Memorandum of Understanding PMA Updates

Transcription

1 Memorandum of Understanding PMA Updates An FAA/Industry Workshop Presented to: MARPA Conf By: Chris Richards, ANE-112 Date:

2 Background Various versions of the concept have been around for many years The most current iteration discussed here was established by the Atlanta ACO in 2005 Focus PMA activities on everyday projects Living document mentality Regarded as a stepping stone to a PMA ODA More companies could use these agreements to increase certification efficiency 2

3 PMA MoU goals Meet FAA safety mission and strategic planning initiatives Manage FAA PMA workload Meet applicant and industry needs Provide qualified holders with the maximum authority to initiate, process, show approvable data and test plans, and complete projects Top down approach for utilizing Discretionary Authority Note that this has undergone a significant expansion 3

4 What does an MoU Allow? Process Consistency Increased Efficiency Defined Methodology Less Guesswork May Reduce Turn Times More Projects, Fewer Delays 4

5 What does an MoU Require? Training Audits MoU is only effective if people can implement it Less FAA involvement up-front Following a Set Process Work quickly with less effort 5

6 PMA business drivers that impact FAA workload Desire for higher market shares Pressure from Airlines to provide OEM $ alternatives Thriving MRO opportunities due to aging fleets Increasing demand of PMAs due to OEM supply chain issues Limitations or loss of OEM support for aging products Increasing number of STCs which breed more PMAs 6

7 Who does it benefit? MOUs must be a benefit both parties How many projects per month or year would be within the scope of the proposal? Past history of projects that would be affected? Dose applicant and FAA have the necessary positive working relationship needed to succeed? If both parties cannot realize a benefit then the process cannot be utilized This determination is made by the ACO and should be communicated to the applicant 7

8 How can an MoU help the FAA? During the initial application and/or kick-off discussion: Identify rough number of expected PMA articles that will meet criteria for the process Establish eligibility determination methods up front Establish material analysis and other testing methods allowed under the process Establish applicant experience within the process and technical aspects Expectations and ability to self audit 8

9 How can an MoU help the Applicant? Establish in writing a consistent approach to the PMA process Specify FAA Designee roles and buy-in Identify key players within the applicant s organization Minimize the need for designees to supplement the applicant s knowledge Better control of project timeline Increased systems-level approach to the PMA Understand the FAA s point of view within the process 9

10 Getting Started Pre-evaluation typical guidelines: Applicant will submit preliminary MoU (draft) FAA and applicant will define project types and scope Simple to complex articles MIDO involvement needed FAA will work closely with the applicant to understand strengths and weaknesses on both sides FAA will review revisions to the draft document Applicant and the FAA will finalize a shadow program schedule 10

11 Getting Started; Cont d Post-evaluation typical guidelines: After MoU approval, Company will work trial projects under a Shadow Program Final Draft MoU Approval by ACO, MIDO and Applicant Company can thereafter work PMA in accordance with approved MoU Project(s) status reporting will be required by FAA FAA will issue notification letters of design approvals and PMA FAA will conduct audits as needed (different levels per MoU) Company or FAA can revise MoU as necessary 11

12 For Part Suppliers with PMA by Identicality Increasing problem with TCH no longer supporting a product design Can you make design changes? VERY limited, if you have PMA by Identicality So what can you do? PMA by Test & Computation is an option, but requires you to go through the full PMA process for each article you want to modify. 12

13 Shortened Path to a T&C PMA New FAA policy does provide a smoother path forward, IF: - You can show that you understand the part and it s effect on the higher level assembly - The part isn t critical to flight safety FAA Policy AIR PM16 Guidance for Recognition and Use of Applicant Showings on Standard Certification Projects 13

14 Applicant Showing Only (ASO) Company is still required to show compliance with all applicable regulations FAA uses discretionary authority to determine what they review - May do an administrative review and follow up with an audit at a later date 14

15 ASO Benefits Less FAA touch points - ACO and DERs don t need to be directly involved step-by-step through the process - Projects can move at a pace dictated by the company, more than FAA workload Test and Comp PMA - Holder can make changes as long as regulatory compliance is maintained 15

16 ASO Requirements Company must still show compliance to all applicable regulations. - Showing of compliance (testing, analysis, reports, etc.) may be periodically audited by the FAA - Supports FAA s goal of transitioning to an oversight organization ACO needs to be confident you can find compliance without their direct involvement. 16

17 What articles fit in the process? Parts typically not available for increased autonomy under the MoU process are: Life limited parts or Critical parts (rotating or static) Primary propulsion main shaft engine bearings Single engine aircraft engine parts whose failure could cause an in-flight shutdown. Engine gearbox parts whose failure would eliminate propulsion required for flight Parts associated with A.D. s Parts requiring ICA independent of OEM ICA Any part whose failure, or whose failure in combination with one or two other failures, could result in a hazardous or catastrophic event. 17

18 Continuing Requirements Under MoU Service difficulty reporting (no change from any other design approval). Must satisfy 14 CFR 21.3 The applicant has increased requirements to selfaudit Suspension/Termination MoU s can be suspended and/or terminated at any time by the FAA Suspension/Termination may be due to: loss of key applicant personnel or a change in FAA oversight personnel Violation of agreement requirements and/or PMA policy It is a privilege and not a right 18

19 Next Steps A company with an established MoU: - Can expand the scope of the MoU - Can better predict project timelines - Can reduce the overhead associated with FAA certification projects This MoU can also be a first step towards PMA ODA. - Optimized balance of workload and oversight between the company and FAA 19

20 In Conclusion The FAA is here to work with the applicant but not for the applicant. You must put your best foot forward You must convince us that we will benefit from an MoU You must show us why you deserve this consideration Types of articles # of relevant projects Positive working history 20

21 Your Experiences Any suggestions? Successes Failures Stuck in limbo 21

22 Questions???? My Contact Information: Chris Richards Project Officer FAA Engine & Propeller Directorate Phone: (847)