Presentation on theme: "Gorham-Technical Workshop Series"— Presentation transcript:
1Gorham-Technical Workshop Series PMA’sGorham-Technical Workshop SeriesFAA PMA – OLD /NEW RULESPresentation ByDOMINICK P. DACOSTAC.O.O. DERS GROUP SVC INCFAA DER-T/RS-DERFAA DAR-FMarch 30, 2011San Diego, CA11
2FAA DER DISCLAIMERThe Federal Aviation Administration is not in any way responsible for the data, or the opinions presented in this presentation.The opinions and data presented herein are the those of the presenter.The audience is responsible to confirm all data, relative to FAR’s, Orders, and Advisories for accuracy and being the current revisions.The FAA Delegate’s that function as a DER is defined in FAR 183, and FAA Orders C & DFAA data may be obtained on Fed world, atFAA Disclaimer22
3FAA PMA BY ASSOCIATED MEANS 14 CFR Part 21.303….. Workshop SyllabusGeneral Understanding of what is a PMA reallyWhen and Why the PMA rules came into beingWhat are the ways to obtain PMA’sIdenticalityID by LicenseID by DesignID by Associative meansTest and ComputationGeneral AnalysisComparative AnalysisTestingThe Process to obtain a PMALogical Flow ChartThe Data Linkage3
4About your Instructor Dominick P. DaCosta FAA DER-T Engines Chart E, Powerplant Chart B, Systems Chart C1, Structures Chart A ~ PMA ID Findings Authority & Major Repair/Alterations Multiple Use Authority & RS-DER Authority.FAA DAR-F ~ Class I, II, and III Parts .28 years Aerospace Manufacturing Engineering18 years Engine/APU Maintenance & Repair EngineeringWorked with GE, P&W, Textron/Lycoming, Rolls Royce, Honeywell APU, Garrett Engine, Bendix Fuel Cntrls/Brake/LG, CTL Inc., United Airlines, CRT, American Airlines, Exotic Metals, Soundair, Lufthansa, MTU, Alitalia, Air France FedEx, Iberia, ITT, Hamilton Std., Parker, Rexnord, SR Technics, ACS, Eaton, SW Airlines and others.ASNT Level III Since 1976~2010Licensed FAA A&P MechanicCertified by National Institute for the Certification of Technologist [NICET~NSPE]Senior Welding Engineering Technologist ~ 1979 ~ 2012Indiana University - BGSOhio State University - Welding Engineering Certification ProgramMassachusetts Institute of Technology - Micro Mechanics ProgramKings Aeronautical Institute of Technology – Powerplant TechnologyInstructors Background44
6What is a PMA ? Overview of the FAA PMA VIEWS A PMA [Part Manufacturing Authority] Is A Modifications and Replacement Part or commonly referred to as a (PMA)!PMA is one of the eleven (11) ways the FAA uses to control and approvereplacement or modification parts manufactured for and installed on aType Certificated Product following its initial Airworthiness Approval.6
7Key Amendments to the PMA Regulations Historical significance of the PMA Regulation’s amendmentsKey Amendments to the PMA RegulationsAmendment issued May 19, 1972Revised Part § by adding paragraph (c)(4) which statesin part that a PMA may be obtained by Identicality.Amendment issued Dec. 4, 1974Deleted the requirement that a person who holds a PMA mustbe the manufacturer of the part covered by the PMA.Based on this Amendment a distributor may be the PMA holder providing the distributor has a “Fabrication Inspection System” in place that meets 14 CFR PartSo we have had PMA Identicality Parts for over 26 years!7
8Where are PMA’s Manufactured [Held]? All PMA’s to date are held and controlled by U.S. based companies!Ref: FAA Order C Chapter 3b “Undue Burden”b. Confirms Location of Manufacturer. If the FIS is outside the United States, we atthe FAA will not issue or expand a PMA unless regulatory oversight places no undue burden on us. Work with headquarters, Production and Airworthiness Certification Division (AIR-200), to determine if the oversight poses an undue burden. See Order , Developing UndueBurden and No Undue Burden Decision Papers Under 14 CFR Part 21, for more details.8
9Can a PMA PAH sub contract manufacturing tasks to vendors located outside the USA? However, just like TC, TSO & STC’s all PMA companies can,If done in accordance with FAA approved procedures, sub-contract any of the manufacturing to qualified vendors with FAA MIDO agreement.Usually the requirement will be two the these elements:The location of the Vendor should be in a country that has a Bi-lateral agreement with the FAA.That you have an acceptable auditing procedure of work performed at vendor.9
