the extension of FAA Notice 8900.380.  This effort was spearheaded by the Aviation Suppliers Association (“ASA”), the trade association that represents aircraft parts distributors. The policy serves to formalize a repair station’s ability to receive, inspect, and approve for return to service new articles that are not accompanied by an 8130-3 tag. Yesterday, the FAA responded to the petition by agreeing to reissue the policy for another year.

The FAA-EASA Maintenance Annex Guidance revision 6 (“MAG 6”) made the 8130-3 tag a requirement for new parts received into a dual-certificated repair station, even though the 8130-3 tag is not required by the regulations. Not only was this requirement contrary to the actual regulations, it also had the effect of making it difficult for distributors to sell many new parts received from a PAH, and for repair stations to receive new parts released from a PAH, because many PAH’s do not issue 8130-3 tags for new parts (something that is also not required under the regulations).

Notice 8900.380 provided a temporary solution to this issue by ensuring industry knew that repair stations could receive and inspect new parts within their ratings without an 8130-3 tag.  This was particularly important for low-dollar value parts for which obtaining a tag from a designee was economically infeasible.  This solution is expected to be permanently memorialized in MAG 7, but with only weeks before the expiration of the Notice no draft of MAG 7 has yet appeared on the horizon, and so a different solution was required. Notice 8900.380 was scheduled to expire on August 26 before a permanent solution to this tag problem was reached.

In order to support industry the FAA responded to the petition initiated by ASA and signed by MARPA by reissuing the policy in the form of Notice 8900.429.  This notice continues the policy established by Notice 8900.380 for another year, until August 9, 2018.  Hopefully this will give the FAA, EASA, and industry time to develop a permanent solution to the 8130-3 problem created by MAG 6 and memorialize that solution in MAG 7.

MARPA is thankful to ASA for leading this effort, as it allows our members–and the PMA community generally–to continue operating our business in the ways we deem most effective, whether we choose to issue 8130-3 tags with our parts or not. Implementing the optional procedures to issue 8130-3 tags described in 14 C.F.R. § 21.137(o) comes with inherent costs, and so it is valuable to not have that requirement forced onto PMA manufacturers by a de facto requirement arising from MAG 6.

You can read the full Notice 8900.429 here.

MARPA to Return to Dublin in 2018!

Mark your calendars!  After a successful third annual MARPA EMEA Conference, MARPA has decided to return to Dublin, Republic of Ireland to continue building upon the success we have made in engaging the leasing community and expanding the use of PMA across Europe and the Middle East.  MARPA has chosen to return to Ireland and hold its fourth annual MARPA EMEA Conference April 30 – May 1, 2018 at the Hilton Dublin Kilmainham hotel.

MARPA knows our members are busy and that there are many conferences fighting for your time and attendance.  We are therefore continuing with our pattern of running a very efficient two-day conference with a great networking reception on Monday, April 30, and a full and informative general session on Tuesday, May 1, with plenty of opportunities to network throughout the day.

Locating the MARPA EMEA Conference in Dublin allows for easy travel from the United States and Europe, and the efficient two-day event also allows members traveling from the U.S. to tie in visits to existing customers and potential customers across Europe after the event concludes. (Attendees have also taken advantage of event in the past to enjoy a little time off with their families afterward.)

MARPA looks forward to continuing our discussions with the aircraft leasing companies that call Ireland home, and working with our air carrier friends and friends in government to continue the promotion and global acceptance of PMA.  The MARPA EMEA Conference reliably produces an excellent ratio of customers to suppliers and provides ample opportunities to both expand current business and develop new business with customers you might not see anywhere else.

Visit the MARPA EMEA Conference page to learn more, and check back often as we add speakers to the agenda.

Are there speakers or topics you would like to see addressed?  Email your recommendations to MARPA Senior Program Manager Katt Brigham at katt@washingtonaviation.com so that we can provide you the most valuable conference agenda we can.

Standard Parts Do Not Need PMA (but it can be an option)

A consultant recently told me that his client is planning to produce parts under NASM22529.  He asked for advice about the process for showing compliance to get a PMA.

