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Help MARPA Help the Commerce Department

As our members know, MARPA has been working over the past two years with the U.S. Department of Commerce’s International Trade Administration (ITA) under its Market Development Cooperator Program (MDCP).  Under the MDCP the ITA provided MARPA a $300,000 matching grant to help MARPA promote PMA around the world with the ultimate goal of increasing exports of U.S.-made PMA parts, with the additional benefit of potentially adding U.S. jobs.

One of the conditions of MARPA’s receipt of the MDCP grant is that we are required to report back to ITA on the increase in exports our members are seeing. These reports allow the ITA to demonstrate the results of the program to Congress and keep open the funding to support increasing U.S. exports in various industries around the world.

This requirement is why we need our members’ help.  We need to hear from you to know if MARPA’s efforts are working, and if the PMA industry is seeing an increase in export sales. MARPA therefore needs your help in gathering data on new exports of PMA parts.

MARPA is always sensitive to its members’ business needs, so we want to assure you that any information provided to us will be kept confidential, and the only information that is shared with ITA will be the country of export and the value of the export, and no other sensitive business information or data.

We are asking that our members fill out the export survey found by following this link.  MARPA needs to know the following information: for any exports that are traceable to a MARPA effort under the MDCP–the MARPA Europe Conference, the domestic MARPA Annual Conference, MARPA’s presence and promotion at trade shows around the world–to what country was the export (or contract for future sales), and what was the value of the export or future export?

That’s it! Just country and dollar value. We don’t need to know your customer’s name, the specific parts or product type involved, or any other detail. Even your company’s name will be kept anonymous unless you expressly tell us to release it to ITA.

If you wish to provide MARPA additional information so that we can better focus our efforts, of course we welcome it. But we only need for the sake of our MDCP requirements a report on export country and dollar value.

Please help MARPA fulfill its obligations to ITA under the MDCP. The ITA was generous in supporting MARPA with this grant so that we can increase our efforts to expand the global PMA market. MARPA needs to make good on its requirement to report back on our efforts and help ITA keep this valuable program going!

If you have questions about MARPA’s reporting obligations under the MDCP or wish to report export data directly rather than by using the survey form, feel free to email VP of Government and Industry Affairs Ryan Aggergaard directly at ryan@washingtonaviation.com.  MARPA sincerely thanks our members in advance for their help!

Challenges Apparent in Reconciling Performance Based Regulations and Emerging Technologies

MARPA had the opportunity this week to attend the 2016 FAA-EASA International Aviation Safety Conference that was held in Washington, DC. The conference provides an opportunity for the regulatory agencies and industry to get together to discuss emerging issues in aviation safety and strengthen the cooperation between both the regulators themselves as well as the regulators and industry.

One notable panel discussed performance-based regulations (PBR) and their development, implementation and oversight as a part of the ongoing safety management adoption. The goal of PBR is essentially to retain the high level requirements and clearly establish what those high-level regulations are trying to achieve, while clearing out more detailed prescriptive regulations. Those detailed regulations would then be replaced by industry consensus standards.

In theory, this should clear the way for innovation by focusing more on ensuring a satisfactory outcome (that complies with the regulations) is the result, rather than focusing on prescriptive compliance-based rules. (How this exactly squares with a safety management system focused on systems and processes rather than the outcome per se is a conversation for another day.)  Performance-based regulations can free the hands of regulated parties and avoid the trap of innovation stagnation in which companies are forced to design or produce in only limited ways in order to comply with the regulations.

Although moving to a PBR approach may be a laudable goal, the next panel demonstrated how challenging it may be for regulators to break free of deeply ingrained compliance-based approaches to oversight.  Relevant to PMA manufacturers, the “fast-moving technologies” panel spent a significant amount of time discussing certification of projects using additive manufacturing techniques.

In theory, a PBR approach would be ideal for approving parts manufactured using emerging technology like additive manufacturing (AM).  If a part can be produced using AM techniques (like 3D printing) that meets all the design requirements (dimensions, material composition, durability, etc) of a part that is traditionally machined, an outcome-focused approach like PBR claims to be should have no problem approving that part. Conversely, if a 3D printed part cannot be made to conform to the approved design, our quality assurance systems reject the part and we go back to the drawing board.

However, it became clear during that panel that we can expect to see more of the same compliance based review of processes in seeking to obtain approval of parts manufactured using emerging technologies like AM.  Of course to borrow from Captain Renault I was shocked, SHOCKED to find that the OEM panelist expressed skepticism that “sub-tier” suppliers or those in the aftermarket were capable of producing approved parts using these methods. But of greater concern was his statement that the regulators might also question that ability.

