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Visit MARPA at Booth 507 for ACPC 2015!

IMG_20150830_140922MARPA is in Booth 507 at the ACPC 2015 event!  Stop by to say hello if you’re attending the Aviation Networking Forum.

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.

Don’t Forget To Book Your Rooms for the 2015 MARPA Conference!

The 2015 MARPA Annual Conference is just a couple of months away!  Don’t forget to register for the Conference and to book your room at the Renaissance Las Vegas Hotel.  Rooms can sell out quickly, so it’s important to make sure you have yours reserved!

The 2015 MARPA Conference will be held from October 28-29, 2015 and will feature workshops, networking opportunities, and information sessions that benefit all aspects of the FAA-PMA industry!  For more information about the Conference, please click here or visit MARPA at http://www.PMAparts.org!  We hope to see you in Las Vegas!

ICA Guidance Now Open For Comment!

The FAA has released for comment two guidance documents pertaining to Instructions for Continued Airworthiness (ICA): Draft FAA Order 8110.54B and Draft Advisory Circular 20-ICA. As many readers of the blog know, MARPA has done, and continues to do, a significant amount of work to ensure that ICA are available and accurate in accordance with the Federal Aviation Regulations.

Draft Order 8110.54B is guidance directed at FAA personnel and persons responsible for administering the requirements for ICA.  Among other changes, the draft reorganizes the Order to reflect material moved to AC 20-ICA (below), and importantly incorporates guidance implementing the FAA’s Policy Statement PS-AIR-21.50.01, Type Design Approval Holder Inappropriate Restrictions on the Use and Availability of Instructions for Continued Airworthiness.  MARPA and the PMA industry were closely involved with, and supportive of the FAA in, the adoption that Policy Statement intended to protect the industry from anti-competitive ICA restrictions.

Draft AC 20-ICA is a new Advisory Circular that removes industry-specific guidance from the internal FAA Order and places it in a stand-alone AC.  This effort is similar to the FAA’s actions in revising Order 8110.42D – Parts Manufacturer Approval Procedures and developing the new AC 21.303-4 – Application For Parts Manufacturer Approval Via Tests and Computations Or Identicality.  Like Draft Order 8110.54B, the draft AC implements the FAA policy on ICA established in the Policy Statement.  The proposed AC provides guidance to design approval holders (DAH) and design approval applicants for developing and distributing ICA.

After a preliminary review these documents appear to offer very positive guidance for the PMA and aviation maintenance industries, and appear in line with the policy positions for which MARPA has advocated for many years.  MARPA will be reviewing both of these documents closely and offering comments and support for these policies to the FAA.  We encourage the PMA industry to review both documents as well.

Comments on both guidance documents must be submitted by October 6, 2015, and may be submitted to the FAA via email to 9-AVS-ICA@faa.gov.  If you have comments or observations that you feel MARPA should include in its comments to the FAA, email them to Ryan Aggergaard at ryan@washingtonaviation.com so the we can include them.

Delta TechOps Vice President of Engineering, Quality and Planning David Garrison to Keynote at MARPA Conference

David Garrison, Delta TechOps

David Garrison, Delta TechOps

The Modification and Replacement Parts Association (MARPA) is proud to announce that David Garrison of Delta TechOps will serve as a keynote speaker for the 2014 MARPA Conference.

The Modification and Replacement Parts Association (MARPA) is proud to announce that David Garrison, Vice President of Engineering, Quality and Planning at Delta TechOps will serve as keynote speaker for the 2015 MARPA Conference. The MARPA Conference is the Annual Conference for the FAA-approved aircraft parts manufacturing industry. It offers aerospace manufacturing industry professionals an opportunity to meet with customers and also to learn about the latest developments in safety management. In 2015, the Conference will take place October 28-29 in Las Vegas, Nevada, USA.

