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 email@example.com so the we can include them.
Do you have a topic for the MARPA Technical Committee’s next meeting? We are now collecting items for the agenda for the October meeting!
The MARPA Technical Committee addresses technical issues facing the industry. The Committee review proposed FAA Publications (like advisory circulars and orders) and offer technical advice to improve those proposals. Technical Committee members meet with the FAA to discuss policy issues. Technical Committee members also sit on FAA Advisory Committees and Working Groups in order to develop policy that affects the PMA community.
Appropriate topics for the MARPA Technical Committee Agenda include aviation/manufacturing policy issues, amendment of current aviation/manufacturing policy documents, and new technologies that affect the aviation manufacturing industry. Any technical issue that could affect safety is fair game. MARPA is not just focused on FAA and EASA compliance issues – issues before other agencies (in the US or around the world) are also welcome.
The Technical Committee will meet on October 1, 2014 at 11:00 am. The meeting will take place at the Las Vegas Renaissance Hotel at 3400 Paradise Road
Las Vegas, Nevada 89169 (in conjunction with the MARPA Annual Conference – this occurs during the Workshop Day).
All MARPA members are welcome to attend the Technical Committee meeting.
Please send you Technical Committee Agenda items to Jason Dickstein.
MARPA recently filed comments on the FAA Engine and Propeller Directorate’s draft Advisory Circular 33-Geometry, discussing geometry and dimensional considerations for comparative test and analysis for turbine engine and APU replacement parts. In a previous blog post we observed that AC identified a number dimensional and geometric factors that the FAA expects to be assessed in ensuring the integrity of dimensional characteristics for the purposes of showing similarity.
We requested feedback from our members describing to what extent the FAA’s expectations were reasonable and practicable, and identifying any issues with the proposed guidance on which MARPA should comment. We received several very helpful responses from our members that helped us shape our comments to the proposed AC. Among the issues members identified were:
Feedback from our members is both helpful and valuable to our comments, as it helps us to identify issues that directly affect members’ businesses, and helps us to better focus our resources on those matters that are important to the PMA community. The result is more detailed and on-point responses to the FAA to better help shape the guidance material that will ultimately be issued.
We greatly appreciate the feedback we received from our members on this Advisory Circular, and we hope that our members will continue to answers our requests for responses as additional guidance and rulemaking documents are issued. Together we can work with the FAA to develop the best possible guidance for our industry.
I am very excited to see all of you at the 2013 MARPA Conference on October 23-25 in Las Vegas.
This year the Conference will feature a lobbying meeting workshop conducted by new Air Carrier Committee Chairman Ed Pozzi of United Airlines. This will be a brainstorming session attended by both suppliers and carriers, with a goal to explore a lobbying effort aimed at producing an air carrier PMA approval checklist that can be presented to the FAA for potential publication as an FAA Advisory Circular. For Air Carriers, it will be a great opportunity to work with a diverse group who are involved with the efforts of preparing a PMA technical package for the different variations of submittals. For manufacturers, it is an opportunity to gain understanding in the needs of your customers.
From the number of registrations we have received, this year is assured to be a great chance to network with the best of the industry. And as always, we have A LOT of customers registered for the conference so there are tremendous sales opportunities waiting for PMA company attendees as well!
We’re continuing to add more information about speakers and Conference events, so be sure to check out the online Conference Agenda.
Not yet registered? The Conference Registration form is available online. Just fill it out and email or fax it. Questions? Call Katt Brigham at (202) 628-6777 for answers!
Make sure your registration reaches MARPA before the next deadline to get the current registration discount! The next deadline is Sept 21, 2013 and meeting that deadline will save MARPA members $200 (for the first-registrant from a company) to $300 (for each additional registrant from a company) over the cost of on-site registration.
You don’t have to be a member to come – non-members are also welcome to attend the Conference for the non-member rate.
MARPA co-founder George Powell died on Friday, September 6 after a battle with cancer.
George’s aviation career began as an aircraft pilot during World War II. He then spent a career as an engineer and customer support manager for Bell Helicopter (highlighted by a daring escape from Iran when the Shah’s government fell).
By the 1980s, society felt George was ready to retire but George had different
plans. He became active as a PMA manufacturer and as an independent DER. He was passionate about small business and he helped many of today’s PMA companies get on their feet.
The idea of MARPA was born during the late 1990s, when George, Jim Reum and I sketched out our ideas for a trade association on the back of a cocktail napkin during the lunch break at an Aviation Rulemaking Advisory Committee meeting.
