Gorham-Technical Workshop Series PMA’s Gorham-Technical Workshop Series FAA PMA – OLD 21.303 /NEW 21.303 RULES Presentation By DOMINICK P. DACOSTA C.O.O. DERS GROUP SVC INC FAA DER-T/RS-DER FAA DAR-F March 30, 2011San Diego, CA 1 1

FAA DER DISCLAIMER The Federal Aviation Administration is not in any way responsible for the data, or the opinions presented in this presentation. The opinions and data presented herein are the those of the presenter. The audience is responsible to confirm all data, relative to FAR’s, Orders, and Advisories for accuracy and being the current revisions. The FAA Delegate’s that function as a DER is defined in FAR 183, and FAA Orders 8100.8C & 8110.37D FAA data may be obtained on Fed world, at www.fedworld.gov FAA Disclaimer 2 2

FAA PMA BY ASSOCIATED MEANS 14 CFR Part 21.303….. Workshop Syllabus General Understanding of what is a PMA really When and Why the PMA rules came into being What are the ways to obtain PMA’s Identicality ID by License ID by Design ID by Associative means Test and Computation General Analysis Comparative Analysis Testing The Process to obtain a PMA Logical Flow Chart The Data Linkage 3

About your Instructor Dominick P. DaCosta FAA DER-T Engines Chart E, Powerplant Chart B, Systems Chart C1, Structures Chart A ~ PMA ID Findings Authority & Major Repair/Alterations Multiple Use Authority & RS-DER Authority. FAA DAR-F ~ Class I, II, and III Parts . 28 years Aerospace Manufacturing Engineering 18 years Engine/APU Maintenance & Repair Engineering Worked with GE, P&W, Textron/Lycoming, Rolls Royce, Honeywell APU, Garrett Engine, Bendix Fuel Cntrls/Brake/LG, CTL Inc., United Airlines, CRT, American Airlines, Exotic Metals, Soundair, Lufthansa, MTU, Alitalia, Air France FedEx, Iberia, ITT, Hamilton Std., Parker, Rexnord, SR Technics, ACS, Eaton, SW Airlines and others. ASNT Level III Since 1976~2010 Licensed FAA A&P Mechanic Certified by National Institute for the Certification of Technologist [NICET~NSPE] Senior Welding Engineering Technologist ~ 1979 ~ 2012 Indiana University - BGS Ohio State University - Welding Engineering Certification Program Massachusetts Institute of Technology - Micro Mechanics Program Kings Aeronautical Institute of Technology – Powerplant Technology Instructors Background 4 4

Acronym’s 5

What is a PMA ? Overview of the FAA PMA VIEWS A PMA [Part Manufacturing Authority] Is A Modifications and Replacement Part or commonly referred to as a (PMA)! PMA is one of the eleven (11) ways the FAA uses to control and approve replacement or modification parts manufactured for and installed on a Type Certificated Product following its initial Airworthiness Approval. 6

Key Amendments to the PMA Regulations Historical significance of the PMA Regulation’s amendments Key Amendments to the PMA Regulations Amendment 21-38 issued May 19, 1972 Revised Part §21.303 by adding paragraph (c)(4) which states in part that a PMA may be obtained by Identicality. Amendment 21-41 issued Dec. 4, 1974 Deleted the requirement that a person who holds a PMA must be the manufacturer of the part covered by the PMA. Based on this Amendment a distributor may be the PMA holder providing the distributor has a “Fabrication Inspection System” in place that meets 14 CFR Part 21.303. So we have had PMA Identicality Parts for over 26 years! 7

Where are PMA’s Manufactured [Held]? All PMA’s to date are held and controlled by U.S. based companies! Ref: FAA Order 8110.42C Chapter 3b “Undue Burden” b. Confirms Location of Manufacturer. If the FIS is outside the United States, we at the FAA will not issue or expand a PMA unless regulatory oversight places no undue burden on us. Work with headquarters, Production and Airworthiness Certification Division (AIR-200), to determine if the oversight poses an undue burden. See Order 8100.11, Developing Undue Burden and No Undue Burden Decision Papers Under 14 CFR Part 21, for more details. 8