10FAA QUALITY SYSTEM REQUIREMENTS NOW but change after 4-16-2011 FAA-PMAFabrication Inspection System(FIS)FAR § (h)(1) Incoming material used in the finished part must be as specified in the design data.(2) Incoming materials must be properly identified if their physical and chemical properties cannot otherwise be readily and accurately determined.(3) Materials subject to damage and deterioration must be suitably stored and adequately protected.(4) Processes affecting the quality and safety of the finished product must be accomplished in accordance with acceptable specifications.(5) Parts in process must be inspected for conformity with the design data at points in production where accurate determination can be made. Statistical quality control procedures may be employed where it is shown that a satisfactory level of quality will be maintained for the particular part involved.(6) Current design drawings must be readily available to manufacturing and inspection personnel, and used when necessary.(7) Major changes to the basic design must be adequately controlled and approved before being incorporated in the finished part.(8) Rejected materials and components must be segregated and identified in such a manner as to preclude their use in the finished part.(9) Inspection records must be maintained, identified with the completed part, where practicable, and retained in the manufacturer’s file for a period of at least two years after the part has been completed.FAA QUALITY SYSTEM REQUIREMENTS NOWbut change afterApproved Production InspectionSystem (APIS)FAR §21.125Establish a Material Review Board(1) Incoming materials, and bought or subcontracted parts, used inthe finished product must be as specified in the typedesign data, or must be suitable equivalents.(2) Incoming materials, and bought or subcontracted parts, mustbe properly identified if their physical or chemical propertiescannot be readily and accurately determined.(3) Materials subject to damage and deterioration must be suitablystored and adequately protected.(4) Processes affecting the quality and safety of the finished productmust be accomplished in accordance with acceptable industryor United States specifications.(5) Parts and components in process must be inspected forconformity with the type design data at points in productionwhere accurate determinations can be made.(6) Current design drawings must be readily available tomanufacturing and inspection personnel, and used whennecessary.(7) Design changes, including material substitutions, must becontrolled and approved before being incorporated in thefinished product.(8) Rejected materials and parts must be segregated andidentified in a manner that precludes installation in the finishedproduct.(9) Inspection records must be maintained, identified with thecompleted product where practicable, and retained by themanufacturer for at least two years.(10) Materials and parts that are withheld because ofdepartures from design data or specifications, andthat are to be considered for installation in thefinished product, must be processed through theMaterials Review Board.10
11There are two types of PMA’s by Rule and by Order MAJOR – PMA – Developed from an STC. Invoked under 14 CFR Part 21.95, & 21.97, and guidance given under Order C. This PMA which is developed from a STC is a Major Change Designed Component. When this STC-PMA is installed you should follow 43 Appendix B, and issue to the TC product a Form 337, and the should be annotated in Box 13, that it is a Major Design Change Component, in some Bi-laterals this statement is mandatory.MINOR – PMA – Developed from a TC or TSO sub component which does not go beyond 14 CFR Part 21.93, and is considered under Order C as a minor change to the original TC or TSO. With the exception of LLP’s most Bi-laterals allow the use of these types of PMA’s without restrictions or re-validations.Only a be executed upon installation to a TC product.Note: Licensed PMA on LLP’s are normally accepted without restriction in most Bi-laterals.
