FAA Confirms that UAE Will Accept Non-Critical PMAs with 8130-3 Tags

The FAA has been working with the General Civil Aviation Authority (GCAA) of the United Arab Emirates (UAE) on the subject of acceptance of PMA parts. The FAA has published new guidance about the results of their communications.

The new guidance clarifies the intent of the GCAA PMA policy. The issue that had arisen was that the language in the UAE policy uses the term “and” when it should probably use the term “or.” As a consequence, some people were interpreting this to mean that parts had to be in the TC holder’s IPC AND ALSO a PMA part. Recent government-to-government coordination has confirmed that UAE GCAA intended that their guidance permit PMA parts that are either (i) in the Type Certificate Holder’s illustrated parts catalogue and/or the maintenance data or (ii) accompanied by an 8130-3 tag and also described as non-critical.

Here is the language from the UAE GCAA guidance and it is easy to see how someone could misconstrue the intent:

“Note: The following PMA are eligible for installation on UAE registered aircraft:

i. Parts designed and manufactured in the United States of America under the Parts Manufacturer Approval (PMA parts) system of the FAA can be accepted if the PMA part is released on a FAA Form 8130-3 and specified in the Type Certificate (TC) Holder’s illustrated parts catalogue and/or the maintenance data or specified in a FAA Supplementary Type Certificate (STC) approved by the GCAA; and

ii.Parts designed and manufactured in the United States of America under the Parts Manufacturer Approval (PMA parts) system of the FAA can be accepted if all the following conditions are met:

1.The PMA part is released on a FAA Form 8130-3;

2.The PMA part is a non-critical component (as referred in the “Remarks” Block of the accompanying FAA Form 8130-3); and

iii.The contracting CAMO has authorized the use of PMA as an alternate replacement for the component.”

1 Note from UAE’s Acceptable Means of Compliance (AMC) 145.42(a)(1)(e) of CAR-145 Approved Maintenance Organisations. CAR-145 Approved Maintenance Organisations is available online at http://www.gcaa.gov.aei.

The upshot of the recent government-to-government talks is that industry should read the “and” at the end of subparagraph (i) as if it were an “or”; but industry should also read subparagraph (iii) as if it applied to both section (i) situations and section (ii) situations.

For independent PMA companies seeking to sell independent FAA-PMA aircraft parts into the UAE, this means that the parts need to be released on an 8130-3 tag. It also means that such parts are limited to non-critical PMAs (which is most of them). This clarification makes a big change in what the GCAA will permit to be sold and installed in the UAE.

The FAA policy guidance describing the government-to-government conclusion can be found here.