Can a PMA PAH sub contract manufacturing tasks to vendors located outside the USA? However, just like TC, TSO & STC’s all PMA companies can, If done in accordance with FAA approved procedures, sub-contract any of the manufacturing to qualified vendors with FAA MIDO agreement. Usually the requirement will be two the these elements: The location of the Vendor should be in a country that has a Bi-lateral agreement with the FAA. That you have an acceptable auditing procedure of work performed at vendor. 9

FAA QUALITY SYSTEM REQUIREMENTS NOW but change after 4-16-2011 FAA-PMA Fabrication Inspection System(FIS)‏ FAR §21.303 (h)‏ (1) Incoming material used in the finished part must be as specified in the design data. (2) Incoming materials must be properly identified if their physical and chemical properties cannot otherwise be readily and accurately determined. (3) Materials subject to damage and deterioration must be suitably stored and adequately protected. (4) Processes affecting the quality and safety of the finished product must be accomplished in accordance with acceptable specifications. (5) Parts in process must be inspected for conformity with the design data at points in production where accurate determination can be made. Statistical quality control procedures may be employed where it is shown that a satisfactory level of quality will be maintained for the particular part involved. (6) Current design drawings must be readily available to manufacturing and inspection personnel, and used when necessary. (7) Major changes to the basic design must be adequately controlled and approved before being incorporated in the finished part. (8) Rejected materials and components must be segregated and identified in such a manner as to preclude their use in the finished part. (9) Inspection records must be maintained, identified with the completed part, where practicable, and retained in the manufacturer’s file for a period of at least two years after the part has been completed. FAA QUALITY SYSTEM REQUIREMENTS NOW but change after 4-16-2011 Approved Production Inspection System (APIS)‏ FAR §21.125 Establish a Material Review Board (1) Incoming materials, and bought or subcontracted parts, used in the finished product must be as specified in the type design data, or must be suitable equivalents. (2) Incoming materials, and bought or subcontracted parts, must be properly identified if their physical or chemical properties cannot be readily and accurately determined. (3) Materials subject to damage and deterioration must be suitably stored and adequately protected. (4) Processes affecting the quality and safety of the finished product must be accomplished in accordance with acceptable industry or United States specifications. (5) Parts and components in process must be inspected for conformity with the type design data at points in production where accurate determinations can be made. (6) Current design drawings must be readily available to manufacturing and inspection personnel, and used when necessary. (7) Design changes, including material substitutions, must be controlled and approved before being incorporated in the finished product. (8) Rejected materials and parts must be segregated and identified in a manner that precludes installation in the finished product. (9) Inspection records must be maintained, identified with the completed product where practicable, and retained by the manufacturer for at least two years. (10) Materials and parts that are withheld because of departures from design data or specifications, and that are to be considered for installation in the finished product, must be processed through the Materials Review Board. 10

There are two types of PMA’s by Rule and by Order MAJOR – PMA – Developed from an STC. Invoked under 14 CFR Part 21.95, & 21.97, and guidance given under Order 8110.4C. This PMA which is developed from a STC is a Major Change Designed Component. When this STC-PMA is installed you should follow 43 Appendix B, and issue to the TC product a Form 337, and the 8130-3 should be annotated in Box 13, that it is a Major Design Change Component, in some Bi-laterals this statement is mandatory. MINOR – PMA – Developed from a TC or TSO sub component which does not go beyond 14 CFR Part 21.93, and is considered under Order 8110.42C as a minor change to the original TC or TSO. With the exception of LLP’s most Bi-laterals allow the use of these types of PMA’s without restrictions or re-validations. Only a 8130-3 be executed upon installation to a TC product. Note: Licensed PMA on LLP’s are normally accepted without restriction in most Bi-laterals.

A PMA [Parts Manufacturing Authority] therefore is a specific way to obtain FAA approval to replace or modify a component to be installed onto a Type Certificated Product. There are two (2) fundamental ways to apply for a PMA. Identicality [Which has three (3) subsets] Identicality by License Agreement Identicality by Design without a License agreement Identicality by Associative Means [OCM evidence] Test & Computation Method [Which has three (3) subsets] Comparative Analysis Method General Analysis Method Testing

PMA ID PMA T&C PMA License Design PMA ID by Association Comparative Analysis General Analysis Testing

Basic Requirements to Obtain a PMA 1. Fabrication Inspection System (FIS) per FAR §21.303(h)‏ 2. Design Approval From: Aircraft Certification Office (ACO)‏ 3. Production Approval From: Manufacturing Inspection District Office (MIDO)‏ These requirements are defined in Order 8110.42C Chapter 2 What to expect from the applicant 14