12A PMA [Parts Manufacturing Authority] therefore is a specific way to obtain FAA approval to replace or modify a component to be installed onto a Type Certificated Product.There are two (2) fundamental ways to apply for a PMA.Identicality [Which has three (3) subsets]Identicality by License AgreementIdenticality by Design without a License agreementIdenticality by Associative Means [OCM evidence]Test & Computation Method [Which has three (3) subsets]Comparative Analysis MethodGeneral Analysis MethodTesting
13PMA ID PMA T&C PMA License Design PMA ID by Association Comparative AnalysisGeneral AnalysisTesting
14Basic Requirements to Obtain a PMA 1. Fabrication Inspection System(FIS) per FAR §21.303(h)2. Design ApprovalFrom: Aircraft Certification Office (ACO)3. Production ApprovalFrom: Manufacturing Inspection DistrictOffice (MIDO)These requirements are defined in Order C Chapter 2What to expect from the applicant14
15FAA ORDER 8110.42C PMA Approval Procedures, Chapter 2
16How many different ways can you obtain an APPROVED part? The definition of APPROVED part is found in several regulations and FAA Orders and AC’s…Here are the 11 [Eleven ways] to obtain an approved Part that can be installed onto a type certificated product [Airplane, Engine or Propeller]16
17FAA HAS AMENDED CERTAIN CERTIFICATION PROCEDURES SUMMARY: The FAA is amending its certification procedures andidentification requirements for aeronautical products and articles. The amendments will update and standardize those requirements for production approval holders (PAHs), revise export airworthiness approval requirements to facilitate global manufacturing, move all part marking requirements from part 21 to part 45, and amend the identification requirements for products and articles. The intent of these changes is to continue to promote safety by ensuring that aircraft, and products and articles designed specifically for use in aircraft, wherever manufactured, meet appropriate minimum standards for design and construction. As a result of this action, the FAA's regulations now better reflect the current global aircraft and aircraft products and articles manufacturing environment.DATES: This rule is effective April 14, 2010.
18Background To The Rule Changes: Over the last several decades, the aircraft manufacturing industry has evolved significantly. Years ago, most transport category aircraft were manufactured in the United States. A typical business model consisted of a production certificate (PC) holder with a relatively small number of suppliers. Today, the number of aircraft manufacturing suppliers has increased dramatically. Conversely, through the years, the aircraft industry has seen a steady decline in the number of U.S.- based transport category aircraft manufacturers. Those manufacturers, who once predominantly oversaw the production of replacement articles for their aircraft, now witness the ever increasing production of replacement and modification articles by independent parts manufacturers. Suppliers, including parts manufacturers, were located mainly in the United States decades ago; now, they are located all over the world. Suppliers are manufacturing greater percentages of aircraft products and articles. As a result, aircraft are now manufactured in anincreasingly global environment.
19BACKGROUND CONTINUED: When the certification rules were first promulgated in 1964 we don’t think the FAAenvisioned the rapid growth and globalization of the aerospace industry. This is substantiated by the present numerous International Bilateral Agreements. This rule change incorporate is the FAA's response to the changing dynamics of the aircraft manufacturing industry, and this final rule contains requirements that reflect the current global environment. Evolution of the manufacturing industry prompted the FAA to publish in the Federal Register a notice of proposed rulemaking (NPRM) on ``Production and Airworthiness Approvals, Parts Marking, and Miscellaneous Proposals'' (71 FR 58914, October 5, 2006). Comprehensive changes to certification procedures and identification requirements for aeronautical products and articles
20In general, the FAA proposes to: Standardize quality system requirements for all Production Approval Holders (PAH)Require PAHs, including those producing under Type Certificate, to mark all articles, including sub-assemblies and componentsRequire PAHs to issue airworthiness approvals for aircraft engines, propellers, and other aviation articles;4. Require PAHs to create a certifying staff to issue those approvals; and5. Revise export airworthiness approval requirements to facilitate globalmanufacturing.
