On August 2 MARPA joined a petition signed by 12 other industry groups seeking the extension of FAA Notice 8900.380. This effort was spearheaded by the Aviation Suppliers Association (“ASA”), the trade association that represents aircraft parts distributors. The policy serves to formalize a repair station’s ability to receive, inspect, and approve for return to service new articles that are not accompanied by an 8130-3 tag. Yesterday, the FAA responded to the petition by agreeing to reissue the policy for another year.
The FAA-EASA Maintenance Annex Guidance revision 6 (“MAG 6”) made the 8130-3 tag a requirement for new parts received into a dual-certificated repair station, even though the 8130-3 tag is not required by the regulations. Not only was this requirement contrary to the actual regulations, it also had the effect of making it difficult for distributors to sell many new parts received from a PAH, and for repair stations to receive new parts released from a PAH, because many PAH’s do not issue 8130-3 tags for new parts (something that is also not required under the regulations).
Notice 8900.380 provided a temporary solution to this issue by ensuring industry knew that repair stations could receive and inspect new parts within their ratings without an 8130-3 tag. This was particularly important for low-dollar value parts for which obtaining a tag from a designee was economically infeasible. This solution is expected to be permanently memorialized in MAG 7, but with only weeks before the expiration of the Notice no draft of MAG 7 has yet appeared on the horizon, and so a different solution was required. Notice 8900.380 was scheduled to expire on August 26 before a permanent solution to this tag problem was reached.
In order to support industry the FAA responded to the petition initiated by ASA and signed by MARPA by reissuing the policy in the form of Notice 8900.429. This notice continues the policy established by Notice 8900.380 for another year, until August 9, 2018. Hopefully this will give the FAA, EASA, and industry time to develop a permanent solution to the 8130-3 problem created by MAG 6 and memorialize that solution in MAG 7.
MARPA is thankful to ASA for leading this effort, as it allows our members–and the PMA community generally–to continue operating our business in the ways we deem most effective, whether we choose to issue 8130-3 tags with our parts or not. Implementing the optional procedures to issue 8130-3 tags described in 14 C.F.R. § 21.137(o) comes with inherent costs, and so it is valuable to not have that requirement forced onto PMA manufacturers by a de facto requirement arising from MAG 6.
You can read the full Notice 8900.429 here.
MARPA is happy to announce that it has extended its partnership with the U.S. Department of Commerce International Trade Administration through the Market Development Cooperator Program (“MDCP”) for another year. The extension of our partnership means MARPA can continue to draw upon the expertise and wide network of contacts the ITA can bring to bear, and in exchange will continue to report export data to ITA, honoring the commitment MARPA made at the beginning of the MDCP relationship. Although there will be no additional direct funds from ITA as a result of the extension, the support and resources ITA staff will continue to offer will be invaluable to MARPA’s continued PMA promotional efforts going forward.
As readers of this blog know, MARPA was awarded an MDCP award of $300,000 in late 2014 for a program to promote the export of PMA parts to certain international markets of emphasis. These markets included Europe, the Middle East, and the Asia Pacific region. In exchange for this award, MARPA agreed to put up $900,000 in cash and in-kind contributions in support of its new initiatives as well as collect export data from participating companies and report it to ITA to validate the MDCP program. (The obligation to report data is an import condition of receiving the MDCP funds and helps ITA justify this program to Congress to promote U.S. exports.) The vast majority of MARPA’s contribution was of the “in-kind” sort, primarily arising from the labors of MARPA staff in organizing conferences and participating in trade shows to promote PMA.
MARPA’s MDCP award has already borne fruit. The matching award has allowed MARPA to establish a second conference: the MARPA EMEA Conference. The conference was held in three different locations in the past three years: Istanbul, Madrid, and Dublin, and has resulted in new customer contacts for attendees, and generated new business for a number of U.S. companies. The conference has been such a success that even though the MDCP funds have been depleted, MARPA has determined that the conference will be held again in 2018, when we return to Dublin to build on our success generating new customers and engaging the leasing community. MARPA’s long-term goal is to make the MARPA EMEA Conference an annual event that people attend every year, much like the MARPA Annual Conference in the U.S. (Orlando, FL, October 25-26, 2017).
The MDCP award also allowed MARPA to participate in several trade shows around the world that we would otherwise not have had the resources to reach. These have included events in Europe, the UAE, Japan, Singapore, China, and South and Central America. MARPA is working internally to determine the value proposition of our continued participation in these events. If our members believe there are events MARPA should be at to promote PMA, we would love to hear from you.
