MARPA Conference 2016

Transcription

1 MARPA Conference 2016 FAA PMA Update Presented to: Conference Attendees By: Robert Sprayberry and Ian Lucas Date: Oct. 27, 2016

2 Topics Why do we support PMA? PMA Metrics Passing the Torch PMA Policy Updates Re-use of data Minor mods and PMA Additive Manufacturing Future Initiatives 2

3 Why does the FAA support PMA? Confidence in FAA PMA Long history of safe approvals dating back to the early 1970 s Often fills a need within the industry for timely and airworthy replacement articles Many PMAs are on articles no longer produced or supported by the OEMs Over 60% of all PMAs are Licensing Agreements Robust and mature process Studied and vetted on multiple occasions since the 1980 s Order originally released in 1995 Operational safety tracking supports our position 3

4 Why does the FAA support PMA? International Acceptance What do the International Agreements say? Nearly ALL foreign CAAs accept FAA-PMA without further showings or validation Many international manufacturers support and supply US TC holders with Licensing Agreement PMAs Several bilateral partners are now working towards implementing their own versions of PMA regulations and guidance materials 4

5 PMAs by Type and Product 5

6 PMAs Issued Over Time Test and Comp

7 Passing the torch As of October 2, 2016 Mr. Ian Lucas has assumed the FAA role as the PMA National Policy focal. He is your new target now so feel free to lob all your questions and comments his way I am still with the FAA and have moved over into a new position within our International Office (AIR-400) I have not left the PMA party totally and will help ensure as smooth a transition as possible My new role will allow me to work on international policy effecting all areas of aviation including PMA 7

8 Alas, a parting gift Intended uses: Fond remembrance Artful expressions Dartboard target 8

9 Who is Ian Lucas? BS and MS from Penn State University in Engineering Science and Mechanics 5 Years as Civilian with US Army, Aviation Engineering Directorate Structural Engr. on Apache and Blackhawk platforms 4 Years in Boston ACO as Structural ASE Certification, COS, Validation, 3 OMTs (TC, STC, PMA) Joined AIR-111 in April 2016 PMA and Commercial Parts Focal 9

10 Re-use of Data Memo AIR PM03 Signed on Reminder to use of discretionary function when reviewing new PMA applications that utilize data from existing PMAs Does not allow PMA transfer Assumes a new and complete application Amount of re-review is a function of the new applicant s competence and standing within the ACO Previous PMAs are still approved and legal for sale and installation per FAA regulations 10

11 Re-use of Data, Cont d Changes in Licensing Agreement status A change in status is allowed and continued sales are allowed within the regs, until minor changes occur and need approval Identicality with licensing to Identicality w/o A major change per 14CFR but it s still identical and therefore the previously approved data is directly applicable to the new application No minor Changes Identicality to Test and Comp A major change per 14CFR that requires full reevaluation from the ACO of the data since reverse engineering data is NOT Identicality data 11

12 Minor Mods and PMA Policy Statement PS-AIR Signed on Oct. 6 th, 2016 Rev. D of the Order clarified the definition of a Modification Article as new to the product via a major or minor change Historic precedence has allowed PMAs for mod articles outside the use of a STC (this is NOT new) Onus of utilizing this guidance is on the applicant NOT to be used to subvert a STC project Will not be reliant on any comparative analysis but rather a general analysis only Will NOT be applicable for most modification articles Supplemental ICAs will almost always be required 12

13 Additive Manufacturing Current data shows limited AM application within the PMA industry Changes to the current regulations is not necessary Policy is being developed for near term release Additional marking requirements are on the table for anyone desiring to utilize AM technology FAA does not desire to limit or infringe on this emerging market FAA is seeking to gain better understanding on trends and usage PMA policy is being developed to align with the AM team s policy and regulatory determination once they are established 13

14 Future Initiatives D Change 1 FY 2018 Incorporate Minor Mods/Additive Manufacturing Adjust for Air Transformation Adjust for Possible Design and Manufacturing Split Clarify PMA of TSOA articles Add International Considerations Special Projects FY 2017 Clarify appropriate uses of Special Projects A Cert project that is not a TC, STC, amended TC, amended STC, or PMA project under 14 CFR 21.8d Should have viable future use on Article or Product 14

15 Contact Info. 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: E: ian.lucas@faa.gov 15

16 16