21PRIMARY AREAS BEING AMENDED BY THE NEW 21 RULE CHANGE List of Amended Rules Change Subjects:14 CFR Part 1 “General Definitions”14 CFR Part 21 “Production Aircraft, Aviation safety, Exports, Imports, Reporting andrecordkeeping requirements.”14 CFR Part 43 “Aircraft, Aviation safety, Reporting and recordkeeping requirements”14 CFR Part 45 “ Parts Marking, Aircraft Identification, Exports, Signs and symbols”
22Example Of Definition CFR 1.1, Changes: Approved, unless used with reference to another person, means approved by the FAA or any person to whom the FAA has delegated its authority in the matter concerned, or approved under the provisions of a bilateral agreement between the United States and a foreign country or jurisdiction.Example Of PART 21 Changes -CERTIFICATION PROCEDURES FOR PRODUCTS, ARTICLES, AND PARTS;Removing the word ``Administrator'' and adding in its place the word ``FAA'' wherever it appears.Removing the word ``shall'' and adding in its place the word``must'' wherever it appears
43Federal Aviation Regulations Certification Procedures for Part 21Certification Procedures forProducts and PartsDefinesEight (8) ways to obtain new partsthat are considered to be approved,plusThree (3) special conditionsA total of 11 ways.4343
44New Approved Parts 1. FAR §21.123 Production Under Type Certificate Only (TC)Operate under TC only for 6 months unless extended by the Administrator.2. FAR §21.125Approved Production Inspection System (APIS)After 6 months TC holder obtains (APIS) Ref. § (c)3. FAR §21.131Production Certificate (PC)Eligibility for PC Ref. FAR §21.133a. Current TC holderb. Rights to a TC under Licensing Agreementc. Supplement Type Certificate (STC) holder4444
45New Approved Parts 4. FAR §21.303 (h)(4) Standard Part A part manufactured in complete compliance with an established industry or U.S.government specification which includes design, manufacturing, and uniform identification requirements. The specification must include all information necessary to produce and conform the part and be published so that any party may manufacture the part. Examples include but are not limited to National Aerospace Standards (AS), and Military Standards (MS).Definition per A/C 20-62DOrderOrder A5. FAR § (b)(2)Parts produced by Owner OperatorThe Owner-Operator controls the design, manufacture, or quality of parts produced. These parts may only be sold to the Owner-Operator who has approved the parts.4545
46New Approved Parts Imported Parts 7. FAR §21.601 Produced in accordance with an Approval under a Bilateral Airworthiness Agreement (BAA).7. FAR §21.601Technical Standard Order (TSO)Parts produced in accordance with a (TSO) authorization issued by the Administrator.8. FAR § (a)Replacement and Modification PartsParts Manufacturer Approval (PMA)Order C establishes procedures for the evaluation and approval of Parts Manufacturer Approval.4646
47Special Conditions for MRP Part Approval 9. Parts sold prior to the issuance of a Type Certificate (Provisioning).A manufacturer with a APIS or PC may ship replacement parts prior to the issuance of TC or STC provided the parts are segregated at their destination and identified as “Not for Revenue Service - Type Certificate Pending”. Ref. Advisory Circular 21-32A.47
48Special Conditions for MRP Part Approval (cont.) 11. Repair Station Production of Replacement or Modification Parts.AC Chg 1 Allows Maintenance personnel to fabricate replacement components consumed in the repair when the data for that component has been FAA approved.48
49There are 11 [Eleven] Legal Ways! SUMMARYFAA “Approved Parts”Defined as:Parts which are acceptable for installationon an FAA Type Certificated (TC) Aircraftor other TC products, which have beenproduced in accordance with therequirements or exceptions of 14 CFR,Part 21, maintained in accordance with parts43 and 91, and meet applicable design standards.There are 11 [Eleven] Legal Ways!49
50Replacement and Modification Parts FAR §45.15Replacement and Modification Partsa. Except as provided in paragraph (b) of this section, each person who produces a replacement or modification part under a Parts ManufacturingApproval issued under § of this chapter shall permanently and legibly mark the part with -1. The letters “FAA-PMA”;2. The name, trademark, or symbol of the holder of the Parts Manufacturing Approval;3. The part number, and;4. The name and model designations of each type certificated product on which the part is eligible for installation.b. If the Administrator finds that a part is to small or that it is otherwise impractical to mark a part with any of the information required by paragraph (a) of this section, a tag attached to the part or its container must include the information that could not be marked on the part. If the marking required by paragraph (a)(4) of this section is so extensive that to mark it on a tag isimpractical, the tag attached to the part or the container may refer to a specific readily available manual or catalog for part eligibility information.PMA Parts are approved when the manufacturer meets the marking requirements of FAR §45.15.50