NASM22529 is an AIA/ NAS standard.  It replaced a milspec of the same number that was retired in 1996.  As an AIA (NAS) specification, it is recognized as the sort of industry specification that supports ‘standard parts’ under the FAA’s interpretation of the term.

Standards parts can be manufactured and sold without a PMA.  The regulatory authority for this can be found at 14 C.F.R. § 21.9(a)(3).  Therefore a PMA is not necessary in order to produce standard parts intended to be consumed in civil aviation.

While it is not necessary to seek FAA approval to manufacture a standard part,it is nonetheless possible to get a PMA for a standard part, and in some cases (like fasteners) it can also be possible to obtain a TSOA for a standard part.

There are a number of reasons why someone might seek to obtain FAA approval for a standard part.  This sort of FAA approval can be valuable for marketing purposes.

If you seek FAA approval for a part, then the design of the part must be shown to meet the appropriate FAA standards, and the production quality assurance system must be developed to meet FAA requirements.

The same consultant also asked whether AS9100 certification satisfies all or most of the PMA requirements?  The AS9100 series of specifications were specifically designed to support compliance to aviation regulatory standards, but compliance with AS9100 should not be confused with compliance to FAA regulations.  The answer to this question can depend on the implementation of the AS9100 system.

AS9100 will typically satisfy requirements under 14 C.F.R. § 21.137, as well as certain other requirements, but it may does not satisfy all FAA approval requirements (A well-developed AS9100 system can be developed to provide management assurance of compliance with all of the relevant FAA requirements but it can also be developed to omit some of them).

The design side of the manufacturing process is a process that is particularly susceptible to a finding that the AS9100 system is not adequate, alone, to ensure compliance to FAA regulations.

Looking to learn more about PMAs?  You may want to consider attending the MARPA Conference in Orlando on October 25-26, 2017.  The FAA has confirmed that they will be teaching a “PMA 101” workshop as part of the Conference.  You can find out more at http://pmaparts.org/annualconference/about.shtml

Manufacturing Receiving Inspection is Not the Sort of “Inspection” that requires Drug and Alcohol Testing Under DOT Standards

Are manufacturers required to drug test their receiving inspectors?  A recent FAA legal interpretation explains that receiving inspectors typically are not subject to the DOT drug and alcohol testing rules.

The FAA has issued a legal interpretation that confirms that receiving inspectors who are receiving articles for stock are not performing maintenance activities, and therefore they are not among the personnel who are required to be subject to DOT-regulated drug and alcohol testing.

This effort was spearheaded by our industry colleagues at ARSA, but the final request for interpretation was jointly filed by 15 organizations (including MARPA).

The root of the issue is that the Part 120 requirements require air carriers to ensure that their maintenance subcontractors are tested under the drug and alcohol rules. This requirement is applied to those who perform aircraft maintenance duties – but those who do not perform such duties are not subject to the testing requirement.  Inspection is described as a species of maintenance in the FAA’s definitions.

So what about manufacturers who produce in support of an air carrier’s maintenance efforts?  Are their receiving inspectors performing maintenance when they inspect incoming articles?

The FAA explained:

14 CFR part 43 applies to the performance of maintenance and preventative maintenance. Sections 43.9 and 43.11 establish recordkeeping requirements for tasks associated with maintenance and preventative maintenance. These recordkeeping requirements have never been applied to tasks associated with receiving articles for stock. Individuals who perform receiving tasks ensure that there is no visible damage to the packaging or the enclosed items, and that the articles were obtained from an approved or acceptable source. Persons performing these tasks compare part numbers, serial numbers, quantity, etc. with the purchase order and confirm that the items match the purchase order and that they are not damaged. These tasks are not maintenance or preventative maintenance activities. Therefore, employees receiving items for stock are not safety sensitive employees under part 120 and should not be included in the pool of employees subject to drug and alcohol testing.

 

2017 MARPA EMEA Conference a Success

This month marked the third annual MARPA EMEA PMA Parts Conference. After successful events in Istanbul (2015) and Madrid (2016), MARPA hosted this year’s conference in Dublin, Republic of Ireland, with the twin objectives of engaging the aircraft leasing community, and making attendance convenient for both MARPA’s manufacturing members and air carrier members.  Building on the success of the previous two years, MARPA was able to bring together more than a dozen different customers and potential customers to meet and network with PMA manufacturers and hear from government representatives and members of industry about the opportunities and benefits of PMA.

