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This category contains 136 posts

Demonstrating Eligibility

PMAs are unique, in that they are production approvals that also inherently include an eligibility (an installation for which the PMA is eligible).  The PMA application must identify the product onto which the PMA part will be installed (14 C.F.R. § 21.303(a)(1)).  Before 2009, the installation eligibility was required to be printed on the PMA … Continue reading

FAA Issues Draft “Sample Size” Advisory Circular that Would Apply to PMA, STC, and RS-DER applications

The FAA has issued for comment a draft Advisory Circular focused on sample size for statistical analysis in PMA applications. As many of you remember, there was a draft on statistical analysis issued several years ago. MARPA objected to that draft because it implied that every PMA application needed to be based on statistical analysis, … Continue reading

FAA is Updating Alternative Methods of Compliance (AMOC) Guidance

The FAA has released for comment Draft Order 8110.103C. This is an update to the Alternative Methods of Compliance (“AMOC”) guidance. AMOC are typically used when an airworthiness directive (“AD”) provides one resolution to a safety problem, but the AMOC applicant has another approach that achieves the same level of safety. One example would be … Continue reading

FAA Issues Revised Production Approval Guidance for Public Comment

The FAA has released for comment an updated draft of 8120.22B (Production Approval Procedures). It is open for comment through April 21, 2025. A cursory review shows that the in-line sample documents have been removed from the PMA section. This is an opportunity to ask the FAA to address some industry concerns, like directions that … Continue reading

FAA Publishes Risk Assessment Guidance for Public Comment

The FAA has published for comment a draft Transport Airplane Risk Assessment Methodology (“TARAM”) Handbook. They have also published a corollary draft policy statement. Both are currently available for public review and comment. The two documents are meant to support risk assessment required by SMS rules, but (1) they are useful for performing risk assessment … Continue reading

MARPA issues White Paper on Illustrated Parts Catalogs, PMA and Copyright Law

MARPA has published a white paper explaining the intellectual property ramifications of sharing a page from an illustrated parts catalog in support of an FAA-PMA application. In order to produce an aircraft part in the United States, the producer typically needs to obtain design and production approval from the Federal Aviation Administration (FAA).  A parts … Continue reading

Can FAA Production Oversight Be Improved?

Section 314 of the FAA Reauthorization Act requires the FAA to examine its production oversight, including the risk-based decision making approach to allocation of manpower to facility oversight.  This affects the oversight decisions made by FAA Certificate Management Sections (previously known as MIDOs). This is a potential opportunity to influence the system for FAA audits … Continue reading

Minor Changes to FAA PMA Policy

This morning, the FAA circulated Change 2 to the FAA Order 8110.42D. FAA Order 8110.42 is the internal FAA order that tells FAA employees how to process PMA applications. It has been very important for PMA applicants to read it in order to now how to assemble a PMA application so that it is acceptable … Continue reading

Should MARPA Comment on Part 25 Draft ACs?

Back in December, the FAA published the System Safety Assessments NPRM. Along with that publication was issued a raft of draft advisory circulars related to specific provisions of Part 25 (Airworthiness Standards for Transport Category Airplanes). Those draft ACs are: Comments on each of these draft ACs is due April 24, 2023. The MARPA Technical … Continue reading

FAA Examines the Changed Product Rule

Yesterday, the FAA announced the availability of a Report from the from the Changed Product Rule International Working Group (CPR IAWG). The report provides recommendations related to changes to the way that the Changed Product Rule would be used and managed in FAA certification and approval processes. These changes are likely to affect MARPA members … Continue reading