MARPA Conference 2016

Transcription

1 MARPA Conference 2016 FAA Workshop PMA 102 Presented to: Workshop Attendees By: FAA Representatives Date: Oct. 26, 2016

2 Topics Put on your thinking caps! 2

3 Time for something new 3

4 Stump the Regulator Open Q&A session with the FAA policy focals We reserve the right to tap into local FAA knowledge Any question relating to PMA of any kind is fair game Prizes to those who manage to stump us Note: not liking our answer is not stumping us 4

5 Before we get started lets work a few examples! 5

6 PMA a PMA Can I use a PMA d article for the basis of a new Test and Comp PMA? Generally you cannot PMA a PMA Exception to the rule If the OEM s data (IPC typically) identifies the PMA d article as an OEM article or even an approved alternative then they are effectively incorporating the PMA article into their Type Design If however, the OEM has never made such a link from the ID PMA to their Type Design, then even with a PMA via identicality w/ licensing agreement, there is not enough to establish a basis new PMAs via Test and Comp 6

7 RGL and Installation Eligibility If I see another PMA on RGL stating an OEM article has installation eligibility on an aircraft, can I use that as my installation eligibility evidence? Yes, but It is acceptable to use RGL information to prove eligibility But it can only be use to a limited degree and is discourage from being the primary or sole source of eligibility information AC refers to it only in the context of other evidence 7

8 Questions before we begin? 8

9 Ok, then let s see if you can STUMP THE REGULATORS 9

10 Still can t think of anything? In that case, how about we talk though some more examples 10

11 TSO Assist Letter Can I get a PMA via Identicality with a licensing agreement if I have an agreement with the TSO holder who manufactures the article? No! A design based on identicality solely to a TSOA is not applicable for PMA All PMAs are against certified articles installed on products (or in the case of minor modification articles, they are new articles for installation on a product) TSOAs are articles approved to a set of minimum specifications, they do not have installation eligibility until they have been certified through a certification project by an ACO or through an alteration by a FSDO 11

12 Using xxx in Part Numbering Can I use the suffix xxx (or similar) so I don t have to revise a PMA supplement when we make minor changes and add other part numbers? Yes but be clear about it The key to it being within policy is for the design data to clearly limit and define the scope of minor variations that we are approving within the XXX In other words, you MUST control your design in all aspects to which it is approved 12

13 STC vs PMA How do I know if I should get an STC or a PMA? Test and Comp PMAs are not required to be the same as their OEM counterparts If there is a difference between the two articles (PMA and OEM) then it MUST be minor to the product or else by rule (14 CFR ) it must be approved via an STC 13

14 Minor Change How do I know if a change is minor? Two distinct minor change assessments under the PMA process. The initial application The PMA applicant must show that they have not introduced any changes to the design which would have an appreciable affect on the Product s (21.1(b)(5)) certification basis (i.e. Part 23, 25, 27, 29, or 33) Changing the PMA article s design Follow the minor/major change guidance and show that they have not made a change that appreciably affects the certification basis of the current and approved PMA design (i.e. Identicality without a Licensing Agreement, Identicality with a Licensing Agreement, STC, or Test Reports and Computations) Example Test and Comp Minor Change Request Seat cover material change Needs testing to flammability requirements Change to PMA is Major 14

15 Base Material Articles Can I get a PMA for a base article like bar stock, carpet, sealant, paint, or software? Maybe but typically not A PMA is an article as defined in 21.1(b)(2) as a material, part, component, process, or appliance A PMA must be an approved article of the product s type design Many articles used in repairs or service operations are not defined specifically as an aspect of the Type Design One way to see this is if the article has a part number identified within the Type Design data (IPC) Repair or service manuals are not usually the best place to find TC data for PMA articles 15

16 Contact Info. Angelia Collier Aviation Safety Inspector FAA Aircraft Certification Service - L'Enfant Plaza Aircraft Certification Service - Certification Procedures Branch AIR-110 Production Certification Section, AIR-112 T: E: angelia.collier@faa.gov Ian Lucas Aerospace Engineer / PMA Policy FAA Aircraft Certification Service - L'Enfant Plaza Aircraft Certification Service - Certification Procedures Branch AIR-110 Design Certification Section, AIR-111 T: xx E: ian.lucas@faa.gov Robert Sprayberry Aerospace Engineer International Office AIR-400 International Policy Branch, AIR-410 T: E: robert.sprayberry@faa.gov Chris Richards Aerospace Engineer / PMA Policy FAA Engine Propeller Directorate Standards and Policy Section, ANE-140 T: xx E: chris.richards@faa.gov 16