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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 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!

MARPA Air Carrier Committee Seeks Clarification on post-AD PMA Parts

The MARPA Air Carrier Committee, led by Michael Rennick, Delta Air Lines Component Engineering Manager, is hard at work supporting PMA users and MARPA members.  In June, members of the MARPA Air Carrier Committee, including Air Wisconsin, American Airlines, Republic Airways, US Airways, Air Canada, and Delta Air Lines, submitted to the FAA a letter seeking clarification on the issue of PMA parts that are alternates to post modification Airworthiness Directive (AD) related parts.

This clarification is necessary because confusion has sometimes arisen between operators and local regulators over the need for an Alternative Method of Compliance (AMoC) for post-modification AD-related PMA parts.  It is the position of the MARPA Air Carrier Committee that if the PMA is an alternate to an OEM part contained in a post-AD configuration, no such AMoC is required.

When a PMA is issued for a replacement part for a post-modification AD-related OEM part, it is uncommon for the PMA applicant to request an AMoC to the AD, or for the FAA to note the AD on the PMA approval.  This makes some sense because a post-AD PMA part is inherently an alternative method of compliance without being described as one. However, an issue arises because many ADs call out only the modified OEM part as a means of compliance.  Because ADs are technically regulations under Part 39, alternate approvals such as PMAs might not satisfy the regulatory requirement and so an AMoC may be required.

It would be beneficial to both operators and PMA manufacturers to see this change.

The OEM part is the source of the condition giving rise to the AD.  The post-modification part must resolve the condition in order to satisfy the AD. During the PMA approval process for the same part, the AD is also taken into consideration..  In order to receive PMA approval, the subject PMA part must resolve the condition resulting in the AD, just as the post-modification OEM part does.  There should be no need to call out an AMoC for the PMA part related to the AD; the underlying condition that necessitated the AD has changed because the approved PMA part has replaced the post-AD OEM part. The PMA should be a valid terminating action for the AD.

There are limited circumstances in which this reasoning may not apply, but these limited circumstances are not the subject upon which the Air Carrier Committee seeks clarification.  For instance an AMoC may be necessary in a scenario in which an AD applies to a higher level component or assembly. In this scenario the PMA replacement for the OEM part may not address the AD for the higher assembly because it is a replacement at the piece-part level, and thus an AMoC may be necessary for the higher assembly.

Generally, however, an AMoC should be inherent in an approved PMA part and therefore unnecessary as a separate approval.  This is the policy clarification that the Air Carrier Committee seeks in the form of a formal FAA communication.  If an approved PMA part is a replacement for a post-AD OEM part, the FAA’s policy should clearly state that the approved PMA is a terminating action for the AD and that no additional approval or discrete AMoC is required. In the alternative, an AMoC could automatically issue for each post-AD PMA to show compliance.

MARPA greatly appreciates the Air Carrier Committee’s work on this project.  MARPA will be working with the FAA and the Committee to determine whether future ADs will list an approved PMA as a valid terminating action, or whether an automatic AMoC should automatically issue with a PMA to show compliance to the AD, or some other solution is desired.  We will keep our members apprised of these developments.

If you are a MARPA member air carrier and want to get involved with the Air Carrier Committee, please email Katt Brigham at katt@washingtonaviation.com.  If you are not yet a MARPA member but would like to get involved, visit our membership application page.  MARPA membership is free for air carriers!

Edited to clarify that ADs are regulations and identify possible solutions to the issue raised in the Air Carrier Committee’s letter.

Mike Rennick Talks PMA Reliability at Delta Air Lines

Those who attended MARPA’s inaugural European conference last month in Istanbul were treated to an excellent presentation by Delta Air Lines Manager of Component Engineering and MARPA Air Carrier Committee Chairman Mike Rennick on the impressive reliability benefits of PMA parts in Delta’s fleet.