FAA ORDER 8110.42C PMA Approval Procedures, Chapter 2

How many different ways can you obtain an APPROVED part? The definition of APPROVED part is found in several regulations and FAA Orders and AC’s… Here are the 11 [Eleven ways] to obtain an approved Part that can be installed onto a type certificated product [Airplane, Engine or Propeller] 16

FAA HAS AMENDED CERTAIN CERTIFICATION PROCEDURES SUMMARY: The FAA is amending its certification procedures and identification requirements for aeronautical products and articles. The amendments will update and standardize those requirements for production approval holders (PAHs), revise export airworthiness approval requirements to facilitate global manufacturing, move all part marking requirements from part 21 to part 45, and amend the identification requirements for products and articles. The intent of these changes is to continue to promote safety by ensuring that aircraft, and products and articles designed specifically for use in aircraft, wherever manufactured, meet appropriate minimum standards for design and construction. As a result of this action, the FAA's regulations now better reflect the current global aircraft and aircraft products and articles manufacturing environment. DATES: This rule is effective April 14, 2010.

Background To The Rule Changes: Over the last several decades, the aircraft manufacturing industry has evolved significantly. Years ago, most transport category aircraft were manufactured in the United States. A typical business model consisted of a production certificate (PC) holder with a relatively small number of suppliers. Today, the number of aircraft manufacturing suppliers has increased dramatically. Conversely, through the years, the aircraft industry has seen a steady decline in the number of U.S.- based transport category aircraft manufacturers. Those manufacturers, who once predominantly oversaw the production of replacement articles for their aircraft, now witness the ever increasing production of replacement and modification articles by independent parts manufacturers. Suppliers, including parts manufacturers, were located mainly in the United States decades ago; now, they are located all over the world. Suppliers are manufacturing greater percentages of aircraft products and articles. As a result, aircraft are now manufactured in an increasingly global environment.

BACKGROUND CONTINUED: When the certification rules were first promulgated in 1964 we don’t think the FAA envisioned the rapid growth and globalization of the aerospace industry. This is substantiated by the present numerous International Bilateral Agreements. This rule change incorporate is the FAA's response to the changing dynamics of the aircraft manufacturing industry, and this final rule contains requirements that reflect the current global environment. Evolution of the manufacturing industry prompted the FAA to publish in the Federal Register a notice of proposed rulemaking (NPRM) on ``Production and Airworthiness Approvals, Parts Marking, and Miscellaneous Proposals'' (71 FR 58914, October 5, 2006). Comprehensive changes to certification procedures and identification requirements for aeronautical products and articles

In general, the FAA proposes to: Standardize quality system requirements for all Production Approval Holders (PAH) Require PAHs, including those producing under Type Certificate, to mark all articles, including sub-assemblies and components Require PAHs to issue airworthiness approvals for aircraft engines, propellers, and other aviation articles; 4. Require PAHs to create a certifying staff to issue those approvals; and 5. Revise export airworthiness approval requirements to facilitate global manufacturing.

PRIMARY AREAS BEING AMENDED BY THE NEW 21 RULE CHANGE List of Amended Rules Change Subjects: 14 CFR Part 1 “General Definitions” 14 CFR Part 21 “Production Aircraft, Aviation safety, Exports, Imports, Reporting and recordkeeping requirements.” 14 CFR Part 43 “Aircraft, Aviation safety, Reporting and recordkeeping requirements” 14 CFR Part 45 “ Parts Marking, Aircraft Identification, Exports, Signs and symbols”

Example Of Definition CFR 1.1, Changes: Approved, unless used with reference to another person, means approved by the FAA or any person to whom the FAA has delegated its authority in the matter concerned, or approved under the provisions of a bilateral agreement between the United States and a foreign country or jurisdiction. Example Of PART 21 Changes -CERTIFICATION PROCEDURES FOR PRODUCTS, ARTICLES, AND PARTS; Removing the word ``Administrator'' and adding in its place the word ``FAA'' wherever it appears. Removing the word ``shall'' and adding in its place the word ``must'' wherever it appears

NEW FAA PART 21 RULES CHANGES TO PMA

FAA REQUIRES AN EVEN PLAYING FIELD FOR PAH QUALITY SYSTEM

FAA HAS INITIATED A GAME CHANGER BY THIS IMPOSITION

Implying Suitability for installation can be grounds for violation

14 CFR Part 21 Sub Part K - NEW Existing Sub Part K 21.301 Applicability 21.303 Replacement and modification parts. 21.305 Approval of materials, parts, processes, and appliances. 21.307 [Deleted.]