51What are the Key Steps for PMA Data You need to PROVE, Installation Eligibility [ C]Any combination of two of these will usually be sufficient: [IPC, & ESM, AMM, SRM, MML, SB, or SIL]You need to SHOW, Compliance to ALL applicable Airworthiness Regualtions [ C ], in your design.If the component goes into an engine then all applicable FAR 33 design issues apply etc. [33.4, 33.15, 33.19a, 33.62, 33.63, & 33.75]You need to show that component is NOT critical, or Life Limited [ C + national Policy memo’s]This is accomplished three , ways: 1. Perform SDR/AD search, 2. Perform [S&CA] analysis per C, or A, 3. Perform comparative analysis of your MRP, against TC Part. [More on this “Criticality assessment”]Prepare a Compliance plan & check listYou need to Prove a Test Plan is NOT needed [ C]51
53What are the Key Steps for PMA Data [continued] Prepare ALL design data [ie. Drawings, sketches, manufacturing & Inspection procedures.Identify outside vendors [especially special or critical processes]You also need to disclose method for controlling quality of these vendorsRFC [ ] proposal must be plannedRFC “Part Conformity”RFC “Installation Conformity”RFC “Special Testing”You must show compliance to 14 CFR Part [Part ID/Marking] [ C]Get FAA ACO design approval, and then FAA MIDO manufacturing approval [FIS] that meets (h).YOU THEN GET A Supplement letter authorized to sell your PMA design parts.Then you could depending on “Criticality” have a “Post PMA” Review by FAA ACO/MIDO53
54FAA & DER Inter-Action & Regulatory Hierarchy It is very important to both applicant and designees to understand these inter- actions, and chain of commandsWhat is chain of command or better put “Hierarchy” between Applicant, FAA, Designee, and the rules, orders, advisories, and policies?Lets look at FAA to Designee relationship first!54
55What Branches of The FAA are Responsible for various Designee’s FAA HQTRSAEGMIDOACOFSDOALL DESIGN ENGINEERINGDER-T, DER-YFAR 21, 23, 25, 27, 29, 33, & 39 etc.TCSTCPMATSORepairs, AlterationsDAS, DOA, SFAR 36NEW PARTS MFG INSPDAR-F, DMIRFAR 21, FAR 45TCSTCPMATSOMaintenance & Flight StdDAR-TFAR 43, 45FAR 91, 121, 125FAR 129, 133, 135FAR 145DAS, SFAR 365555
57Safety Assessment Safety Assessment Definitions (cont’d) Functional Hazard AssessmentA systematic, comprehensive examination of airplane and system functions to identify potential Minor, Major , Hazardous, and Catastrophic Failure conditions that may arise as a result of a malfunction or a failure to function.57
58Safety Assessment Critical Parts The criticality of a part is determined after preparation and review of the Safety Assessment (the FMEA).The FMEA presents a clear understanding of the part in question, its function, and its impact to the NHA and end item installation.If a part is determined critical, it must be addressed differently than a “non-critical” part.Places limitations on DER authorityRequires ACO to ACO coordinationDetermination / Evaluation of additional requirements58
59NEW FAA NATIONAL POLICY ON PART 21 The FAA has released changes to 14 CFR Part 21 “Product Rules”These changes will affect [Modification and Replacement Parts Rules] PMAPart 43 rules, Part 45 rules and several other airworthiness rules.These changes become permanent and effective April 16, 2011.Notice of rule making has already been published. Several National Policies have beenReleased with more to follow:AC 21-42, AC 21-43, AC21-44, and OrderIf you are presently a PAH [PMA holder] your FIS system must be converted froma FIS, to a FAA “Approved” PC Quality by April 16th 2011
60SUMMARY OF PMA’sThere are Eleven ways the FAA allows parts to be installed unto a type certificated product, and PMA is “ONE” of the eleven ways.After April 16th 2011 there will be no difference between an TCH OEM PAH QA System, and that of a PMA PAH QA system.There are “TWO” types of PMA’s [Identicality], and Design equivalent [Test and Computation].Effective May 01, 2011, New EASA Bi-lateral allows use of FAA PMA unto SOD USA product without restrictions, and on to EASA SOD, all but LLP without restrictions.New Part 21 rules change “Increases” over-sight on PAH suppliers and vendors.
61INFORMATION ON WORKSHOP DATA & COPIES Presentation will be available electronically at : Gorham-Tech.com website.All Referenced FAA materials can be obtained from: RGL.FAA.GOVAny other data can be obtained by sending a request to: DERS-GROUP.COMAnyone attending wishing a CEU / FAA AC65.25C certificate can contact Gorham-Tech and be sure you have registered at with the facilitator for that certificate course request.