The FAA has released a Draft Policy Statement related to Order 8110.42D that is directly applicable to the PMA community. PS-AIR-21-1601 – FAA Order 8110.42D, Parts Manufacturer Approval Procedures – Use of Parts Manufacturer Approvals (PMA) for Minor Modifications to Products establishes FAA policy for “the gray area when a modification to a product does not rise to the level of a major change . . . and the producer of the modification article wishes to sell it in accordance with 14 CFR 21.9.”
The Draft Policy explains that historically there was not a consistent policy for issuing PMAs when the PMA made a modification that did not rise to the level of a major change under the regulations. Confusion existed as to whether a STC was appropriate for a modification article that did not constitute a major change to type design.
The Draft Policy clarifies the FAA’s position that:
PMA is a suitable method to approve an article, and provide for that article’s installation, in cases where the installation would not constitute introduction of a major change in a product’s type design.
The policy goes on to explain that the applicant must be able to identify the change resulting from installation of the article and justify it as not being a major change to the product and have the project ACO’s agreement.
On balance this looks like a positive policy for the PMA industry, clarifying modification PMAs that do not constitute a major change to a product’s type design can be approved through the PMA process and not require a STC. However we would still like to hear from our members to determine if there are any unintended consequences of this policy or ways in which the policy can be made more clear.
Comments on this policy statement are due May 1, 2016, so please email Ryan Aggergaard at ryan@washingtonaviation.com if you have any concerns about this policy or potential effects on the PMA industry.
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