Bob Cook from the FAA will be retiring after this week. You may not know the name but you certainly know his work.
He has been involved in a tremendous amount of rulemaking and policy making efforts at the FAA. The one that sticks in my mind is 14 C.F.R. 21.137. Bob was part of the team tasked with coming up with a modern vision of quality assurance. It would have been very easy to create a subjective rule that was vague and made compliance difficult; instead, 14 C.F.R. 21.137 very clearly establishes objective criteria expected in a modern quality assurance system.
How did 14 C.F.R. 21.137 come into being? Bob once told me that they put together a wish list of quality system elements, and then he led a chopping block exercise in which they asked for each element (1) what safety value does it provide and (2) does the FAA really need to regulate this element? This exercise allowed them to remove many elements that were nice to have, but that were not necessary and therefore did not need to be part of the regulation. The result was a quality assurance regulation that serves as a model for the entire global industry. It is the sort of regulation that no one complains about – no one thinks it is overbearing and no one thinks it falls short of what it should address. That is a rare sort of regulation, indeed. This was the sort of reasonable approach to regulation that we always expected from Bob Cook.
Bob sent an email announcing his retirement. It read (in part):
To all those that I have worked with over this last 17 years in the FAA and 40+ in the aviation industry:
I will be retiring on June 23rd. I wish to thank each of you for helping to make my time at the FAA both enjoyable and rewarding. I have stated many times that this has been the best job I ever had, and I truly meant it. The managers and the management team I worked for (while being frustrating at times) provided me with every opportunity to learn and progress within the organization.
To those that I had the pleasure of working with on aviation issues I want to thank you for all the time, effort and concern you placed on the continuous improvement of quality within our industry. Your openness to share quality improvements and working, as an industry, through organizations such as the IAQG, AAQG, AIA, GAMA, and MARPA to establish quality standards and a quality system oversight processes that are used internationally, is one of the greatest achievements of which I had the pleasure to be involved.
* * *
After 40+ years of working in the aviation industry I expect it will be hard for me to just walk away so you may see me commenting on rulemaking as a concerned citizen. If you do, I hope to see a better response than “Thank you for your interest in aviation safety”. I will miss working with you on issues that makes our aviation industry the safest and most respected in the world.
* * *
Very Soon to be a Private Citizen
We will miss his attention to detail, his willingness to listen, and his commitment to safety.
If anyone wants to send Bob a thank-you or goodbye message, then he is still in the office this week, and his email is Robert.email@example.com.
MARPA is extremely pleased to announce that Peter Requa, Senior Director of Supply Chain Management-Technical Operations for Southwest Airlines, will serve as the Keynote Speaker for the 2017 MARPA Annual Conference in Orlando, Florida from October 25th -26th at the B Resort & Spa.
Peter has responsibility for Strategic Sourcing teams for purchase of maintenance materials and overhaul services for engines, component and airframe. He is also responsible for Material Planning, Technical Purchasing, Repair Administration, and Inventory Management in support of Southwest’s 700+ aircraft.
Peter began his career with United Airlines in 1988 at the San Francisco Maintenance Operations Center where he last held the position of Manager-Capital Planning. In 1998 he joined Reno Air, and following the acquisition by American Airlines in 2000, joined AirTran Airways as Director of Operations Administration overseeing Material Planning, Operations Financial Planning, Stores, Repair Administration, and Ground Support Equipment Maintenance. Following the acquisition of AirTran airways he made the transition to Southwest Airlines in 2011.
In its 46th year of service, Dallas-based Southwest Airlines continues to differentiate itself from other air carriers with exemplary Customer Service delivered by more than 54,000 Employees to more than 100 million Customers annually. Southwest proudly operates a network of 101 destinations in the United States and nine additional countries with more than 3,900 departures a day during peak travel season.
Southwest Airlines is the world’s largest operator of the Boeing 737, was the launch customer of the 737-300, 737-500, and -700, and will be the launch customer of the 737 MAX 7.
Southwest Airlines is one of many air carriers attending the MARPA Conference. The 2017 MARPA Annual Conference provides an excellent opportunity for our members to meet and network with their customers. It is also an opportunity to continue the ongoing discussion about the benefits and value of PMA parts. More Conference information is available online here.
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
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.
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!
The 3rd Annual MARPA EMEA Conference, this year being held in Dublin, Ireland, is less than two weeks away. The event, scheduled May 8-9, with a special tour of MRO Dublin Aerospace’s facility May 10*, will be a great opportunity to meet air carriers, MROs, suppliers, and government officials, that you don’t see at other conferences, including the MARPA domestic conference.
Even now we are still adding air carrier attendees, including two new additions just this week that we know our members will want to speak with. We typically see air carriers register even up to the day of the conference, so we don’t want you to miss out on an opportunity to develop a relationship with a new potential customer. You can find an updated list of conference attendees here.
We will also have as a part of the conference agenda a Panel Discussion on how PMA improves safety and reliability, moderated by MARPA board member Josh Krotec, from First Aviation Services. This panel will offer the panelists a great chance to provide real-world examples of how they have worked with customers to use PMA to solve problems for air carriers. Due to a scheduling conflict, there is still one slot available for an interested conference attendee to participate on this panel! If you would like to have the opportunity to sit on this panel and provide testimonials about your company’s successes in front of your current and potential customers, please reach out to MARPA Program Manager Katt Brigham at Katt@washingtonaviation.com for details.
We look forward to seeing you all in Dublin!
*Please RSVP to Katt if you would like to participate in the Dublin Aerospace facility tour.
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:
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.