George served as the first President for the Association, and after he stepped down he remained an active guiding voice for MARPA. He was important mentor who helped to guide me and many others within the PMA community. He frequently communicated his ideas to the FAA, helping to shape the policies and regulations that affect the aerospace community.
George was never the sort who could rest – he always wanted to be active and involved. He was one of the leading voices on the MARPA Leasing Committee during the last year of his life. Despite the cancer, he also was active in supporting aerospace businesses right up until days before he passed.
George’s family is planning a celebration of life ceremony in October. They are trying to plan the celebration in Arizona just after the MARPA Conference in order to permit more of George’s friends and business associates from the aerospace industry to conveniently attend (more details are coming soon, and final details will depend on availability).
His family is working on a scholarship fund for aerospace engineering at George’s alma mater (RPI). We hope to have more details on this effort to share with the industry by the time of the MARPA Conference.
MARPA and the industry will be forever indebted to George for his leadership and guidance.
MARPA is pleased to announce that we have been invited to exhibit and present at the 2013 Aerospace Industry Exhibition Tokyo. MARPA will have an exhibitor booth for the three day event, October 2-4, 2013, and MARPA President Jason Dickstein will give a keynote address discussing all things PMA. This is an excellent opportunity to further raise industry awareness about the value and benefits of PMA and about MARPA itself.
The Aerospace Industry Exhibition Tokyo (ASET) is the only exhibition held in Tokyo dedicated to specialized aerospace technologies. In addition to the unique business opportunity, ASET also features programs and lectures from key industry figures, as well as business and social networking events.
ASET is very excited to continue to develop its PMA sessions and exhibitors. The Exhibition has asked for our help in getting the word out about this opportunity, as ASET seeks PMA companies to join their PMA session. The PMA companies would be asked to introduce their business to the attendees and participate in a PMA panel. As inducement for participation, ASET is offering to provide exhibition booth space (three-day exhibition required) and potentially other inducements to PMA companies who are willing to present at the exhibition.
The city of Tokyo’s event planning subsidiary specifically requested the presence of PMA manufacturers at ASET 2013. This is a great opportunity for our members to exhibit their products in front of a large audience in one of Asia’s key business hubs. It is also a chance to further educate the aerospace community on the advantages of PMA.
If your company is interested in taking advantage of this opportunity, please contact ASET advisor Jay Kato via email at firstname.lastname@example.org. ASET 2013 runs October 2-4, so it is important to act quickly. MARPA hopes to see you there.
On July 2, MARPA filed comments with the FAA in response to the draft Standard Operating Procedure Aircraft Certification Service Project Prioritization and Resource Management. The SOP, commonly referred to as “sequencing,” is intended to assist the FAA in prioritizing certification projects submitted for FAA approval in order to get the most out of its limited resources. The goal of sequencing is to give priority to those projects that should have the most significant and immediate effect on safety.
Unfortunately, the policy as written misses out on clearly offering additional safety benefits, and disproportionately favors large businesses over small businesses, while offering no sound policy or safety rationale for this favoritism.
MARPA’s comments identified a number of problems with the policy. The factors and criteria established by the FAA and used to determine a ranking for the purposes of prioritization appear in many ways to be arbitrarily established, with no identified methodology or basis for the calculation of the assigned values. Additionally, the determination of the safety impact of a given project (a significant factor in calculating priority) appears to be left to the subjective evaluation of individual FAA offices or even individual employees. Such subjectivity creates the possibility that identical projects may be assigned a higher or lower priority based on the opinion of an individual employee.
Even when evenhandedly applied, the policy may negatively affect the ability of small businesses to compete with large companies and OEMs, based not upon the safety benefits of their projects, but almost entirely upon the resources available to the companies.
MARPA understands and appreciates the FAA’s efforts to optimize the use of their resources to provide the greatest possible safety benefit to the industry and the flying public. MARPA consistently works with the FAA to optimize its resources and enhance safety, through initiatives such as the Streamlined PMA Process, and participation on rulemaking committees. MARPA looks forward to continuing to work with the FAA to better improve aviation safety and resource commitment.
As regular readers of this blog undoubtedly know, two of MARPA’s many accomplishments over the last year were the development of the MARPA 1100 Standard and successfully assisting the FAA in its issuance of Order 8110.119: Streamlined Process for Parts Manufacturer Approval. Last week, MARPA sat down with FAA staff to update them on the progress of the program and discuss feedback–both positive and negative–that we have received from our members regarding the implementation of this new program.
The MARPA 1100 Standard is a recommended format for demonstrating that a PMA part is appropriate for the streamlined approval process. The goal of that process–outlined in Order 8110.119–is to allow approval of non-safety significant (NSS) PMA parts within 30 days of application by companies with safety records that demonstrate that the FAA may reasonably rely on their systems to ensure quality.