As we continue our cooperative efforts with ITA, MARPA will continue to need your help. We need our members to provide us with export data that we can report to ITA as part of our MDCP obligation. ITA keeps all this information confidential and are well versed in protecting sensitive information and trade secrets. However, MARPA is happy to report trade information anonymously if you prefer. But we need your help to provide us with export data so that we can honor our commitment to ITA. Your export data will also help MARPA better craft its conference agendas to offer the best and most helpful programming possible. Our goal is to help our members export more PMA parts to the world.
We look forward to continuing our relationship with ITA, and we look forward to seeing all of you at future MARPA events!
Questions or suggestions about the conferences? Contact Senior Program Manager Katt Brigham at firstname.lastname@example.org.
Export data to report or questions about reporting? Email VP of Government and Industry Affairs Ryan Aggergaard at email@example.com.
Mark your calendars! After a successful third annual MARPA EMEA Conference, MARPA has decided to return to Dublin, Republic of Ireland to continue building upon the success we have made in engaging the leasing community and expanding the use of PMA across Europe and the Middle East. MARPA has chosen to return to Ireland and hold its fourth annual MARPA EMEA Conference April 30 – May 1, 2018 at the Hilton Dublin Kilmainham hotel.
MARPA knows our members are busy and that there are many conferences fighting for your time and attendance. We are therefore continuing with our pattern of running a very efficient two-day conference with a great networking reception on Monday, April 30, and a full and informative general session on Tuesday, May 1, with plenty of opportunities to network throughout the day.
Locating the MARPA EMEA Conference in Dublin allows for easy travel from the United States and Europe, and the efficient two-day event also allows members traveling from the U.S. to tie in visits to existing customers and potential customers across Europe after the event concludes. (Attendees have also taken advantage of event in the past to enjoy a little time off with their families afterward.)
MARPA looks forward to continuing our discussions with the aircraft leasing companies that call Ireland home, and working with our air carrier friends and friends in government to continue the promotion and global acceptance of PMA. The MARPA EMEA Conference reliably produces an excellent ratio of customers to suppliers and provides ample opportunities to both expand current business and develop new business with customers you might not see anywhere else.
Visit the MARPA EMEA Conference page to learn more, and check back often as we add speakers to the agenda.
Are there speakers or topics you would like to see addressed? Email your recommendations to MARPA Senior Program Manager Katt Brigham at firstname.lastname@example.org so that we can provide you the most valuable conference agenda we can.
The FAA has published a draft policy statement on PMAs for critical propeller parts. The draft policy statement is entitled “Parts Manufacturer Approval (PMA) for Propeller Critical Parts and Category 1 Propeller Parts.” If this policy effects you, then we need to know your opinion before we file the MARPA comments on this draft policy!
The essence of the proposed policy appears to be:
One concern is that a major propeller effect (as defined in 14 C.F.R. 35.15(g)(2)) is different from a hazardous propeller effect (as defined in 14 C.F.R. 35.15(g)(1)). Only parts whose failures result in hazardous propeller effects are propeller critical parts under 14 C.F.R. 35.15(c). And only propeller critical parts are required to meet the integrity establishment requirements of 14 C.F.R. 35.16. But the policy document establishes additional classes of parts that will be subject to section 35.16. Some parts with major propeller effects (as defined in 14 C.F.R. 35.15(g)(2)) could also be characterized as category 1 parts under FAA Order 8120.23A. This policy memo appears to subject those parts to an inappropriate requirement by conflating them with propeller critical parts and requiring that they comply with the integrity establishment requirements of 14 C.F.R. 35.16. This appears to be a potential de facto change to the regulations.
What do you think? Do you have category one parts whose failure only reflects a major propeller effect and not a hazardous propeller effect?
Do you see any different impact? Anything we’ve missed? How does this affect your business? Let us know so that MARPA’s comments on this policy can reflect your interests.
Comments on this draft are due to the FAA by August 31, 2017. We would appreciate your comments to MARPA by August 24.
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
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!
On March 2, MARPA had the opportunity to attend the U.S. Chamber of Commerce 2017 Aviation Summit in Washington, DC. The event featured addresses and panels by the presidents and CEOs of aerospace industry leading operators, manufacturers, and service providers. Although the focus was primarily on operational issues affecting air carriers like Open Skies, airport infrastructure, and air traffic control, there were a couple of points raised by speakers that are relevant to MARPA members and the PMA industry.
During the manufacturing panel, HEICO Corporation Co-President and past MARPA Annual Conference keynote speaker Eric Mendelson, discussed the importance of choice and competition without which it becomes difficult for carriers to operate cost effectively. He used the decrease in suppliers relied upon by Boeing for successive new aircraft to illustrate the challenges facing both operators and aftermarket parts manufacturers, as competition becomes more and more restricted. He noted that the original 777 had three engine options, and approximately 17 component suppliers provided 75% of components. For the 787, those numbers fell to two engine options, and about four component suppliers for 75% of components. In the case of the new 777 there will be only one engine option and fewer still component suppliers.