One of the primary reasons for selecting Dublin as the site of the 2017 MARPA EMEA Conference was to work to engage the leasing community in discussions about the acceptability and use of PMA on leased aircraft. The use of PMA on leased aircraft is one of the most important issues that members mention to MARPA, and restrictive clauses in lease agreements often create challenges for member operators in implementing and achieving their maintenance program goals, whether driven by cost, efficiency, or reliability.  As leased aircraft continue to expand as percentage of the global fleet, it will become more and more important to work with lessors to ensure PMA remains an option for operators of leased aircraft.

MARPA worked closely with representatives from the International Trade Administration and the U.S. Embassy in Ireland to secure a meeting with members of the leasing community. This initial meeting was hosted by the Charge d’affaires Reece Smyth and was attended by representatives of the ITA, FAA, representatives from each of MARPA’s conference sponsors, and representatives of several leasing companies.  This was a very productive luncheon in which the lessors were able to explain their positions and concerns, and government regulators and MARPA members were able to address and discuss those concerns, as well as describe how and why PMA are beneficial not just to operators, but to the lessors themselves.  (Due the sensitive nature of these discussions, and potential competitive issues, the lessors have asked us to refrain from broadly naming them at this time.)  The challenges of PMA and leased aircraft were not solved by this luncheon, but it was an important step in continuing the conversation and addressing lessor concerns. MARPA hopes that this was just the first of many productive conversations that we will have with the aircraft leasing community.

The MARPA EMEA Conference also provided an opportunity to meet and network with a number of air carriers and MROs, some of whom can’t be seen (or previously haven’t been seen) at the MARPA Annual Conference in the U.S. Attendees included operators such as Aer Lingus, Emirates, Swiftair, and the Dubai Royal Air Wing, among others, as well as MROs like Luthansa Technik and Dublin Aerospace.  The combination of receptions, lunch, and breaks, provided several hours of time to meet with the attendees and begin to develop or further build customer relationships, and for the operators to get new and useful information from manufacturers.

And, as always at a MARPA event, there was a robust agenda featuring presentations from all sides of the industry.  These presentations included the keynote address by Aer Lingus Chief Technical Officer Fergus Wilson, as well as presentations from Stobart Air and Delta Air Lines, in which each discussed the role PMA plays in their operations, how they use PMA now and what they see in the future, and anecdotes about the successful use of PMA in their maintenance programs. Charge d’affaires Reece Smyth also offered remarks on the efforts by the U.S. and Ireland to encourage small businesses, stimulate trade and job creation, and the excellent trade and diplomatic relationship between the U.S. and Ireland.

Manufacturers also offered their insight into the industry, described hows and whys of some of their successes, and made predictions about the direction of PMA.  Finally, speakers from the FAA made presentations about the status of initiatives that could affect the PMA industry, both domestically and internationally, and recapped for attendees the regulatory basis for PMA.

MARPA hopes to build on the success of the past three EMEA Conferences going forward and continue to deliver quality content and networking opportunities to our members domestically and internationally. MARPA also looks forward to seeing everyone in Orlando for the 2017 MARPA Annual Conference for more great speakers, workshops, and business development opportunities.  Register today!

Finding Suppliers in Taiwan

Are you looking to expand your global supply base?  The Taiwan Trade Center is raising awareness about the Taipei Aerospace & Defense Technology Exhibition (TADTE), which will be held in Taipei on August 17 – 19.  In order to entice potential business partners to the show, the Taiwan Trade Center is offering generous subsidies to MARPA members interested in attending the exhibition.  Here is their offer:

For qualified buyers, we offer the following incentives:

  1. For companies with annual sales exceeding US$30 million that are related to the industries profiled in the show, TAITRA will offer 1 R/T economy-class ticket scheduled stay during two full show-day periods between August 17 and August 19, 2017, 1 room with a maximum allowance of NT$15,000 (tax included) to be used toward lodging (up to 4 nights being in August 16 to August19, 2017) and airport pickup to-from the accommodating hotel. Attending procurement meetings is requested.

