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.
MARPA is pleased to announce the release of the MARPA 1100 Standard. This standard provides guidance in assembling a PMA application for a non-safety sensitive (NSS) aircraft part.
This guidance is meant to reflect a standard mechanism for compiling applications for FAA Parts Manufacturing Approval (PMA) for NSS parts. It includes the obligation to analyze the safety-sensitivity of such parts to demonstrate that they are NSS.
MARPA has been working with the FAA to help develop corollary FAA guidance to explain to FAA employees the public safety benefits of this program, and to advise the FAA on how to handle applications that are properly prepared under the MARPA 1100 standard. If the FAA concurs with the NSS analysis, then this means that the part is outside the main thrust of the FAA”s mission, because the part’s failure would not adversely affect safety. This means that the FAA may exercise discretion to rely on the statement of conformance form the applicant for purposes of making a finding of compliance (the FAA always retains the right to to examine the application themselves).
This benefits the FAA, because it allows FAA employees to devote more time to critical safety issues, and potentially decreases the amount of time spent processing PMA applications that are not safety sensitive. For applicants, the program provides a streamlined process for developing the application, and it also sets a goal of a 30-day turn-around time from application to PMA supplement issue.
The FAA plans to limit expedited treatment under this program to PMA applicants with a history of PMA applications, as those without a history are more likely to need a more complete PMA-application-package review by the FAA. Details on what this means are found in the standard.
PMA applicants who are not yet eligible for expedited treatment under this program are encouraged to use it to build their program, so that they will be able to easily move into the streamlined program for NSS parts when the applicant is eligible for the program. In addition, they may find that the additional documentation and rigor recommended by the standard reflects a useful way to prepare a PMA application for NSS parts.
The standard was developed through an industry collaborative process that included making it available for comment, and revising the drafts to reflect member and government comments. Recommendations on the standard are appreciated, and should be sent to MARPA for disposition in the second edition.
MARPA is also currently working on revisions to the MARPA Continued Operational Safety (COS) guidance, and plans to release the next revision to that guidance, soon. Members who are interested in working on this guidance should contact the Association.
John Milewski spoke at the MARPA Conference in October about his efforts to update the FAA guidance that affects the PMA community. We caught up with him at the PMA Summit to follow-up on some of the issues facing the PMA industry.
Rev D of the PMA Order (FAA Order 8110.42) is in the works. Under the new guidance, A major change in the PMA includes a change in the basis of the PMA. it will also reflect the extraction of the applicant guidelines which will be placed into an Advisory Circular (AC).
FAA is developing a separate AC to clearly distinguish applicant responsibilities from FAA responsibilities. The AC will clearly delineate the application obligations of the private sector seeking PMAs.
FAA is promoting the creation of a compliance table listing regulations and showing methods of compliance. These sort of tables have represented a “best practice” among PMA applicants. Applicants will be encouraged to include such tables in order to clarify for FAA engineers which regulations apply, and how the applicant is showing compliance. This permits reviewing officials to more quickly zoom in on potential issues and rapidly determine whether technical issues appear to have been adequately addressed in the PMA application.
Milewski indicated that Industry should expect the opportunity for public comment on a draft of FAA Order 8110.42D in February of 2012.
At the PMA Summit in London, there were a number of questions for John Milewski. Two that caught our attention were the following: