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Aircraft Parts, aviation, EASA, International Trade, Manufacturing, Uncategorized

Parts Approval in Europe Becomes a Reality

For years, PMA parts were a uniquely American product. But recent European events may suggest that others will be following our lead. BAE has been focused on obtaining design approval and production approval to create approved independent replacement parts under the European system.

On January 22, Graham Smith and Phil Beard explained how BAE has been obtaining replacement parts approval user EASA standards. They explained that BAE has been able to get European approvals that are very similar to US PMA approvals.

As with FAA PMA, they start with a significant review of a part in order to determine whether it is feasible to reverse engineer and produce the part. They perform a full reverse engineering operation. They develop their own engineering drawings. Like most modern PMA companies, they take special pains to avoid using OEM data to support their analysis in order to make sure tat they are avoiding misuse of someone else’s intellectual property.

Beard feels that the substantiation of these engineering documents is a little different from the U.S. process. He explained that EASA does not allow BAE to use identicality. Instead they must use positive substantiation of compliance with the airworthiness standards. He said that this generally comes from analysis, understanding of the part’s function, and testing.

As with test and computation PMAs in the US, the substantiation process that BAE uses permits them to fully understand the part, which in turn permits them to remedy reliability problems with the original design or make other improvements desired by the customer. Beard offered an example during his discussion; he commented that if service history has shown evidence of unexpected corrosion, then BAE might change the coating in order to better protect against corrosion.

BAE has made good use of its Design Organisation Approval (DOA) system, which allows BAE to operate under a government-controlled system in order to make findings of compliance up which the government can rely (similar to the ODA system in the United States). Smith and Beard affirmed that this system has been invaluable to their parts approval efforts.

BAE’s initial efforts appear to be largely focused on parts for Regional Jet Aircraft; but they are approved and willing to undertake work on all fixed-wing aircraft types.  This an exciting development for international trade in civil aircraft parts.

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.

Discussion

2 thoughts on “Parts Approval in Europe Becomes a Reality

  1. Jason,

    Thank you for the kind words that you’ve written which are all very positive. One thing I would like to point out is that we’re not just focused on parts for Regional Jet Aircraft but are approved and willing to undertake work on all fixed winged aircraft types.

    If anyone would like to further discuss any “Replacement Part” issues please feel free to contact myself philip.beard@baesystems.com

    Phil Beard

    Posted by Philip Beard | January 27, 2014, 5:02 am
  2. Phil – Sorry, you had mentioned that in your presentation. I have updated the main test to reflect the full breadth of your DOA approval.

    Posted by Jason Dickstein | January 27, 2014, 11:52 am

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