  2. For companies with annual sales exceeding US$5 million that are related to the industries profiled in the show, TAITRA will offer 1 R?T economy-class ticket scheduled stay during two full show-day periods between August 17 and August 19, 2017. Attending procurement meetings is requested.

  3. For companies with annual sales exceeding US$0.3 million that are related to the industries profiled in the show, TAITRA will offer 1 room with a maximum allowance of NT$ 15,000 (tax included) to be used toward lodging (up to 4 nights being in August 16 to August 19, 2017) and airport pickup to-from the accommodating hotel.

In order to accept this offer from the Taiwan Trade Center, MARPA members must complete the 2017 TADTE Registration Form. The completed form should be emailed to Unice Wu from the Taiwan Trade Center – New York at unicewu@taitra.org.tw. There are a limited number of subsidies available, so apply ASAP!

 

Taiwan Details:

Despite the ‘One-China-Policy,’ Taiwan has its own Civil Aviation Authority which is separate from the CAA of China. Taiwan has processes for issuing TSOA and PMA. Under a bilateral agreement, the US accepts new TSO appliances from Taiwan that meet the performance standards of an FAA TSO under an FAA letter of TSO design approval. They also accept replacement parts for those TSOA articles. The U.S. currently does not accept PMA parts from Taiwan.

EASA has a working arrangement with the Taiwan CAA for the validation of EASA certificates. This appears to be a one-way arrangement; EASA does not appear to have a process for validating Taiwan CAA approvals.

In defense contracts, Taiwan is treated by the United States as a major non-NATO ally (22 C.F.R. § 120.32).

FAA-AIR Transformation Process Continues

Those readers of the MARPA blog who have attended a MARPA Annual Conference in the past two years probably heard the FAA’s David Hempe give a presentation discussing the transformation currently underway at the FAA’s Aircraft Certification Service (AIR) division. As we have previously discussed here and elsewhere, the goal of this transformation is to shift AIR from a compliance-based certification strategy (wherein an applicant makes a showing and the FAA issues a finding on a one-for-one basis) to an oversight-based certification strategy (wherein the FAA focuses more broadly on standards and systems oversight in order to ensure applicants are remaining compliant).  Mr. Hempe’s presentations have provided a great deal of information and insight into this transformation, and MARPA is grateful for his participation and willingness to answer conference attendee questions over the course of the conference.

Obviously, such a transformation will require change by industry; but more importantly the FAA understands that it will also require a culture shift within the agency itself to reflect this change away from a compliance model toward an oversight model.  To that end, the FAA has offered a briefing to applicants and approval holders (those who will be affected by the AIR transformation) to offer an update on where the transition stands and what to expect as AIR reorganizes.

The briefing first notes the benefits of the AIR transformation. These are worth reiterating:

  • Encourage early industry engagement and risk-based monitoring to eliminate later unnecessary FAA involvement
  • Improve consistency and standardization
  • Foster innovation by engaging industry applicants early to understand new concepts and ensure path to compliance
  • Provide agility and adaptability
  • Establish practices for using metrics to determine efficacy

The next step in reorganization implementation will be the first step visible to industry. AIR will begin realigning the organization to shift the existing offices, like ACOs and MIDOs out of the current directorate structure and into alignment with AIR’s functional divisions. For instance, ACOs will all be aligned under the Compliance & Airworthiness Division, while MIDOs will align under the System Oversight Division.  Currently, both ACOs and MIDOs are spread across the Transport Directorate, Small Airplane Directorate, Engine and Propeller Directorate, and Rotorcraft Directorate. This creates significant unnecessary redundancy and confusion, particularly if a company designs and manufactures parts for different categories of products.

After realignment, the Directorate structure will no longer exist.

Because of the nature of the process, existing industry Points of Contact will be retained during realignment to ensure relationships are maintained and contact with appropriate employees is facilitated. This is an important feature because as with every transition there exists the possibility for confusion.

