FAA Releases PMA Policy Revisions for Comment

On July 1 the FAA released for comment drafts of revisions to two policy documents of great importance to PMA manufacturers.  Both documents speak directly to the PMA approval process.

The first is revision D to FAA Order 8110.42 Parts Manufacturer Approval Procedures.  Among other changes, the revision updates the regulatory citations from the latest Title 14 of the Code of Federal Regulations (14 CFR), part 21 rule changes, introduces risk based resource targeting (RBRT) with management options, incorporates directive feedback and clarifies certification office responsibilities under the FAA’s quality management system.

This order describes the internal responsibilities and procedures for approving replacement and modification articles for installation on type-certificated products. The order addresses only the requirements for issuing a PMA; FAA Order 8120.22, Production Approval Procedures, contains the procedures addressing the production activities of manufacturers who produce articles under PMA.

The proposed revision also removes applicant guidance from Order 8110.42D.  The applicant guidance removed from the draft of revision D has been relocated to the other draft document released on July 1: FAA AC 21.303-PMA.

AC 21.303-PMA updates the FAA guidance to applicants for PMA of articles submitted on the basis of test and computation or identicality without a license agreement.  The AC also provides an application and compliance checklist, adds a certifying statement of compliance, provides guidance for assessing an article’s impact on safety and describes how the FAA approves replacement parts for TSO articles.  The AC describes one way, but not the only way, to comply with subpart K of Part 21 of the Federal Aviation Regulations.

Comments on both of these drafts are due September 1, 2013.  Comments on Draft Order 8110.42D should be sent to robert.sprayberry@faa.gov.  Comments on Draft AC 21.303-PMA should be sent to john.milewski@faa.gov.  Whether you file formal comments or not, please share your thoughts and concerns with MARPA Associate Counsel Ryan Aggergaard at ryan@washingtonaviation.com.  MARPA will make every effort to address our members’ concerns in our comments to the FAA.