Part of this concern on the part of the regulators arises from the fact that the regulators themselves do not fully understand technologies like AM yet. The FAA is currently working with industry to determine what controls will need to be in place and what the oversight requirements will be with respect to AM. It will therefore be very important for any PMA manufacturer seeking to use new techniques to manufacture parts to engage the FAA early in the process and demonstrate to the FAA its competence with the technique. This may involve educating the FAA in some cases (and refuting the implications of some larger OEMs that only they know the “special sauce” of new technology).

This much was supported by FAA AIR-1 Dorenda Baker, when she explained that the key to getting approval when relying on new technology is ensuring an understanding on both sides. The FAA needs to be brought into the process very early on. When the FAA is brought in at the last minute, problems and confusion can arise, because what might seem clear to the applicant, who has been working with the technology for months or even years, can seem confusing to the regulator seeing it in action for the first time.  Ms. Baker explained that we don’t want questions being asked for the first time, or engineers trying to understand new processes, at the time of certification. We, as applicants relying on new manufacturing techniques, need to engage the FAA early and often.

Of course this is somewhat inconsistent with a performance-based approach. As we mentioned above, if the goal of PBR is to ensure an outcome that satisfies high-level regulations, it should be less important how we get to the result than that we obtain a satisfactory result. A need on behalf of the regulator to understand fully the processes by which we obtain the result is more consistent with systems oversight (their stated goal) but doesn’t square perfectly with a PBR approach.

Nonetheless, it thus becomes clear that the PMA industry will have to fight this battle of fast moving technology on two fronts: First, we will have to (again) battle against an OEM-driven (mis)perception that only OEMs are capable of understanding and safely applying emerging technologies like additive manufacturing. Second, we will have to work very closely with the regulators to continuously demonstrate our competence and expertise in applying these technologies, and in effectively implementing systems that consistently produce the desired outcome.

There is a lot happening right now; from fundamental shifts in the role regulators play to the way we design and manufacture parts. By frequently engaging with the regulators we are able demonstrate our competence and abilities (simultaneously refuting any implications by competitors to the contrary) and keep the regulators closely engaged so that the certification process moves smoothly and we are able to nimbly adapt to changes as they happen.

MARPA will continue to keep you updated as old regulations change and new regulations emerge.

MARPA Needs Your Comments on the FAA Materials AC

As readers of this blog and attendees at MARPA events know the FAA, specifically the Engine and Propeller Directorate, has been releasing a significant number of PMA-related advisory circulars of late. Currently open for comment is AC 33.15-3 Parts Manufacturer Approval (PMA) Metallic Part Material Compliance Using Comparative Test and Analysis Method for Turbine Engines or Auxiliary Power Units. This is a highly complex draft advisory circular that has the potential to affect many MARPA members and the PMA industry as a whole.

MARPA plans on submitting comments on this advisory circular, but we need the assistance and expertise of the MARPA community to make sure we identify all the possible issues that may have an adverse effect on the PMA industry.

I know that some of our members have already looked at this and have begun to identify issues.  For those who have not yet had the opportunity, please take the time to review the draft language and identify any issues and possible solutions you see. Please provide any comments you identify to MARPA so that we can include them in our comments that we will submit to the FAA.

The AC is fairly lengthy document, so it may take some time to get through. Because of this complexity, we would like to have all of your comments in well in advance of the July 20, 2016 comment due date. MARPA therefore requests that any comments you identify are provided to us as quickly as possible, and in any case no later than July 8.  This should give us ample time to compile all of your comments into a single comment submission on behalf of the members. It will also give us time to circulate our comments back to both the MARPA Technical Committee and MARPA Board for review.

This is a complex and weighty document, so if you plan on reviewing and submitting comments to MARPA or submitting comments on behalf of your company, we encourage you not to wait until the last minute to review the draft AC.

Please email your comments to VP of Government and Industry Affairs Ryan Aggergaard at ryan@washingtonaviation.com.

 

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.

Technical Committee Agenda Items for October Meeting

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 Files Comments on FAA Geometry AC

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:

    •  Possible confusion over availability of existing industry guidance;
    •  Apparent inconsistency with existing FAA guidance;
    •  Inaccurate implications that product testing is the only method available to collect data for lifing methods of life limited parts; and
    •  Issues regarding the specific practice of part selection for selective assembly components.

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.

Are You Registered for the MARPA Conference? Brainstorm with Air Carriers and Suppliers!

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 Passes

George Powell at the 2005 MARPA Meeting

George Powell at the 2005 MARPA Meeting

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 Powell, Gloria Nations and Jason Dickstein at the 2009 MARPA Conference

George Powell, Gloria Nations and Jason Dickstein at the 2009 MARPA Conference

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 to Present at Aerospace Industry Exhibition Tokyo

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  jktechci@jcom.home.ne.jp.  ASET 2013 runs October 2-4, so it is important to act quickly.  MARPA hopes to see you there.

MARPA Offers Comments on FAA Sequencing Program

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.

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