1. Gorham-Technical Workshop Series
PMA’s
Gorham-Technical Workshop Series
FAA PMA – OLD /NEW RULES
Presentation By
DOMINICK P. DACOSTA
C.O.O. DERS GROUP SVC INC
FAA DER-T/RS-DER
FAA DAR-F
March 30, 2011San Diego, CA 1 1

2. FAA DER DISCLAIMER
The 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 & D
FAA data may be obtained on Fed world, at
FAA Disclaimer 2 2

3. FAA PMA BY ASSOCIATED MEANS 14 CFR Part 21.303…..
Workshop Syllabus
General Understanding of what is a PMA really
When and Why the PMA rules came into being
What are the ways to obtain PMA’s
Identicality
ID by License
ID by Design
ID by Associative means
Test and Computation
General Analysis
Comparative Analysis
Testing
The Process to obtain a PMA
Logical Flow Chart
The Data Linkage 3

4. About 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 Engineering
18 years Engine/APU Maintenance & Repair Engineering
Worked 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 1976~2010
Licensed FAA A&P Mechanic
Certified by National Institute for the Certification of Technologist [NICET~NSPE]
Senior Welding Engineering Technologist ~ 1979 ~ 2012
Indiana University - BGS
Ohio State University - Welding Engineering Certification Program
Massachusetts Institute of Technology - Micro Mechanics Program
Kings Aeronautical Institute of Technology – Powerplant Technology
Instructors Background 4 4

5. Acronym’s 5

6. What 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 approve
replacement or modification parts manufactured for and installed on a
Type Certificated Product following its initial Airworthiness Approval. 6

7. Key Amendments to the PMA Regulations
Historical significance of the PMA Regulation’s amendments
Key Amendments to the PMA Regulations
Amendment issued May 19, 1972
Revised Part § by adding paragraph (c)(4) which states
in part that a PMA may be obtained by Identicality.
Amendment issued Dec. 4, 1974
Deleted the requirement that a person who holds a PMA must
be 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 Part
So we have had PMA Identicality Parts for over 26 years! 7

8. Where 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 at
the 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 Undue
Burden and No Undue Burden Decision Papers Under 14 CFR Part 21, for more details. 8

9. Can 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

10. FAA QUALITY SYSTEM REQUIREMENTS NOW but change after 4-16-2011
FAA-PMA
Fabrication 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 NOW
but change after
Approved Production Inspection
System (APIS)‏
FAR §21.125
Establish a Material Review Board
(1) Incoming materials, and bought or subcontracted parts, used in
the finished product must be as specified in the type
design data, or must be suitable equivalents.
(2) Incoming materials, and bought or subcontracted parts, must
be properly identified if their physical or chemical properties
cannot 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 industry
or United States specifications.
(5) Parts and components in process must be inspected for
conformity with the type design data at points in production
where accurate determinations can be made.
(6) Current design drawings must be readily available to
manufacturing and inspection personnel, and used when
necessary.
(7) Design changes, including material substitutions, must be
controlled and approved before being incorporated in the
finished product.
(8) Rejected materials and parts must be segregated and
identified in a manner that precludes installation in the finished
product.
(9) Inspection records must be maintained, identified with the
completed product where practicable, and retained by the
manufacturer for at least two years.
(10) Materials and parts that are withheld because of
departures from design data or specifications, and
that are to be considered for installation in the
finished product, must be processed through the
Materials Review Board. 10

11. There 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.

12. A 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 Agreement
Identicality by Design without a License agreement
Identicality by Associative Means [OCM evidence]
Test & Computation Method [Which has three (3) subsets]
Comparative Analysis Method
General Analysis Method
Testing

13. PMA ID PMA T&C PMA License Design PMA ID by Association
Comparative Analysis
General Analysis
Testing

14. Basic Requirements to Obtain a PMA
1. Fabrication Inspection System
(FIS) per FAR §21.303(h)‏
2. Design Approval
From: Aircraft Certification Office (ACO)‏
3. Production Approval
From: Manufacturing Inspection District
Office (MIDO)‏
These requirements are defined in Order C Chapter 2
What to expect from the applicant 14

15. FAA ORDER 8110.42C PMA Approval Procedures, Chapter 2

16. How 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

17. FAA HAS AMENDED CERTAIN CERTIFICATION PROCEDURES
SUMMARY: The FAA is amending its certification procedures and
identification 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.

18. Background 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 an
increasingly global environment.

19. BACKGROUND CONTINUED:
When the certification rules were first promulgated in 1964 we don’t think the FAA
envisioned 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

20. In 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 components
Require 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; and
5. Revise export airworthiness approval requirements to facilitate global
manufacturing.