As many know, Delta operates a very diverse fleet of aircraft, which are on average older aircraft than many other carriers’ fleets.  Yet Delta also operates one of the most reliable mainline fleets in the world.  In 2014, Delta had an impressive 169 maintenance cancellation free days; a metric that has improved each of the last three years.  Mr. Rennick pointed out that one of the important contributing factors to this success was the widespread use of PMA parts.

MARPA and its members frequently tout the many benefits PMA provide to operators.  Operators are generally aware of the lower prices offered by PMA parts.  They are also aware that PMA parts may be their only option, or one of very few options, for replacement parts for legacy aircraft. However, operators may not be aware of the significant reliability benefits that PMA parts also provide.

Mr. Rennick explained that in order to maintain its fleet to the level it requires Delta wants options.  Service experience has demonstrated that PMA parts match, and in some cases exceed, the performance of OEM parts.  Based on this experience Delta has found PMA parts to be acceptable for use throughout the aircraft, components, and engines.

Mr. Rennick’s presentation included exciting metrics showing an upward trend in Mean Time Between Unscheduled Removals (MTBUR) and Mean Time Between Failures (MTBF) on certain applications in which Delta had utilized a PMA solution.  Metrics like these indicate the great value proposition that PMA’s can offer air carriers; not only from a purchase price standpoint, but importantly, from a reliability standpoint.  These metrics, along with shortened lead times, are part of the greater holistic value proposition offered by PMA parts and something we should remember to emphasize when talking to potential customers.

Mr. Rennick also stated that because of Delta’s close cooperation with its vendors it is able to address issues more quickly than might otherwise be possible.

Delta’s comfort level born of experience with PMA parts has led to the carrier using PMAs in even very critical applications, including engine gas path and rotating parts, life limited parts, and power generation.

The emphasis on the reliability of PMA parts is one that we, as an industry, should be sure to promote to our customers.  Cost savings means more than just lower prices (an obvious benefit of PMA!)  Keeping aircraft safely and reliably operating without unscheduled removals and increasing time between failures generates cost savings for operators by allowing them to get planes turned quickly and keeping their passengers happy.  MARPA always makes it a point to emphasize the reliability benefits of PMA wherever we go.

If you were unable to join us in Istanbul you will still have a chance to see this great presentation on the reliability benefits of PMA parts.  We anticipate Mr. Rennick giving a similar presentation at the 2015 MARPA Annual Conference.  This will be a great opportunity for PMA manufacturers to hear directly from Delta on the air carrier’s take on PMA parts, and an excellent opportunity for operators to see how one carrier is making PMA parts an important element of their maintenance program success. Register today to take advantage of Early Bird rates!

FAA Seeks Experts to Develop Airframe Crashworthiness and Ditching Standards

Do you want to serve on a FAA working group that will help the FAA shape regulations affecting safety?  Do you have expertise in composite and other nonmetallic airframe materials?  Can you add to a discussion about airframe crashworthiness?

The FAA has asked the Aviation Rulemaking Advisory Committee (ARAC) to provide recommendations regarding airframe-level crashworthiness and ditching standards that would be incorporated into the FAA’s regulations.  TYhe group would also prepare advisory materials.

During the development of current airworthiness standards and regulatory guidance, the FAA assumed that airframe structure for transport airplanes would be constructed predominantly of metal, using skin-stringer-frame architecture. Therefore, current regulatory requirements either do not address all of the issues associated with nonmetallic materials, or have criteria that are based on experience with traditionally-configured large metallic airplanes.

With respect to crashworthiness, there is no airframe-level standard for crashworthiness.  Many of the factors that influence airframe performance under crash conditions on terrain also influence airframe performance under ditching conditions. Past studies and investigations have included recommendations for review of certain regulatory requirements and guidance material to identify opportunities for improving survivability during a ditching event; consideration of these recommendations is included in this tasking.

You can find a full discussion of the working group’s task, online.

