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:
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.
MARPA is in Singapore this week for MRO Asia-Pacific promoting all things PMA. The first day of the MRO conference agenda dedicated substantial discussion (as they usually do) to market forecast and trends. Some of these trends could be an opportunity for PMA manufacturers, but others could mean significant challenges down the road if companies are unable to adapt.
The opening session presented a discussion of trends in supply chain logistics. One of the largest takeaways was the change in inventory management practices, especially in the Asia Pacific region, from a just-in-case model, to a just-in-time (JIT) model. This follows the trend in many other industries, including manufacturing and retail, which enable businesses to reduce costs by carrying less inventory.
PMA manufacturers are in an excellent position to benefit those customers shifting to a JIT model because PMA parts can help customers defray the costs associated with warehousing and inventory management, which is outside of the customers’ core competency. This applies to both operators and MRO facilities. This is because PMAers have the parts on the shelf ready to go, eliminating the need for users to maintain parts inventories themselves to ensure availability.
But the shift to a JIT model also presents certain challenges in Asia Pacific, particularly for AOG situations or other scenarios demanding quick turn times. In certain markets with well-established MRO markets, like Japan and Singapore, getting parts to the customer is often a fairly straight-forward exercise and can be done overnight from the United States. However, in less-developed markets and countries in the region, import and customs requirements can pose significant barriers, meaning delays of several days in clearing the shipment and getting the part to the customer. Those companies able to most efficiently navigate those challenges will be at a competitive advantage.
Another trend in Asia Pacific is the MRO spend focused on the narrow body fleet–namely the 737 and A320 families. The narrow bodies currently account for approximately 70% of the MRO spend in the region (and are the two largest fleets by type). This trend should continue over the next decade for two reasons: (1) a significant number of these aircraft have been delivered over the last decade (and continue to be delivered); and (2) the commonalities that exist between the current gen aircraft and the Max and neo versions of the aircraft.
Finally, an emerging trend that should be of great concern to PMA manufacturers is the shift by component and airframe OEMs toward power-by-the-hour agreements. The PMA industry has already seen the problems that are caused when OEMs use PbH agreements as engine OEMs have taken significant steps to lock up the engine spares market. Although the percentage of PbH agreements in component and airframe is still small, it is growing. PMA manufacturers need to get out in front of this trend and remind their customers that they are a) not obliged to sign such agreements and b) demonstrate the value of PMA in terms of cost, reliability, and customer service offered by PMA. It can also benefit smaller PMA companies to form partnerships with other manufacturers of complimentary product lines to offer greater benefits to customers.
MARPA will work to stay on top of these trends. We welcome any information or questions our members have that can help MARPA continue to craft its strategy.
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.
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.
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:
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.
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.
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, 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.
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.
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.
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!
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 email@example.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.
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!
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).
We would be interested in hearing from any MARPA member who is affected by one of these new advisory circulars.