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SNAFU: Situation Normal, Authorization for FAA Unfunded

After more than a week the FAA remains unfunded. Congress still has not passed a law that authorizes payment of the FAA’s bills. Continue reading →

Why Isn’t the FAA Returning Your Phone Calls?

The FAA Authorization has been allowed to lapse. As a consequence, 4000 FAA employees who are deemed “non-essential” have been furloughed. While the newspapers may call these personnel “non-essential,” in many cases they are the safety professionals who are absolutely essential to continued advances in aviation safety. They are FAA FSDO inspectors and FAA engineers in the field. They are policy-makers in Washington. They are the people who make sure that the FAA continues to provide world-class leadership in safety. Continue reading →

What Does it Mean to be Accredited?

The FAA’s Advisory Circular (AC 00-56A) sets forth steps that are necessary in order for a civil aircraft parts distributor to become accredited. Continue reading →

Restrictive ICA/CMM Licensing Agreements that Preclude the Use of Independent PMA Parts

Many people are talking about restrictive ICA/CMM licensing agreements. These agreements condition access to the ICA or CMM on a licensing agreement that restricts the repair station or air carrier from using PMA parts. In some cases the restriction may be explicit, but in other cases it may be more subtle (like an agreement that forbids use of the OEM ICA for inspecting the PMA part, despite the fact that the FAA has already approved the PMA part with ICA provisions that require continued reliance on the OEM manual). Continue reading →

New Definition of “Parts”

The FAA has issued a new definition of the term “part” in AC 43-18. Although AC 43-18 is the Advisory Circular that provides guidance for Fabrication of Aircraft Parts by Maintenance Personnel, past FAA practice suggests that this definition could ultimately be used for other purposes that could affect Part 21 manufacturing issues. Continue reading →

PMA Statement of Compliance

The FAA regulations now require each PMA applicant to include a statement of compliance with each PMA application. Can the FAA require you to provide additional information in order to meet the requirement of 21.303(a)(5)? Probably not. Continue reading →

Holding the CMM Hostage to an Agreement Precluding Use of PMA Parts

One of our members referred me to a very disturbing component maintenance manual program that appears to make it impossible for a company to comply with the FAA’s regulatory requirements under 145.109 without agreeing to violate U.S. antitrust laws. Continue reading →

International Regulators Discuss Instructions for Continued Airworthiness (ICAs)

At the recent EASA-FAA International Aviation Safety Conference, a group of regulators and industry experts discussed the requirements and regulations surrounding Instructions for Continued Airworthiness (ICAs). They noted that FAA, EASA and TCCA have agreed to work together to come up with harmonized solutions to the issued surrounding ICA. Continue reading →

Manufacturing Processes for Premium Quality Nickel Alloy for Engine Rotating Parts

The FAA has published new guidance concerning nickel alloy engine (rotating) parts. Consistent with the new quality assurance procedures of 14 C.F.R. 21.137, PMA holders will be expected to work closely with their metal suppliers to ensure that smelting operations are performed correctly. Our informal inquiry among manufacturers suggests that many PMA manufacturers are purchasing their metals by specification number and then testing the materials using sampling techniques. They do not typically get involved in direct quality assurance oversight of smelters to ensure that they are smelting correctly. This appears to create a disconnect between the current standard practices and the FAA’s new guidance. Continue reading →

Industry Discusses PMA Part Numbers

A PMA applicant must assigns a part number to the PMA part. The nature of that part number was a topic of discussion at a recent industry meeting, the 2011 Gorham Conference. The discussion focused on the extent to which a PM Apart can resemble (or not resemble) the OEM part number for the OEM corollary part. Continue reading →