If you wish to become a member of the Transport Airplane Crashworthiness and Ditching Working Group, you can express that desire by contacting:

Ian Won
Federal Aviation Administration
1601 Lind Avenue SW.
Renton, WA 98055,
ian.y.won@faa.gov
phone number 425-227-2145
facsimile number 425-227-1232

Please describe your interest in the task and state the expertise you would bring to the working group. The FAA must receive all requests by July 6, 2015. The ARAC and the FAA will review the requests and advise you whether or not your request is approved.  For MARPA members, if you would like MARPA’s endorsement for such a position, please contact us before the deadline.

FAA Publishes Designee Management Policy for Public Comment – All Manufacturers Need to Review and Comment

Do you rely on a Designated Engineering Representative (DER) to approve data for your business? Do you use DMIRs for issuing 8130-3 tags?  If you do, then you know how critical designees can be to the parts approval process.  Often, though, designees are required by the FAA to do things that the FAA employees themselves are not permitted to do, like require paperwork that is not required by law or regulation (this can be a violation of the Paperwork Reduction Act), or impose standards of conduct that are not required by law or regulation (this can be a violation of the Administrative Procedures Act). When this happens, the designee has no choice but to obey the instructions from the FAA-Advisor … even if they would be illegal if undertaken by the FAA’s employees.

Want to make sure that designees are not used to do things that FAA employees can’t do (by law)?  The be sure to take the time to offer comments to the FAA Designee Management Policy that is now out for comment.  The FAA has issued for public comment a draft change to the guidance document affecting designees.  Although only parts are changed, it is a potential opportunity to comment on the entire document.

The original guidance is called “Order 8000.95, Designee Management Policy.” It was first issued in April of 2014.

This guidance document provides a wide variety of guidance on how to manage FAA designees. It has not and does not appear to cancel FAA Order 8100.8 (Designee Management Handbook), although some of the guidance appears to address some of the same issues as that guidance (failure to cancel 8100.8 might have been an oversight).

As a practical matter, designees (who are the people most directly affected by this guidance) will not be able to write comments that are critical to this guidance. This is because designees can be terminated for cause or without cause, at the discretion of the FAA. So the FAA can terminate a designee for exercising his or her First Amendment freedoms (as long as they come up with any other pretext for the action, including a termination ‘not for cause’). Designees are well aware of this and they regularly self-censor their comments because of the chilling effect that the FAA’s discretionary termination power has had. In some cases, designees have contacted me because they know that I will protect their anonymity.

The real-world issue us that designees rely on their designation from the FAA to ply their trade. If they are terminated (for-cause or not-for-cause) then they cannot simply be a designee for someone else. They need to choose a entirely different career path. So the process for reviewing designee termination is very important. And both the current policy and the draft policy are woefully inadequate, because they offer no standards for review, so the FAA employees are able to rubber stamp any termination decision on review. Honest review depends 100% on the personal integrity of the reviewing personnel – and there is no formal training for the employees who act as reviewers in that process (by comparison, state court judges typically attend judicial training).

The FAA’s failure to have effective standards actually undermines the FAA’s own interests. One example arises in the context of designee termination. The lack of effective standards means that individual FAA employees can cause the termination of a designee for any reason, including a reason that would have been considered to be illegal if it was used to terminate an employee, as long as the party who initiates the termination offers a pretextual reason. There is no formal inquiry into such pretext – it is taken at face value – and the VERY short time period for presenting a defense means that it is tough to be effective in assembling a defense: the full appeal including all supporting evidence must be submitted within 15 days – while the designee is given the charges, he or she has no opportunity to review the FAA’s underlying evidence. In comparison, the appeals panel has 45 days to consider the appeal and then another 15 days to notify the designee of their decision for a total of 60 days. We have seen evidence that FAA inspectors will use this period to gather more evidence to refute the defense and bolster the ‘prosecution’ so clearly the FAA is not bound to any sort of deadline for presenting its own case.

There is plenty that could be improved in the designee management process.

This is a great opportunity to help the FAA to better manage the designee community using effective processes that ensure fairness for everyone. MARPA members should strongly consider reviewing and commenting on this draft guidance.

