MARPA and You Working Together to Make PMA Successful March 31, 2011 Gorham Conference 1 Modification and Replacement Parts Association (MARPA)

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Presentation transcript:

MARPA and You Working Together to Make PMA Successful March 31, 2011 Gorham Conference 1 Modification and Replacement Parts Association (MARPA)

safety PMA MARPA Trade Association representing PMA parts manufacturers Established 1999 – To give the PMA industry a voice in Washington Promote regulations that ensure safe practices Protect the PMA industry – To educate our customers about PMA’s safety record – To promote the value posed by PMA – To circulate industry best practices March 31, 2011 Gorham Conference Modification and Replacement Parts Association (MARPA) 2

MARPA’s Role Coach – We promote best practices – We work with industry committees to help establish uniform industry lobbying positions Cheerleader – We work with the customer base to promote PMA – Safety, reliability, availability & economic benefits Referee – We work directly with government regulators to help ensure that regulations are fair to the PMA industry March 31, 2011 Gorham Conference Modification and Replacement Parts Association (MARPA) 3

10+ Years Ago Air carriers asked – What are these PMA parts? – Are they safe? TC holders called PMAs “bogus parts” Some non-U.S. Governments were not sure what to do with PMA parts The U.S. Government was taking steps to educate our trading partners about PMA MARPA was formed in 1999 March 31, 2011 Gorham Conference Modification and Replacement Parts Association (MARPA) 4

Today Air carriers are asking – How can I convince my leasing companies to partner on use of PMA parts TC holders are active participants in the PMA market – Licensed PMAs – Partnering with PMA holders Non-U.S. Governments are comfortable with PMA parts – 2007 EASA Directive – EASA-FAA BASA recognizes PMA parts (May 1, 2011) – China and Australia are issuing their own PMAs The U.S. Government has issued Reports and Bulletins supporting PMA parts MARPA continues to work with industry and governments March 31, 2011 Gorham Conference Modification and Replacement Parts Association (MARPA) 5 – Acquisition of PMA holders – Acquisition of their own PMAs

Look at the Comparison! Past Air carriers asked about PMAs TC holders called PMAs “bogus parts” Non-U.S. Government uncertainty Today Air carriers are asking – How can I convince my leasing companies to partner on use of PMA parts TC holders embracing PMA as a way of doing business Non-U.S. Governments comfortable with PMA parts – Accepting PMA parts under bilateral agreements and local legislation – Issuing their own PMAs – Contemplating additional PMA structure March 31, 2011 Gorham Conference Modification and Replacement Parts Association (MARPA) 6

How Did We Accomplish the Change? As an industry, PMA manufacturers have been successful in protecting safety while also providing value to our customers – We have demonstrated our commitment to safety through our safety record – We have demonstrated our commitment to safety through our industry activities March 31, 2011 Gorham Conference Modification and Replacement Parts Association (MARPA) 7

COS – an Example of the PMA Industry’s Commitment The MARPA Continued Operational Safety (COS) Program (published in 2007) – Problem Prevention Initial data gathering Prediction of future issues – Parts Monitoring Field data collection and monitoring – Problem Response Closed-loop response to all issues Industry communication concerning issues March 31, 2011 Gorham Conference Modification and Replacement Parts Association (MARPA) 8

What Has Adoption of COS Done for Us? Demonstrated our safety commitment to the customers Demonstrated our safety commitment to the FAA Demonstrated our safety commitment to non- U.S. governments This has made it easy for MARPA to promote the industry March 31, 2011 Gorham Conference Modification and Replacement Parts Association (MARPA) 9

Major Regulatory Milestones 2007 EASA Decision 2007/003/C – Codified EASA position accepting PMAs 2007 MARPA publishes its COS Program 2008 FAA Order C – Recognizes the importance of COS March 31, 2011 Gorham Conference Modification and Replacement Parts Association (MARPA) 10

More Regulatory Achievements 2008 SAIB NE – Affirmed that PMA parts are interchangeable with TC/PC parts, and that FAA approved limits and instructions continue to apply to them 2009 RAFT Report – Recognized that PMA parts are safe and that FAA oversight is adequate 2009 Part 21 – Codified Order by unifying the quality system regulations that apply to PMA and PC holders March 31, 2011 Gorham Conference Modification and Replacement Parts Association (MARPA) 11

The Next Challenges Part 21 implementation Safety Management Systems Streamlined PMA Application Processes Educating the Leasing Community about PMA Value March 31, 2011 Gorham Conference Modification and Replacement Parts Association (MARPA) 12

Part 21 Implementation Only 47% of PAHs had started the process of getting quality manuals approved – Submit your quality manuals to the FAA by April 16 if you have not already done so! Supplier control – requires supplier control NOT just confirmation of quality of materials – Recent FAA guidance on nickel parts requires unusually high levels of supplier control March 31, 2011 Gorham Conference Modification and Replacement Parts Association (MARPA) 13

ICAO’s Vision of SMS 1 Safety Policy and Objectives 1.1 – Management Commitment and Responsibility 1.2 – Safety Accountabilities of Managers 1.3 – Appointment of Key Safety Personnel 1.4 – Coordination of Emergency Response Planning 1.5 – Documentation, Including SMS Implementation Plan 2 Safety Risk Management 2.1 – Hazard Identification Processes 2.2 – Risk Assessment and Mitigation Processes 3 Safety Assurance 3.1 – Safety Performance Monitoring and Measurement 3.2 – The Management of Change 3.3 – Continuous Improvement of the SMS 4 Safety Promotion 4.1 – Training and Education 4.2 – Safety Communication ASA QA Committee June 27,

Safety Management Systems SMS is an effective method for managing safety ICAO has asked governments to mandate SMS as a means of managing safety Challenge: – How does the government promote the beneficial aspects of SMS without inhibiting future innovation in systems management March 31, 2011 Gorham Conference Modification and Replacement Parts Association (MARPA) 15

MARPA and SMS MARPA was a member of the FAA’s first SMS Aviation Rulemaking Committee (ARC) – We expect a new ARC either late in 2011 or else in 2012 – We developed Design & Manufacturing Industry comments (with AIA and GAMA) and two sets of MARPA comments in response to the air carrier SMS rule, because it will serve as the foundation for a manufacturer’s SMS rule MARPA is working with the FAA to develop performance oriented-standards instead of process- oriented standards – The provide industry with more discretion to develop and optimize processes that work, and that can be improved March 31, 2011 Gorham Conference Modification and Replacement Parts Association (MARPA) 16

Streamlined PMA MARPA has developed a template for non- critical aircraft parts PMA applications FAA is developing guidance to permit certain non-critical parts to be favored with expedited treatment if the application meets certain FAA standards March 31, 2011 Gorham Conference Modification and Replacement Parts Association (MARPA) 17

Leasing This summer, MARPA will begin working on the development of a White Paper on PMA and Leasing Anyone who would like to participate is welcome to join the development team March 31, 2011 Gorham Conference Modification and Replacement Parts Association (MARPA) 18

Get Involved MARPA is made up of the PMA community You are the heart and soul of MARPA MARPA Committees – Board of Directors – Continued Operational Safety – Technical – Marketing March 31, 2011 Gorham Conference Modification and Replacement Parts Association (MARPA) 19

Thank You Jason Dickstein, President Modification and Replacement Parts Association 2233 Wisconsin Avenue, Suite 503 Washington, DC Tel: (202) – Fax: (202) March 31, 2011 Gorham Conference 20 Modification and Replacement Parts Association (MARPA)