This on-going reduction in suppliers means that operators face fewer and fewer choices both at the initial purchase stage and in terms of maintenance over the life of the product. This also means that those suppliers have a great deal of leverage in locking operators into long-term service agreements, which threaten PMA manufacturers.
In order to fight this phenomenon, it is vitally important that our customers be educated through their organizations as to the value of ensuring PMA is viable replacement part option, to ensure that they aren’t locking themselves into unfavorable maintenance agreements that needlessly restrict their replacement part options and drive up their costs. This will become even more important if fuel prices begin to rise, causing operators to look more aggressively for areas to realize cost savings.
Another interesting point was made later in the day, by Dennis Muilenburg, Chairman, President, and CEO of Boeing. He noted the importance of the Ex-Im Bank to financing export of US-manufactured goods, and stated that there is approximately $30 billion in deals merely awaiting the Ex-Im Bank’s board to reach a quorum. This requires one more confirmed nominee (currently, only 2 of the 5 seats are filled, and a quorum is required to approve deals over $10 million).
Although MARPA’s members aren’t generally making deals that require that level of financing from Ex-Im, having Ex-Im move out of limbo would be valuable for MARPA’s members. We’ve talked previously at conferences about the various ways the Ex-Im Bank can support MARPA’s members in exporting goods to credit-worthy customers abroad who may otherwise lack the cash flow to complete a large purchase. If Boeing’s willingness to throw its weight behind Ex-Im results in securing the stability of the bank for the future, the benefits would ripple out to the rest of the industry. This is something we will be keeping an eye on.
If you have questions about how Ex-Im can be leveraged help your PMA business, don’t hesitate to let MARPA know.
Twice in the preamble to the new part 23 rule, the FAA explains that “many part suppliers may benefit from this performance-based rule through an expected quicker approval process.”
This seems to suggest that the parts approval process will be expedited because it will be easier for an applicant for a Part 23-based PMA to demonstrate compliance under the performance-based regulations. The question on everyone’s lips is whether that will turn out to be true.
While the majority of our members are focused on parts for commercial aviation, a sizeable minority of our members produce parts for Part 23 airplanes. It is important to MARPA that these members continue to be able to obtain PMAs on a equitable and safe basis. It is equally important that they be able to enter the marketplace on an even playing field.
The new rules will facilitate use of non-standard mechanisms for approval. Under current policy (which is supported by the rule change), manufacturers may build Angle-of-Attack indicator systems according to standards from the American Society for Testing and Materials (ATSM). They may apply to the FAA for approval of the design via a letter certifying that the equipment meets ATSM standards and was produced under required quality systems. The FAA’s Chicago Aircraft Certification Office (ACO) processes all applications to ensure consistent interpretation of the policy. This sort of model may be used more often under the new rules.
One approach for MARPA members might be to identify other articles that could be described by industry consensus standards, and to help develop those standards in partnership with the FAA.
For PMA projects for Part 23 airplanes, the certification basis might be a prior revision level of Part 23, so be careful that you choose the right certification basis for your project. Because of this, the direct effect on PMA applications of the rule changes may not be fully understood for many years. But to the extent that the new rules permit competitors to enter the marketplace more easily (but always with adequate showings of airworthiness), the rules could represent a benefit to an industry where competition and safety innovation have gone hand-in-hand.
The new rules go into effect August 30, 2017. We are eager to hear your experiences with them.
The FAA has revised part 23 (the regulations for non-transport airplanes), and PMA applicants seeking approvals for parts that meet Part 23 requirements will need to pay attention to these changes (but remember that your certification basis might be a prior revision level of Part 23).
One change is the addition of a design metric related to ” the expected operating conditions of the airplane.”
The current rules (which are being revised) state that a designer must “take into account the effects of environmental conditions, such as temperature and humidity, expected in service.”
§ 23.603 Materials and workmanship.
(a) The suitability and durability of materials used for parts, the failure of which could adversely affect safety, must –
(1) Be established by experience or tests;
(2) Meet approved specifications that ensure their having the strength and other properties assumed in the design data; and
(3) Take into account the effects of environmental conditions, such as temperature and humidity, expected in service.
(b) Workmanship must be of a high standard.
The new Part 23 rule will require applicants for PMA for part 23 airplane parts to “design each part, article, and assembly for the expected operating conditions of the airplane.”
Sec. 23.2250 Design and construction principles.
(a) The applicant must design each part, article, and assembly for the expected operating conditions of the airplane.
(b) Design data must adequately define the part, article, or assembly configuration, its design features, and any materials and processes used.