Comments are dues to the FAA by January 7. Please send comments to MARPA, as well, so we can sure that our comments reflect your concerns.

Comments Due: 01/07/2015
How to Comment: Deliver comments by mail or hand to:
Susan Hill
1625 K Street NW
Suite 300
Washington DC, 20006Email comments to: Susan.ctr.hill@faa.gov
Email CommentsFax comments to:
(202) 223-4615, Attn: Susan Hill

UPDATE:

My comment on the cancellation of FAA Order 8100.8 failed to take into account FAA Notice 8000.372.  That Notice directs all AIR manufacturing personnel who oversee designees to stop using Order 8100.8 and being using 8000.95 on a schedule.  The schedule reflects the implementation of the Designee Management System (DMS) in those offices.

Under that schedule, all MIDOs with designee management responsibilities should have transitioned to Order 8000.95 during the summer (of 2014).  So Order 8000.95 will have supplanted 8100.8 for MIDOS (but not necessarily for ACOs and FSDOs).  This means that DMIRs and DAR-Fs have transitioned.  But DERs should still be under 8100.8 until they are formally transitioned (at which time they will fall under the instructions of 8000.95).

Special thanks to William Denihan for pointing this out!

Draft Policy Concerning § 33.83 Engine Surveys Due Next Week

We previously wrote in this space about a new Draft Policy Statement issued by the FAA concerning the vibration surveys and engine surveys required under section 33.83 of the Federal Aviation Regulations.  The draft guidance attempts to more narrowly address the FAA’s concerns about full engine test for type certificate applicants.

MARPA plans to provide comments on this Draft Policy Statement to the FAA and has sent a draft of our comments to the MARPA Technical Committee for review.  If any of our members wish to review our draft comments to provide their feedback we would love to hear from you.  Please email Ryan Aggergaard at ryan@washingtonaviation.com if there are particular issues in the draft statement you believe should be addressed so that we can incorporate our members’ concerns.

MARPA also encourages our members to file their own comments on the Draft Policy Statement.  Comments are due to the FAA by November 21, 2014.  Comments should be emailed to Dorina Mihail at dorina.mihail@faa.gov. Comments can also be mailed to her at:

Federal Aviation Administration
Engine and Propeller Directorate
Standards Staff, ANW-111
12 New England Executive Park
Burlington, MA 01803

MARPA looks forward to your comments.

New Guidance: Casting and Proof of Structure

The FAA has released two new advisory circulars that may affect the PMA community.  Both advisory circulars are issued by the Transport Aircraft Directorate and apply to Part 25 aircraft (and parts thereof).

  • Casting Factors, AC 25.621-1: This AC provides guidance for meeting the requirements of 14 C.F.R. 25.621.
    • This regulation imposes limits and restrictions on casting, and also requires a design approval applicant/holder to have control over the operations of a vendor casting facility.
    • The intention of both the regulation and the AC is to drive greater levels of consistency into casting (or to mitigate inconsistencies).
    • Discusses a means of qualifying a casting process

 

  • Proof of Structure, AC 25.307-1: This AC provides guidance for meeting the requirements of 14 C.F.R. 25.307.
    • This regulation is for the demonstration of compliance for each critical loading condition.
    • The AC provides a list of factors that should be considered in deciding the need for and the extent of testing, including the load levels to be achieved.
    • The AC states that there are four certification approaches to choose from (and provides guidance on each one):
      • Analysis supported by new strength testing of the structure to limit and ultimate load.
      • Analysis validated by previous test evidence and supported with additional limited testing.
      • Analysis supported by previous test evidence.
      • Test only.

We would be interested in hearing from any MARPA member who is affected by one of these new advisory circulars.

FAA Issues Statistical Analysis Guidance – Are You Testing Enough Parts?

The FAA has issued a new advisory circular for statistical analysis.  This AC only applies to engine and APU parts.

