One of the many ways MARPA supports the PMA industry is through the issuance of its Continued Operational Safety (COS) system guidance material. In order to continue to improve safety and address industry and regulatory concerns, MARPA regularly revises its COS guidance and makes the revised guidance available to the public.
MARPA recently issued Revision 3 to MARPA’s Guidance Material for a PMA Continued Operational Safety (COS) System for review and comment. The COS guidance is available on the MARPA website under the Government Affairs Continued Operational Safety menu, or by clicking the direct link in this post.
As with any guidance material it is important that we receive comments and feedback from our members to ensure that the revisions to the COS guidance are workable and make sense. We are therefore asking our members and the PMA industry to review the revised COS guidance and provide us with feedback.
Comments are due to MARPA by September 19, 2014. You can submit comments to MARPA by emailing them to Ryan Aggergaard at firstname.lastname@example.org. We look forward to your feedback.
MARPA has released the latest revisions of the MARPA 1100 Standard and MARPA Continued Operation Safety (COS) guidance. These revisions improve both documents.
The MARPA 1100 Standard is a streamlined program for Parts Manufacturer Approval applications. It reflects a standard mechanism for compiling applications for FAA PMAs for non-safety-significant (NSS) aircraft parts. These are parts whose failure would have little or no effect on the continued safe flight and landing of an aircraft.
MARPA continues to work with the FAA to help develop corollary FAA guidance to explain to FAA employees the public safety benefits of the program, and to advise FAA employees on how to handle PMA applications properly prepared under the MARPA 1100 standard. The program will benefit both the FAA and the PMA manufacturing community by allowing the FAA to more quickly approve applications for NSS PMA parts and to focus its limited certification resources on more safety-sensitive issues.
MARPA COS guidance is designed to help PMA manufacturers implement an effective COS program to satisfy the need for PMA holders to be responsible for the continued operational safety of their aircraft parts. The MARPA COS program uses three philosophies — problem prevention, part monitoring, and problem response — to support operational safety of a manufactured part.
Visit the MARPA website at http://www.pmaparts.org to learn more about the MARPA 1100 program for NSS parts, and the MARPA COS Guidance.
The Modification and Replacement Parts Association (MARPA) is proud to announce that the 2010 MARPA Conference will feature a special workshop on practical implementation of Safety Management, as well as general session presentations on Safety Management Systems (SMS).
Earlier this month, the President signed into law the Airline Safety and FAA Extension Act. A key element of this new law is a requirement for the FAA to publish a new law requiring Safety Management Systems (SMS) by 2012.
A Safety Management System (SMS) is the formal process of using System Safety practices in an organization’s everyday activities to control risk. It is like a quality assurance system that uses risk-based analysis to looks forward, predicts future needs, and permits a company to commit resources today to address the industry’s future safety needs. SMS is an approach that can be used throughout the aviation industry to meet System Safety standards set by the International Civil Aviation Organization (ICAO).
This year’s MARPA Conference will feature several speakers addressing SMS concepts and implementation mechanisms. As a special bonus, though, John Hunter (Chairman of the MARPA Continued Operational Safety (COS) Committee) will present a workshop that will analyze case studies of how companies have used the MARPA COS standard to establish a SMS with positive safety benefits.
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 . In addition to the Annual Conference focus on SMS, MARPA also serves on the FAA’s Aviation Rulemaking Committee for SMS and has published a COS standard that is available for free to any PMA company.
MARPA President Jason Dickstein met with Roger Simon (EASA Design Organization Manager) and Jan Novak (EASA Rulemaking Officer – Initial Airworthiness Product Safety Department) for a candid discussion about where Europe is going in terms of supporting an aftermarket aircraft parts industry.
It should go without saying that EASA is quite concerned about maintaining the integrity of their system, and maintaining their high airworthiness standards. Against this framework, EASA would like to encourage the development of a vigorous aftermarket aircraft parts manufacturing industry (similar to the PMA industry in the United States).
The EASA team explained that EASA had previously looked at the idea of a separate rule for manufactyring aftermarket parts, like the separate PMA rule in the US FAA regulations. The proposal would have envisioned two separate approvals: a parts design approval and a parts production approval. This idea has been abandoned in favor of working within the existing regulatory framework.
