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Aircraft Parts, aviation, Continued Operational Safety, FAA, Manufacturing, PMA, Policy, Regulatory

FAA Accepts Comments on Streamlined Process for PMA

The FAA has released for a comment an Order pertaining to a fast-track PMA approval process for non-complex parts.  The Order is entitled “Streamlined Process for Parts Manufacturer Approval (PMA).”

The purpose of the order is to create a streamlined process for the review of applications for non-complex PMAs in order to reduce FAA workload on such projects.  Applicants who want to take advantage of this program would have to provide information that is not required by the regulations and meet requirements that are not required by the regulations, in order to facilitate the expedited review process.

This program will permit the FAA to focus their review efforts on the parts that are more complex and the parts that are more likely to directly affect airworthiness of aircraft.  This new focus would permit the FAA to better use its limited resources to maximize their ability to support aviation safety.

This Order references the MARPA standard, which is known as the “Streamlined Program for PMA Applications of Non-Critical Articles Submitted by Experienced Applicants with a Qualifying Performance Record.”

The September draft of the MARPA standard found on the MARPA website is the latest version that we’ve published.  It was not “finalized” but we have had no adverse comments on the September draft. We did not want to finalize our standard until the FAA Order came out for comment to make sure we were consistent with the post-comment Order.  There are some inconsistencies to hammer out (for example, the draft standard permits the FAA to decide what is a reasonable minimum experience based on the experience of the personnel involved, while the draft Order sets a hard standard of four years, so we will want to modify the standard to reflect the FAA’s standards, even if we just say that the FAA’s minimum standards always apply).

You can access the draft standard  directly here:

http://www.pmaparts.org/gvt/MARPA1100_draft.pdf

You can access the FAA’s draft Order directly here:

http://www.faa.gov/aircraft/draft_docs/media/airOrder8110spma.pdf

Also, FYI, I have updated the discussion of the standard on our website and included a link to the FAA’s draft Order:

http://www.pmaparts.org/government/#STD

About Jason Dickstein

Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. Since 1992, he has represented aviation trade associations and businesses that include aircraft and aircraft parts manufacturers, distributors, and repair stations, as well as both commercial and private operators. Blog content published by Mr. Dickstein is not legal advice; and may not reflect all possible fact patterns. Readers should exercise care when applying information from blog articles to their own fact patterns.

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  1. Pingback: Streamlined PMA Guidance – Comment Deadline is Approaching « MARPA - March 13, 2012

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