In Mr. Garrison’s role as Vice President – Engineering, Quality and Planning, he is responsible for Delta’s engineering and technical services, reliability and maintenance programs, inspection, quality assurance and maintenance planning.  Mr. Garrison has been with Delta TechOps for more than 23 years, beginning as a Propulsion Engineer and increasing in title and responsibility during his career, including experience in leadership roles for varied departments  including leading Engine and Component Maintenance, Engineering and most recently the Materials, Planning and Logistics organizations.

Delta TechOps is a division of Delta Air Lines. Over 9,600 Technical Operations employees system-wide provide full-service aviation maintenance  to Delta and service its fleet of more than 750 aircraft. In addition, they provide complete maintenance for more than 150 other operators.

Delta TechOps is proud to offer their customers the same operational expertise, quality, and service that enables Delta Air Lines to enjoy industry leading aircraft and engine reliability at low operating costs.  As a full-service MRO , Delta TechOps can provide comprehensive services including technical training, engineering support, line maintenance services, inventory management, component support, engine overhaul, and engine condition monitoring to keep your fleet flying. And when you are in need of emergency services, Delta TechOps can dispatch their quick-response Disabled Aircraft Recovery Team (D.A.R.T.) to get you back in the air.

Delta Air Lines is one of many air carriers attending the MARPA Conference.The MARPA Annual Conference will take place October 28-29, 2015 at the Renaissance Las Vegas Hotel. More Conference information is available online at: www.pmaparts.org/annualconference.

You asked, MARPA Listened – PMA Trade Mission to Visit China in October!

MARPA is organizing the first-ever PMA Trade Mission to China (Guangzhou, Shanghai and Beijing) in response to your feedback!  The Trade Mission will occur from November 9-13, 2015.

The purpose of this trade mission is to introduce air carriers and MROs in 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, since MARPA already knows you can sell FAA PMA parts in China!

The mission will begin for MARPA Guangzhou, November 9th.  Then we will spend November 10th – 11th in Shanghai and November 12th – 13th in Beijing meeting with air carrier and MRO sales targets.  These meetings are arranged in conjunction with the Department of Commerce International Trade Administration office, and will offer Gold-Key Services in each location.  This means that they will work to assure that your customers are eager to meet with you, translation service is available at each meeting, and each company will have the opportunity to expose customers to your products and services.

WHAT IS COVERED BY THE $3500 REGISTRATION FEE?

  • Commercial Service and Export Assistance Center’s Gold Key Services in all three cities
  • Translator/Interpreter services in-country during each meeting
  • Printing and/or shipping of member company’s promotional materials within a “mission guide book” provided to customers
  • Ground transportation from the MARPA hotel to each meeting
  • Pre-arranged meetings with vetted customers and companies in each city of the Mission*

*MARPA is currently working with U.S. Commercial Service to confirm meetings with targeted carriers and customers chosen through feedback from MARPA members.  These meetings are subject to change.

Guangzhou – China Southern Airlines, GAMECO.  Shanghai – China Eastern Airlines, China Cargo Airlines, Yangtze River Express.  Beijing – CAAC, Air China/Air China Cargo, China United Airlines, AMECO Beijing, and Tianjin Airlines. 

WHAT ARE MEMBERS RESPONSIBLE FOR?

  • Air transportation to the starting point of the Mission and from the ending point of the Mission to their final destination
  • Air and ground transportation between Mission cities unless otherwise noted
  • Personal hotel accommodations
  • Meals and incidentals (except any covered under Gold Key Services
  • Visa services and fees in order to meet travel requirements
  • Any additional incidental costs or expenses

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 China, 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!

Registrations are available for MARPA members on a first-come-first-served basis until the extremely limited slots of this program is full.  Since a number of members have expressed interest, we expect the mission to be filled quickly!

Have you made your decision?  Would you like to register today?  Click here for a registration form to return to MARPA: 2015 China Trade Mission Registration Form

If you would like more information, then please contact the Association.  We’d love to hear from you.  Call or email Katt Brigham at 202.628.6777 or katt@washingtonaviation.com.