AIR will continue to brief industry on the transition and solicit industry feedback as it progresses. MARPA encourages you to maintain a consistent dialogue with your FAA contacts to let them know about any problems with the transition or implementation that you identify, particularly if it the transition messages don’t seem to be reaching the personnel you deal with regularly. MARPA would also be happy to hear feedback from our members so that we can bring any concerns or positive feedback from you to the FAA. Please feel free to email VP of Government and Industry Affairs Ryan Aggergaard at ryan@washingtonaviation.com if you have feedback on the AIR transformation process.

 

 

Become a Supplier to Embraer

For years MARPA has talked about opportunities that exist for PMA manufacturers willing to look for non-traditional customers.  One of the most under-appreciated possibilities, and one that MARPA President Jason Dickstein has emphasized, is to act as a supplier to OEMs.  OEMs are very often massive companies with a need for quality, reliable suppliers, and many MARPA members are ideally positioned to take advantage of OEM purchasing needs with high quality approved parts on the shelf and ready to ship.

The U.S. Department of Commerce is presenting a program on becoming a supplier to Embraer.  Because many PMA companies are already manufacturing parts for Embraer aircraft, this may be an excellent opportunity to broaden your customer base for your Embraer parts.

The program will begin with a presentation made by Embraer representatives on how to initiate a relationship with Embraer. This presentation will be made by webinar on October 28, 2016. Participation in this introductory webinar is a mandatory part of the program, so if this is something your company may even be remotely interested in, you should plan to register and participate.

Interested companies will then be asked to fill out an online questionnaire from which Embraer engineers will evaluate companies and select suppliers for a second round of webinar discussions with Embraer’s engineering department. Embraer may then invite select companies for a further in-depth interview.

There is no cost to participate in this program, and it presents an opportunity to potentially expand parts sales.  MARPA has often said that OEMs should be thought of as no different than air carriers from a customer perspective: they need parts, and we manufacture and sell great parts.  This could be an excellent opportunity for MARPA members to diversify their customer base.

If this opportunity sounds like something your company may be interested in, you can register for the mandatory introductory webinar at the following link: http://2016.export.gov/california/losangelesdowntown/events/embraer/eg_us_ca_102435.asp.

MARPA Returning to Japan

As part of its ongoing drive to increase the export of U.S.-made PMA parts and increase global knowledge and understanding of PMA, MARPA has in the past few years traveled to Japan to speak with potential customers, government contacts, and manufacturing partners.  MARPA is happy to announce that it will continue these efforts this year at the Japan International Aerospace Exhibition 2016, in Tokyo, Japan, October 12-15.

We have worked closely with long-time MARPA member and MARPA supporter Akira “Jay” Kato of JK Tech Consulting to make valuable contacts in Japan and discuss PMA at a very high level with Japanese customers and government officials. These efforts include both explaining and educating air carriers and their purchasing groups about PMA, as well as, importantly, promoting the use of PMA by discussing the safety, value, and reliability PMA provides.

2015-10-15 MARPA Staff and Tokyo Govt Rep and Jay Kato

From left to right: MARPA volunteer staff Judy Dickstein and Harvey Dickstein, MARPA VP of Government and Industry Affairs Ryan Aggergaard, Tokyo Metropolitan Government Supervisor for Aviation Industry Participation Support Project in Tokyo Chikako Nagase, and Tokyo Metropolitan Government Aviation Industry Participation Support Project Adviser (President, JK Tech Consulting, Inc.) Jay Kato at the MARPA booth at the 2015 Tokyo Aerospace Symposium.

These efforts are one prong of MARPA’s ongoing MDCP efforts supported by the U.S. International Trade Administration.

MARPA hopes to continue to make valuable contacts in the Japanese aviation community, and particularly to make additional inroads on behalf of the PMA industry with customers in Japan.

While MARPA always enthusiastically promotes the benefits of PMA where ever it goes, we would like to be able to provide a more targeted benefit to our members. We would therefore like to offer to our members the opportunity to display your marketing literature in the MARPA booth at the Japan International Aerospace Exhibition.  This will allow us to direct visitors at the MARPA booth to those members who can best serve their needs or might be an ideal partner for future business.

If you would like to have your literature displayed in the MARPA booth this October in Tokyo, please contact Senior MARPA Program Manager Katt Brigham at katt@washingtonaviation.com no later than September 30.

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.