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.
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 firstname.lastname@example.org. There are a limited number of subsidies available, so apply ASAP!
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).
Don’t forget to register today for the 2017 MARPA EMEA Conference! The Early Bird discount expires tomorrow, so register before April 1st to save!
The 2017 MARPA EMEA Conference has a lot of opportunities to offer! Join Keynote speaker Fergus Wilson, Chief Technical Officer for Aer Lingus, and Brian Gialloreto, Manager of Component Engineering at Delta Air Lines to hear how their carriers use PMA to increase savings and reliability. Learn about the newest developments in international PMA markets like Japan, Latin America, and Europe. Dive into manufacturer’s success stories and learn ways to energize your company. Find the financial strategy you need to guide your company through the PMA landscape. The Conference Agenda is packed with speakers you want to see, and with networking opportunities! Your customers and regulators will be there… will you?
To register, just click here for a registration form or to register online. If you have any questions, contact MARPA by calling (202) 628-6777. We look forward to seeing you in Dublin!
The FAA has proposed a set of special conditions that would apply to a set of certification projects involving an inflatable restraint system with non-rechargeable lithium batteries. These special conditions could have far-reaching effect that goes beyond the STC projects for which they are intended.
The special conditions would apply to the aircraft listed on the approved model list in an AmSafe STC. The proposal does not list those aircraft – and as the AmSafe STC is not available to the general public, the list is a ‘secret’ list. This could make specific application of the special condition tricky to identify. This is concerning because special conditions become part of the type certificate basis, so konwing hich aircraft are potentially affected would be important.
It is possible that anyone attempting to obtain PMA for articles on those aircraft that are affected by the AmSafe STC (or by the non-rechargeable lithium batteries special conditions) would also be expected to comply with the special conditions. Therefore anyone with an interest in battery PMAs or seat PMAs/TSOAs ought to examine this proposal to establish whether it could affect their business – now or in the future.
The FAA proposed the following special conditions for Non-Rechargeable Lithium Battery Installations, which would take the place of the current storage battery standards under the regulations:
In lieu of Sec. 25.1353(b)(1) through (4) at Amendment 25-123, each non-rechargeable lithium battery installation must:
1. Be designed to maintain safe cell temperatures and pressures under all foreseeable operating conditions to prevent fire and explosion.
2. Be designed to prevent the occurrence of self-sustaining, uncontrollable increases in temperature or pressure.
3. Not emit explosive or toxic gases, either in normal operation or as a result of its failure, that may accumulate in hazardous quantities within the airplane.
4. Meet the requirements of Sec. 25.863.
5. Not damage surrounding structure or adjacent systems, equipment, or electrical wiring from corrosive fluids or gases that may escape in such a way as to cause a major or more severe failure condition.
6. Have provisions to prevent any hazardous effect on airplane structure or systems caused by the maximum amount of heat it can generate due to any failure of it or its individual cells.
7. Have a failure sensing and warning system to alert the flightcrew if its failure affects safe operation of the airplane.
8. Have a means for the flightcrew or maintenance personnel to determine the battery charge state if the battery’s function is required for safe operation of the airplane.
Note: A battery system consists of the battery and any protective, monitoring, and alerting circuitry or hardware inside or outside of the battery. It also includes vents (where necessary) and packaging. For the purpose of these special conditions, a “battery” and “battery system” are referred to as a battery.
The discussion associated with the proposed special conditions states that the special conditions are “necessary to establish a level of safety equivalent to that established by the existing airworthiness standards.” Because of their special application to non-rechargeable lithium battery installations, it is possible that this could serve as the model for a regulation that applies to non-rechargeable lithium batteries.
MARPA is very excited to announce that Dublin Aerospace has agreed to host a tour for attendees of the MARPA EMEA Conference on the morning of May 10, 2017. The MARPA EMEA Conference itself is scheduled for May 8-9 at the Dublin Hilton Kilmainham in Dublin, Ireland. This is the third year that MARPA has put on a European conference, and it will be a great opportunity to meet and network with customers you may not get a chance to see at the MARPA Annual Conference in Orlando, as well as hear the latest information and developments from the PMA world.
Dublin Aerospace is based at Dublin International Airport, and is equipped to perform work on aircraft, APUs, and landing gear. Dublin Aerospace’s primary focus is on the Airbus A320 family and the A330 aircraft, as well as the Boeing 737NG and Classic aircraft. Their APU repair shop focuses on most Boeing and Airbus APUs, and the landing gear facility performs work on both the A320 family and the Boeing 737 family landing gear. Dublin Aerospace has the capacity to process 70 aircraft, 400 APUs, and 250 landing gear annually.*
Last year in Madrid, about a dozen attendees had the opportunity to tour the Iberia Maintenance facility the morning after the conference. The site visit was viewed as a highlight of the event by those who participated, and it was generally agreed that there was great information and ideas to be taken away from the tour. Many participants suggested MARPA hold a similar event this year, and we are pleased to partner with Dublin Aerospace to bring our conference attendees this opportunity.
Don’t miss out on a great chance to meet with your current and potential new customers, and to take a tour of a leading MRO facility. Register for the 2017 MARPA EMEA Conference in Dublin today, and we look forward to seeing you in there!
For more information about Dublin Aerospace, visit: http://dublinaerospace.com/
For more information about the MARPA EMEA Conference, visit: http://www.pmaparts.org/EMEAconference/about.shtml
Questions? Email MARPA Senior Program Manager Katt Brigham at email@example.com.
*Credit: Dublin Aerospace at http://dublinaerospace.com/grid-12/.