21. PRIMARY 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 and
recordkeeping requirements.”
14 CFR Part 43 “Aircraft, Aviation safety, Reporting and recordkeeping requirements”
14 CFR Part 45 “ Parts Marking, Aircraft Identification, Exports, Signs and symbols”

22. Example 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

24. NEW FAA PART 21 RULES CHANGES TO PMA

25. FAA REQUIRES AN EVEN PLAYING FIELD FOR PAH QUALITY SYSTEM

26. FAA HAS INITIATED A GAME CHANGER BY THIS IMPOSITION

28. Implying Suitability for installation can be grounds for violation

29. 14 CFR Part 21 Sub Part K - NEW Existing Sub Part K
Applicability
Replacement and modification parts.
Approval of materials, parts, processes, and appliances.
[Deleted.]

43. Federal Aviation Regulations Certification Procedures for
Part 21
Certification Procedures for
Products and Parts
Defines
Eight (8) ways to obtain new parts
that are considered to be approved,
plus
Three (3) special conditions
A total of 11 ways. 43 43

44. New 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 §21.125
Approved Production Inspection System (APIS)‏
After 6 months TC holder obtains (APIS) Ref. § (c)
3. FAR §21.131
Production Certificate (PC)‏
Eligibility for PC Ref. FAR §21.133
a. Current TC holder
b. Rights to a TC under Licensing Agreement
c. Supplement Type Certificate (STC) holder 44 44

45. New 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 20-62D
Order
Order A
5. FAR § (b)(2)‏
Parts produced by Owner Operator
The 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. 45 45

46. New Approved Parts Imported Parts 7. FAR §21.601
Produced in accordance with an Approval under a Bilateral Airworthiness Agreement (BAA).
7. FAR §21.601
Technical Standard Order (TSO)‏
Parts produced in accordance with a (TSO) authorization issued by the Administrator.
8. FAR § (a)‏
Replacement and Modification Parts
Parts Manufacturer Approval (PMA)
Order C establishes procedures for the evaluation and approval of Parts Manufacturer Approval. 46 46

47. Special 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

48. Special 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

49. There are 11 [Eleven] Legal Ways!
SUMMARY
FAA “Approved Parts”
Defined as:
Parts which are acceptable for installation
on an FAA Type Certificated (TC) Aircraft
or other TC products, which have been
produced in accordance with the
requirements or exceptions of 14 CFR,
Part 21, maintained in accordance with parts
43 and 91, and meet applicable design standards.
There are 11 [Eleven] Legal Ways! 49

50. Replacement and Modification Parts
FAR §45.15
Replacement and Modification Parts
a. Except as provided in paragraph (b) of this section, each person who produces a replacement or modification part under a Parts Manufacturing
Approval 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 is
impractical, 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

51. What 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 [3], 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 list
You need to Prove a Test Plan is NOT needed [ C] 51

52. PMA FLOW CHART 52

53. What 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 vendors
RFC [ ] proposal must be planned
RFC “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/MIDO 53

54. FAA & DER Inter-Action & Regulatory Hierarchy
It is very important to both applicant and designees to understand these inter- actions, and chain of commands
What 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

55. What Branches of The FAA are Responsible for various Designee’s
FAA HQTRS
AEG
MIDO
ACO
FSDO
ALL DESIGN ENGINEERING
DER-T, DER-Y
FAR 21, 23, 25, 27, 29, 33, & 39 etc. TC
STC
PMA
TSO
Repairs, Alterations
DAS, DOA, SFAR 36
NEW PARTS MFG INSP
DAR-F, DMIR
FAR 21, FAR 45 TC
STC
PMA
TSO
Maintenance & Flight Std
DAR-T
FAR 43, 45
FAR 91, 121, 125
FAR 129, 133, 135
FAR 145
DAS, SFAR 36 55 55

56. Regulatory Heirarcy Federal Aviation Regulations [LAW][Must Do]
FAA ORDERS [Should do]
Airworthiness Directives [Should do]
Advisories [May do]
Notices [May do]
Policy Memo’s [may do] 56

57. Safety Assessment Safety Assessment Definitions (cont’d)‏
Functional Hazard Assessment
A 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

58. Safety 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 authority
Requires ACO to ACO coordination
Determination / Evaluation of additional requirements 58

59. NEW 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] PMA
Part 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 been
Released with more to follow:
AC 21-42, AC 21-43, AC21-44, and Order
If you are presently a PAH [PMA holder] your FIS system must be converted from
a FIS, to a FAA “Approved” PC Quality by April 16th 2011

60. SUMMARY OF PMA’s
There 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.

61. INFORMATION ON WORKSHOP DATA & COPIES
Presentation will be available electronically at : Gorham-Tech.com website.
All Referenced FAA materials can be obtained from: RGL.FAA.GOV
Any other data can be obtained by sending a request to: DERS-GROUP.COM
Anyone 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.

62. QUESTIONS