The experiences reported by members has varied. Some members have reported great success with the streamlined process. A solid relationship with their ACO proved to be of great benefit in drafting a Memorandum of Understanding (MOU) and initiating the streamlined process. Continuous communication was also very important.
Each ACO is given a certain amount of discretion in the implementation of the streamlined process. It is therefore important to work cooperatively and patiently with your ACO in developing an MOU that works for both of you and in commencing the streamlined process.
Some larger members originally reported that they would continue to rely on their ODA processes rather than taking advantage of the streamlined process. However, as the benefits of the streamlined process became apparent, those members decided that they too would take advantage of the rapid turnaround for NSS PMAs.
Other members have reported that their ACOs have been resistant to implementing the streamlined process. The FAA suggested a couple of reasons for this resistance. One reason is that the purpose of the streamlined process is to more efficiently allocate resources. If the applicant cannot demonstrate that establishment of an MOU and initiation of the streamlined process is going to result in resource savings, the ACO may be hesitant to travel down the streamlined path. Another reason the ACO may hesitate to implement the process is that it may already have a turnaround time for PMA applications that is very near to the 30-day goal established by the streamlined process. If there is no time or resource benefit to be realized, the ACO may view the process with skepticism.
It will be important in such cases for those companies seeking to implement the streamlined process to demonstrate to their ACO that use of the process will result in measurable time (and corresponding cost) savings. Cooperation and a strong relationship with the ACO will help the applicant in moving the MOU and streamlined process forward.
One of the most frequent comments to both MARPA and the FAA has been that the MOU process is confusing or difficult to start from scratch. Therefore, to better assist our members, MARPA plans to draft and make available guidance to assist businesses in developing their own MOUs.
The Streamlined Process for PMA is still in its infancy, and there will inevitably be growing pains. MARPA wants to hear about all your experiences, both positive and negative, so that we can continue to refine the MARPA 1100 Standard, develop guidance to address challenges, and work with the FAA to present the PMA industry’s perspectives on the program. If you have taken advantage of the streamlined process, if you have hit sticking points with your ACO, or if you have for any reason struggled to initiate the process, email your experiences to MARPA Associate Counsel Ryan Aggergaard at email@example.com. MARPA will work diligently to address challenges in the streamlined process to ensure that the PMA community is best able to take advantage of this growing initiative.
On July 1 the FAA released for comment drafts of revisions to two policy documents of great importance to PMA manufacturers. Both documents speak directly to the PMA approval process.
The first is revision D to FAA Order 8110.42 Parts Manufacturer Approval Procedures. Among other changes, the revision updates the regulatory citations from the latest Title 14 of the Code of Federal Regulations (14 CFR), part 21 rule changes, introduces risk based resource targeting (RBRT) with management options, incorporates directive feedback and clarifies certification office responsibilities under the FAA’s quality management system.
This order describes the internal responsibilities and procedures for approving replacement and modification articles for installation on type-certificated products. The order addresses only the requirements for issuing a PMA; FAA Order 8120.22, Production Approval Procedures, contains the procedures addressing the production activities of manufacturers who produce articles under PMA.
The proposed revision also removes applicant guidance from Order 8110.42D. The applicant guidance removed from the draft of revision D has been relocated to the other draft document released on July 1: FAA AC 21.303-PMA.
AC 21.303-PMA updates the FAA guidance to applicants for PMA of articles submitted on the basis of test and computation or identicality without a license agreement. The AC also provides an application and compliance checklist, adds a certifying statement of compliance, provides guidance for assessing an article’s impact on safety and describes how the FAA approves replacement parts for TSO articles. The AC describes one way, but not the only way, to comply with subpart K of Part 21 of the Federal Aviation Regulations.
Comments on both of these drafts are due September 1, 2013. Comments on Draft Order 8110.42D should be sent to firstname.lastname@example.org. Comments on Draft AC 21.303-PMA should be sent to email@example.com. Whether you file formal comments or not, please share your thoughts and concerns with MARPA Associate Counsel Ryan Aggergaard at firstname.lastname@example.org. MARPA will make every effort to address our members’ concerns in our comments to the FAA.
MARPA has added video to our website!
Now if you look at the “What is a PMA” page on the MARPA website, you will see that we have added a video presentation that explains what PMA parts are all about. This is our first video on our new Youtube page that will become the home to videos about PMA issues.
Please let us know if you have any ideas for video presentations that you’d like to see on MARPA’s Youtube account or on MARPA’s website!