ICA is an issue of frequent interest to the PMA community. Whether addressing potentially limiting language in ICA on the use of PMA or fighting to make ICA available to our members and partners in the maintenance community, MARPA regularly engages with the FAA to advocate for the rights of PMA manufacturers and installers of aircraft parts to make sure ICA policy not only ensures safety (always our #1 goal) but also allows the PMA community to innovate, leading to safety and reliability improvements across the industry.
The FAA is presently revising guidance that could impact upon ICA policy related to PMA. Specifically, language related to the “adequacy” of ICA with respect to the installation of a PMA part creates an opportunity for inadvertent mischief. As the MARPA community knows, part of the process of obtaining a PMA involves ensuring that a product’s ICA are applicable to the PMA part, or if not, to provide supplemental ICA for any differences. Previous iterations of PMA guidance required that applicants to provide supplemental ICA when the design approval holder’s ICA were “inadequate.” Although current guidance is silent as to inadequacy of ICA, this adequacy requirement stands to return in the next revisions of the FAA’s guidance on PMA (E.g., Order 8110.42, AC 21.303).
The opportunity for mischief arises when a PMA part is developed for a type design that does not have complete (or “adequate”) ICA, such as a type approved before 1981 (when ICA regulations largely took on their present form). Logically, a requirement that a PMA applicant provide supplemental ICA because the type on which it is to be installed has incomplete or inadequate ICA should be limited to instructions specific to the PMA article. However, a mischievous (or inaccurate) reading of a requirement to submit supplemental ICA when the design approval holder’s ICA are inadequate could hold that the PMA applicant was required to develop (or at least review) the adequacy of the ICA for the entire type. Obviously that is not the FAA’s intent, but stranger readings have happened.
MARPA worked closely with the FAA and Bob Anoll (AIR-631) to ensure that such an expansive reading will not happen when new guidance is issued. MARPA’s technical committee discussed the issue and submitted comments explaining the potential for a misreading and recommending any new guidance clarify that a PMA applicant is responsible only for ensuring adequacy of ICA with respect to the PMA article and its immediate interaction with the product. This should prevent the absurd situation in which a PMA applicant for, say, a PMA windshield finds itself tasked with reviewing the adequacy of the design approval holder’s main landing gear ICA. The applicant would only be responsible for ensuring adequacy of the DAH’s ICA for windshield installation (or developing supplemental ICA related directly thereto).
MARPA is appreciative of the FAA and Mr. Anoll’s collaboration on issues like these and we look forward to reviewing the text of the new policy when it is available for comment. This is just one example of the ways MARPA and the FAA work together to ensure the PMA industry is able to thrive in our mission of enhancing aviation safety and providing excellent savings and service to operators.
If you would like to discover more about how MARPA and the FAA are working together and learn the latest developments in FAA policy and the PMA industry, join us at the MARPA Annual Conference in Orlando, November 3-4. Registration is still open. We hope to see you there!
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