EASA has always taken the position that it is possible to produce independent aftermarket parts under the existing EASA regulations that are used for producing aircraft and engines. The problem has come with an interpretation that appears to require recertification of the entire product (aircraft), including systems and airworthiness elements that could not reasonably have been affected by the aftermarket part.
EASA has expressed interest in developing guidance that would permit parts manufacturers to limit their airworthiness showings to a more reasonable set of items of proof (limited to those airworthiness regulations likely to be affected by the part in question). The guidance would interpret the existing regulations.
One of the issues we discussed with EASA was over Continued Operational Safety (COS). They seemed impressed with the association’s COS efforts, and with the fact that COS lays a foundation for copmanies to eventually implement effective Safety Management Systems (SMS). We are hoping that EASA will adopt similar COS standards for the aftermarket manufacturing community.
Another concern raised by EASA during the meeting was over intellectual property. EASA asked about the persistent OEM concern over misuse of data and the aviation authority’s role in policing intellectual property infringements. It was a wonderful opportunity, as it allowed MARPA to discuss some of the limits of intellectual property law, and to debunk some of the myths about “proprietary information.” We had a very productive discussion with EASA, and we are looking forward to continuing our discussions!
The FAA has put out a call for comments on the Safety Management Systems rulemaking. This request was issued in the form of an ANPRM – Advance Notice of Proposed Rule Making – in the Federal Register.
MARPA has been working on the SMS project and is represented on the SMS Aviation Rulemaking Committee (ARC).
For those unfamiliar with Safety Management Systems (or “SMS”), we wrote about it in this blog earlier this year, but here is a short summary:
A Safety Management System (SMS) is the formal process of using System Safety practices in an organization’s everyday activities to control risk. It is like a quality assurance system that uses risk-based analysis to looks forward, predict future needs, and permit a company to commit resources today to address the future safety needs. SMS is an approach that can be used throughout the aviation industry to meet System Safety standards set by the International Civil Aviation Organization (ICAO). ICAO has asked states to implement SMS programs and State Safety Programs (State Safety Programs are risk-based analysis programs for national aviation authorities to use to better manage safety with the often-limited resources available to the NAAs).
ICAO has published significant guidance on implementing SMS programs; so much guidance, though, that it must be reduced significantly to a level that will permit the publication of implementing reguations. In order to help the FAA make sense of what is necessary – and what is not necessary – within a SMS program, the FAA has issued the ANPRM in order to ask for industy’s opinions about some of the core elements of SMS. A primary focus of this ANPRM is on collecting data about existing SMS programs, but it would also be important for companies to share information about non-SMS programs that meet the same objectives as SMS programs.
Many MARPA members have implemented Continued Operational Safety (COS) programs that permit safety data collection and risk-based analysis of that data. COS has always been viewed as providing the infrastructure to support a SMS program – so MARPA member data and information about their implementation of COS programs would be very useful to the FAA.
MARPA members with comments to share about SMS should also forward copies of their comments to MARPA headquarters so we can be sure that your comments and concerns are also addressed in MARPA’s own comments on the SMS rulemaking project.
The Economist has published a thought-provoking article on the Success that Rolls Royce has realized in recent years. The focus of the article is on the successful marriage of manufacturing and service through the Rolls Royce power-by-the-hour program. In addition to the fact that service has served as a significant source of revenue for Rolls Royce, it has also fanned the popularity of their engines.
PMA companies can take a lesson from Rolls Royce’s success. By providing excellent support to customers, they create a revenue stream and also solidify their manufacturing niche. Many PMA companies have either diversified into service realms, or even started in those realms (for example, many PMA companies got their start as repair stations that recognized a need for replacement parts).
In the PMA world, MARPA has published Continued Operational Safety Guidelines that are meant to assist a PMA company in developing a system that will help support customers’ long-term safety needs. These guidelines mirror the FAA’s COS guidance in FAA Order 8110.42C. PMA Companies looking for a blueprint for developing a support program would do well to look at these sources for guidance.
The article can be found online at http://www.economist.com/business/displaystory.cfm?story_id=12887368