New FAA Guidance Available for Comment on PMAs

The FA A has published two proposed guidance documents on PMAs.  While they are primarily aimed at the community of companies that manufacture PMAs, it would be useful for the distribution community to review them to make sure that they are consistent with our needs as well.  Some distributors may be inspired to enter the PMA world themselves!

The first of the guidance documents is Draft Order 8110-42D. This is the latest revision to the PMA guidance for FAA employees who review and approve PMA applications.  One of the most significant additions to this revision level is the inclusion of risk based resource targeting (RBRT).

Comments on the draft order can be emailed to the FAA at robert.sprayberry@faa.gov .  Please send a copy of your comments to ASA, too, so we can be sure to echo our members’ concerns.  You can also mail comments to:

Federal Aviation Administration
Aircraft Engineering Division
Engineering Procedures Office AIR-110
950 L’Enfant Plaza, SW, 5th Floor
Washington, DC 20024

The second of the guidance documents is Draft AC 21.303-PMA.  There was no previous AC on PMA procedures, but there was plenty of guidance on the old Order (8110.42C).  This takes the guidance that is useful to PMA applicants and pulls it out of the order and gives it a home in a public document.

The draft AC makes it clear that the FAA will issue PMAs for materials like sealants, and for modified standard parts, but that it will not grant PMA for raw materials, processes or inspection procedures.  Many companies in the ASA community have found that developing a PMA manufacturing infrastructure is a convenient way to supply parts that used to be considered “commercial parts,” but that under the newer rules are considered unapproved parts when procured from the “OEM” [a distributor can develop an quality assurance process, treat the producer as a supplier, obtain a PMA and supply the part as an approved part].

Comments on the draft advisory circular can be emailed to the FAA at john.milewski@faa.gov . Please send a copy of your comments to ASA, too, so we can be sure to echo our members’ concerns. You can also mail comments to:

Federal Aviation Administration
Aircraft Engineering Division
Engineering Procedures Office AIR-110
950 L’Enfant Plaza, SW, 5th Floor
Washington, DC 20024

Remember – distributors are concerned about parts safety, too!  Don’t be afraid to raise your concerns or ask your questions if you see some thing in the proposed guidance that you think deserves more attention!  Comments are due to the FAA by September 1, 2013.

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About Jason Dickstein
Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.

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