MARPA Conference Air Carrier Workshop To Offer Insight To A Carrier’s Processes

The Modification and Replacement Parts Association (MARPA) is proud to announce that Copa Airlines’ Erick Yep will helm a special workshop presented by Air Carriers Copa Airlines, Delta Air Lines, and others at the 2015 MARPA Conference.  Yep serves as Technical Purchasing Coordinator in the Technical Operations department of Copa Airlines.

His Workshop will answer many of the questions that the industry has raised about how Air Carriers use PMA and what their internal processes may be.  Erick, Delta Air Lines’ David Linebaugh and Jennifer Tuggle will present:

  • Airline Involvement When Developing PMA Products
  • How To Proactively Look Internally for Potential PMA Candidates

Be sure to attend the Conference to take advantage of this opportunity to see inside the workings of the Air Carrier’s processes.

MARPA is the non-profit trade association that represents the aircraft parts manufacturing industry (PMA parts manufacturers).  MARPA works closely with the FAA to help develop safety standards and tools that enable manufacturers to meet those safety standards .  The MARPA Annual Conference will take place October 28-29, 2015 at the Law Vegas Renaissance Hotel.  More conference information is available online.

Announcing the MOU Between the Korea Trade-Investment Promotion Agency (KOTRA) and Modification And Replacement Parts Association (MARPA)

WASHINGTON, DC – MARPA is pleased to announce the signing of a Memorandum of Understanding (MOU) between the Korea Trade-Investment Promotion Agency (KOTRA), Korea’s national trade promotion organization,  and Modification And Replacement Parts Association (MARPA), the non-profit trade association that represents the Parts Manufacturer Approval (PMA) community.

Signed on June 15 by MARPA President Jason Dickstein and KOTRA Executive Vice President Wonsok Yun at a business and technology cooperation conference in Washington, DC, the MOU encourages collaboration between our two organizations to promote success and safety that will benefit both the US PMA community and Korean aerospace companies.  This event was attended with the support of the International Trade Administration, as a part of a three year Department of Commerce grant to increase the export of PMA parts.

MOU

From left, Ryan Aggergaard (MARPA Associate), Fred Elliot (ITA), Jason Dickstein (MARPA President), Wonsok Yun (KOTRA Executive VP),  Tae – Sik Lee (KOTRA North American General Manager), Jongchoon Kim (KOTRA Director General,Washington DC)

KOTRA is Korea’s national trade promotion organization. It serves as a bridge between Korean companies and potential partners overseas, including the U.S., through matching companies that would be the most appropriate and mutually beneficial business partner. It also organizes and hosts international exhibitions and cyber business centers designed to connect Korean companies with overseas markets and suppliers. KOTRA has eight offices nationwide, including near MARPA headquarters in Washington.

As part of this MOU, MARPA anticipates the opportunity to meet with Korean MROs and Air Carriers, as well as parts manufacturers, in order to provide information regarding the FAA PMA parts program, regulations, and quality standards in order to encourage safety and expanded trade between Korea and the US.  Worldwide press published articles like this Korean trade article, announcing the agreement.

Future updates will be posted on this blog regarding an upcoming event in Seoul that will offer an opportunity for MARPA members to provide information to customers in this expanding market!

Yes, You CAN Sell FAA-PMA Parts into China!

Yes, China accepts FAA-PMA parts.

The United States and China signed a Bilateral Airworthiness Agreement (BAA) in 1991.  That agreement recognized that each authority (FAA and CAAC) had a system for production and airworthiness approval of civil aeronautical products, and that each system was sufficiently equivalent to the other to permit the authorities to accept certain approval decisions of the other.

The BAA is implemented through a Schedule of Implementation Procedures.  This schedule explains how international aerospace transactions will work.  It is meant to facilitate certain transactions and relationships.
The schedule covers, inter alia, Chinese acceptance of FAA Export Certificates of Airworthiness appliances, parts, and materials for which the FAA is the exporting authority.  The schedule explains that China will accept US export certificates of airworthiness for parts and materials when the FAA certifies that each article:

(a) Conforms to approved design data;
(b) Is properly marked; and
(c) Meets the special requirements of the importing country.