(c) The applicant must determine the suitability of each design detail and part having an important bearing on safety in operations.
(d) The control system must be free from jamming, excessive friction, and excessive deflection when the airplane is subjected to expected limit airloads.
(e) Doors, canopies, and exits must be protected against inadvertent opening in flight, unless shown to create no hazard when opened in flight.
A related regulation continues to use the “likely environmental conditions” language of the prior regulations:
Sec. 23.2260 Materials and processes.
(a) The applicant must determine the suitability and durability of materials used for parts, articles, and assemblies, accounting for the effects of likely environmental conditions expected in service, the failure of which could prevent continued safe flight and landing.
(b) The methods and processes of fabrication and assembly used must produce consistently sound structures. If a fabrication process requires close control to reach this objective, the applicant must perform the process under an approved process specification.
(c) Except as provided in paragraphs (f) and (g) of this section, the applicant must select design values that ensure material strength with probabilities that account for the criticality of the structural element. Design values must account for the probability of structural failure due to material variability.
(d) If material strength properties are required, a determination of those properties must be based on sufficient tests of material meeting specifications to establish design values on a statistical basis.
(e) If thermal effects are significant on a critical component or structure under normal operating conditions, the applicant must determine those effects on allowable stresses used for design.
(f) Design values, greater than the minimums specified by this section, may be used, where only guaranteed minimum values are normally allowed, if a specimen of each individual item is tested before use to determine that the actual strength properties of that particular item will equal or exceed those used in the design.
(g) An applicant may use other material design values if approved by the Administrator.
What does this “expected operating conditions” language in section 23.2250 mean for test & computation applicants? This phrase is used in AC 25-25A in the context of returning a stall protection to non-icing setting. It is also used in AC 20-151 for approval of TCAS units. But neither of these resources describe what this phrase means in the context of a meeting regulatory requirements.
The FAA explains in the preamble to the rule what it means when it says “expected operating conditions.” The FAA’s explanation is not perfectly illuminating, but at least it provides some guidance about what sort of operating conditions should be anticipated and accounted-for in the design process:
“The FAA did not intend to limit this requirement only to the normal operational environment because, if the failure conditions are an expected environment, then an applicant should consider those conditions and protect the structure. Deterioration or loss of strength due to corrosion, weathering, and abrasion are all examples of failure conditions because capability has been degraded. For many years, the rule has expressly required consideration of these causes. It was an expected environment for items to be corroded, weathered, and abraded, but applicants had to consider any other causes too.”
This week you can look forward to five new features of the FAA’s recent rule changes that alter the small airplane rules, but have some minor effects on all other aircraft as well.
The new Part 23 rules become effective on Wednesday, August 30, 2017. All PMA applications subject to Part 23 and submitted on or after that date should ensure that they show compliance to the proper regulations. Your certification basis might be a prior revision level of Part 23, but as time marches on more and more projects will fall within the new Part 23 rules.
In some cases, the new Part 23 rules may make some significant changes.
One example is found in the changes involving instruments. The old rules required an airspeed indicator, an altimeter, a magnetic direction indicator, and a speed warning device for turbine engine powered airplanes. 14 C.F.R. § 23.1303 (2011). The new corollary rule does not require any specific flight instrument – instead it requires:
Sec. 23.2615 Flight, navigation, and powerplant instruments.
(a) Installed systems must provide the flightcrew member who sets or monitors parameters for the flight, navigation, and powerplant, the information necessary to do so during each phase of flight. This information must–
(1) Be presented in a manner that the crewmember can monitor the parameter and determine trends, as needed, to operate the airplane; and
(2) Include limitations, unless the limitation cannot be exceeded in all intended operations.
(b) Indication systems that integrate the display of flight or powerplant parameters to operate the airplane or are required by the operating rules of this chapter must–
(1) Not inhibit the primary display of flight or powerplant parameters needed by any flightcrew member in any normal mode of operation; and
(2) In combination with other systems, be designed and installed so information essential for continued safe flight and landing will be available to the flightcrew in a timely manner after any single failure or probable combination of failures.
This new language leaves it up to the designer to identify the parameters for the flight that the flight crew must set or monitor. This potentially undermines other related regulations, though. For example, the instructions for continued airworthiness regulations require the design approval holder to publish instructions “for each appliance required by this chapter” [meaning the FAA’s safety regulations]. Under the old regulations, it was clear that the instructions for the airspeed indicator, the altimeter, and the magnetic direction indicator were required to be part of the instructions for continued airworthiness. Under the new regulations, this linkage is less plain, and will likely lead to a need for additional FAA guidance.
On the other hand, the new performance-oriented standard may allow PMA applicants greater freedom in designing new improvements to instruments in order to give the flight crew greater information and greater control over the information.