The new advisory circular uses statistical analysis to arrive at correct sample sizes.  This sample size formula is introduced for persons who are trying to correlate two populations of parts.  MARPA had pointed out to the FAA that typically a PMA applicant does not correlate two different populations of parts – instead they derive the reasonable tolerances on one population of parts, and then design and produce within those tolerances.  The FAA would like PMA applicants to arrive at their appropriate sample size, test the parts being reverse-engineered, and then produce an equivalent number of pre-PMA parts to test for the same properties (and then correlate the two populations).  This is contrary to current FAA regulatory guidance, which requires the design to be approved and the  requires the production quality system to ensure that parts are all produced within the approved design parameters.  In essence, ACO engineers will now take control of the quality assurance system through the design process.

One of the problems with the AC is that it relied on statistical analysis for clinical trial sample size as the basis for assessing statistical analysis of reverse-engineering sample size.  Clinical trials for pharmaceuticals typically rely on populations of hundreds or even thousands of people.  Trying to test hundreds or thousands of parts in order to reverse-engineer them is simply not realistic.  Furthermore, the degree of part-to-part difference under modern quality assurance systems does not support such large sample sizes.
For those cases where the equations in the advisory circular give a lower number for the appropriate sample size, the FAA has also established minimum sample sizes.  The AC sets some minimum limits for the number of parts that must be tested in order to derive certain values (remember that you need that number of PC parts and also that number of reverse-engineered parts to meet the AC’s requirements):

Minimum Number of Parts to be Sampled

  • For basic material properties that are more dependent on alloy constituency than on part manufacture process – 10 approved parts from three separate lots with at least three parts per lot
  • For properties affected by how the material is processed during part manufacture such as high-cycle fatigue, low-cycle fatigue, creep, tensile strength, crack growth, etc. – 30 approved parts
  • For fatigue testing – at least 25 tested parts that are run until they crack
  • For parts exhibiting complex geometry or complex manufacturing variables, additional specimens may be required
  • For parts considered to have a high degree of criticality, greater sample sizes may be required

No statistical basis is offered for these minimum sample sizes.

The new advisory circular provides guidance for statistical analysis of sample-size despite the fact that no regulation actually requires such a broad-based sample.  The advisory circular appears to potentially change the regulations by increasing the burden on applicants.  To the extent that this is true, it is inappropriate.

Our concern is that despite warnings that this is non-mandatory guidance, this guidance may be used as if it were a regulation, with offices refusing to accept PMA applications that are otherwise valid, but that failed to use this AC as a basis for identifying sample size.

If you find that this AC effectively changes the application obligations imposed on you as a PMA applicant, STC applicant, or other FAA-approval applicant, then please contact MARPA so we can raise this concern with the appropriate personnel at the FAA.

AC 33-10 is known by its full title: Statistical Analysis Considerations for Comparative Test and Analysis Based Compliance Findings for Turbine Engine and Auxiliary Power Unit Replacement, Redesign and Repaired Parts.

Inappropriate Restrictions on the Use and Availability of ICAs

Some of you may be wondering where to find the FAA’s policy memo on design approval holder restrictions on ICA availability.  Older MARPA links to the original position of that guidance are no longer valid because it has been moved.  But it is still available if you know where to look!

Many MARPA members look for this policy memo because it clarifies that anti-competitive language in ICAs (restricting use of PMAs or third party repairs) is unacceptable to the FAA:

While not exhaustive, the FAA finds the following practices of using restrictive language in the ICA or through restrictive access or use agreements unacceptable under the provisions of 14 CFR §21.50(b) and related ICA airworthiness requirements:

1) Requiring the owner/operator to only install DAH-produced or authorized replacement parts, articles, appliances, or materials.
2) Requiring that alterations or repairs must be provided or otherwise authorized by the DAH.
3) Requiring the use of only maintenance providers or other persons authorized by the DAH to implement the ICA.
4) Establishing, or attempting to establish, any restriction on the owner/operator to disclose or provide the ICA to persons authorized by the FAA to implement the ICA.

The guidance has found a permanent home in the FAA Regulatory and Guidance Library.  A copy of that guidance is also available on the MARPA website.

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