This is typically done through the issue of an FAA 8130-3 tag.

The special import requirements of China must be formally presented to the United States, and then the United States publishes those special import requirements in Advisory Circular (AC) 21-2.  The Chinese special import requirements apply to airframes, engines, propellers, and TSOA articles, but the only special import requirement that applies to FAA-PMA parts is that the part must be accompanied by an 8130-3 tag.  Since the 8130-3 tag is the medium for communicating the compliance, the 8130-3 for a FAA-PMA part can be safely annotated as meeting the special import requirements of China.

The Chinese have clarified in several places that they really mean it when they say that they are accepting PMA parts.

In order to ensure that there is no confusion, appendix D of the Schedule of Implementation Procedures specifies that the term ‘part’ means replacement and modification parts manufactured under any FAA production approval.  The appendix goes on to say that this includes replacement and modification parts manufactured by an FAA-PMA holder!

Some additional provisions are listed in the Schedule of Implementation Procedures , but none of them actually impose any additional obligations on someone who exports a PMA part to China, so long as that part already complies with US regulatory standards.

  • Critical components must have a part number and a serial number (this is already required under FAA Part 45 for FAA-PMA parts); and
  • All PMA parts must be marked with the part number and the manufacturer’s name or trademark (this is also required of all PMA parts under FAA Part 45 marking requirements).

China has also published their own advisory circular on the acceptance of FAA-PMA parts.  The advisory circular clarifies that FAA-PMA parts are acceptable for use on Chinese aircraft and reiterates that the parts should marked according to the requirements of FAA Part 45.

MARPA and Other Trade Associations Fight to Prevent FAA From Being Assigned Needless Tasks

Some of you may have heard that there is legislative language that would force the FAA to promulgate unnecessary regulations related to marking of “influencing parts.”  These would be defined as parts that can affect an engine LLP; there is no further refinement that would limit the scope of the term “affect.”

The proposed legislation would require the FAA  to issue regulations for marking these “influencing parts.” Ordinarily, you mark a part because the part marking is perceived to be useful; but it appears that the proposed markings would not be used for anything.  No guidance for what should be marked on new parts is indicated, so one cannot even guess at the purpose that such markings might achieve.

Under the proposal, the FAA would also be required to issue regulations for “post repair marking or identification on an influencing part [to reflect] the drawings and specifications used to gain the repair design approval issued by the Federal Aviation Administration.” What is wrong with this picture:

  • Remember that the description of the work performed is required to be on the approval for return to service and is typically included in the work order as well, so this marking requirement is generally redundant.
  • The FAA has no uniform identification system for drawings and specifications, and drawings and specifications are typically proprietary, so the reference would also be meaningless to third parties in many cases, thus the specific requirment provides no value.
  • Given the fact that hot section parts generally will lose markings due to the conditions inside the engine it appears that this requirement is not calculated to achieve anything useful for such parts.
  • Finally, marking engine parts in a way that will not be rapidly eradicated may require physical marking (like vibra-peening); such marking practices need to be researched for individual parts because of the possibility that they may undermine the strength or integrity of the part (thus wasting resources better spent on protecting safety).  So such marking requirements may actually undermine the safety of aircraft engines!

Perhaps the most important issue here is that anything that seemed good about this proposal already exists in FAA regulations and/or guidance.  The FAA has been diligent on the issues surrounding this proposal, and legislation is not needed.  Legislation of this sort would only serve to divert important FAA resources away from issues that really do affect safety.

Several trade associations have banded together to write Congress about the impracticality of this proposal.  The letter is being transmitted to Congress today.

Special thanks go out to Daniel Fisher, the Vice President of Legislative Affairs for ARSA, who alerted us to this legislative issue and who led the effort to send a letter to Capitol Hill on this issue.

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