The FAA released final versions of two important pieces of guidance: FAA Order 8110.42D Parts Manufacturer Approval Procedures, which cancels revision C; and FAA AC21.303-2 Application For Parts Manufacturer Approval Via Tests and Computations Or Identicality. Both have a direct effect on PMA producers.
The Modification and Replacement Parts Association (Marpa) filed comments on the documents and worked closely with the FAA to ensure the final versions of the guidance accurately reflect the nature of the manufacturing industry, are minimally burdensome and could be implemented objectively, while at the same time achieve the ultimate goal of improving aviation safety. Among the issues Marpa noted was the intended use in Order 8110.42D of the FAA’s Risk-based Resource Targeting Tool (RBRT tool) to prioritize PMA projects. Marpa observed that the RBRT tool as intended relied on subjective assessments of project risk that could result in unfair treatment of certain PMA projects. The FAA agreed that the RBRT tool was not quite ready for prime time and has removed it from the order.
Ryan Aggergaard, Marpa associate counsel, told AIN, “One important result was the inclusion in the guidance documents of the relatively new Streamline Process for Parts Manufacturer Approval [PMA]. This process allows companies with proven safety systems to obtain expedited processing of applications for the manufacture of non-safety-significant parts, those parts whose failure would have no effect on the continued safe operation of an aircraft.The process allows companies with proven safety records to bring aftermarket replacement parts [known in the industry as PMA parts] to market more quickly, and allows the FAA to focus its limited resources on more safety significant projects.
“As with any new initiative, adoption of the Streamline Process has been slow; it is hoped by including reference to the process in the new manufacturing guidance that manufacturers of non-safety-significant PMA parts will take advantage of the expedited application processing, and that regional FAA offices will encourage applicant use of the Streamline Process to more effectively leverage the FAA’s resources.”
Both documents are now active and Marpa asks members to familiarize themselves with the guidance as it explains the nature of the application process and the relationship with the FAA and its aircraft certification offices. Marpa asks interested parties to send their thoughts to email@example.com if they notice anything troubling or that seems out of place.