Federal Aviation Regulations Certification Procedures for Part 21 Certification Procedures for Products and Parts Defines Eight (8) ways to obtain new parts that are considered to be approved, plus Three (3) special conditions A total of 11 ways. 43 43

New Approved Parts 1. FAR §21.123 Production Under Type Certificate Only (TC)‏ Operate under TC only for 6 months unless extended by the Administrator. 2. FAR §21.125 Approved Production Inspection System (APIS)‏ After 6 months TC holder obtains (APIS) Ref. §21.123 (c) 3. FAR §21.131 Production Certificate (PC)‏ Eligibility for PC Ref. FAR §21.133 a. Current TC holder b. Rights to a TC under Licensing Agreement c. Supplement Type Certificate (STC) holder 44 44

New Approved Parts 4. FAR §21.303 (h)(4)‏ Standard Part A part manufactured in complete compliance with an established industry or U.S.government specification which includes design, manufacturing, and uniform identification requirements. The specification must include all information necessary to produce and conform the part and be published so that any party may manufacture the part. Examples include but are not limited to National Aerospace Standards (AS), and Military Standards (MS). Definition per A/C 20-62D Order 8110.42 Order 8120.10A 5. FAR §21.303 (b)(2)‏ Parts produced by Owner Operator The Owner-Operator controls the design, manufacture, or quality of parts produced. These parts may only be sold to the Owner-Operator who has approved the parts. 45 45

New Approved Parts Imported Parts 7. FAR §21.601 Produced in accordance with an Approval under a Bilateral Airworthiness Agreement (BAA). 7. FAR §21.601 Technical Standard Order (TSO)‏ Parts produced in accordance with a (TSO) authorization issued by the Administrator. 8. FAR §21.303 (a)‏ Replacement and Modification Parts Parts Manufacturer Approval (PMA) Order 8110.42C establishes procedures for the evaluation and approval of Parts Manufacturer Approval. 46 46

Special Conditions for MRP Part Approval 9. Parts sold prior to the issuance of a Type Certificate (Provisioning). A manufacturer with a APIS or PC may ship replacement parts prior to the issuance of TC or STC provided the parts are segregated at their destination and identified as “Not for Revenue Service - Type Certificate Pending”. Ref. Advisory Circular 21-32A. 47

Special Conditions for MRP Part Approval (cont.)‏ 11. Repair Station Production of Replacement or Modification Parts. AC 43-18 Chg 1 Allows Maintenance personnel to fabricate replacement components consumed in the repair when the data for that component has been FAA approved. 48

There are 11 [Eleven] Legal Ways! SUMMARY FAA “Approved Parts” Defined as: Parts which are acceptable for installation on an FAA Type Certificated (TC) Aircraft or other TC products, which have been produced in accordance with the requirements or exceptions of 14 CFR, Part 21, maintained in accordance with parts 43 and 91, and meet applicable design standards. There are 11 [Eleven] Legal Ways! 49

Replacement and Modification Parts FAR §45.15 Replacement and Modification Parts a. Except as provided in paragraph (b) of this section, each person who produces a replacement or modification part under a Parts Manufacturing Approval issued under §21.303 of this chapter shall permanently and legibly mark the part with - 1. The letters “FAA-PMA”; 2. The name, trademark, or symbol of the holder of the Parts Manufacturing Approval; 3. The part number, and; 4. The name and model designations of each type certificated product on which the part is eligible for installation. b. If the Administrator finds that a part is to small or that it is otherwise impractical to mark a part with any of the information required by paragraph (a) of this section, a tag attached to the part or its container must include the information that could not be marked on the part. If the marking required by paragraph (a)(4) of this section is so extensive that to mark it on a tag is impractical, the tag attached to the part or the container may refer to a specific readily available manual or catalog for part eligibility information. PMA Parts are approved when the manufacturer meets the marking requirements of FAR §45.15. 50

What are the Key Steps for PMA Data You need to PROVE, Installation Eligibility [8110.42C] Any combination of two of these will usually be sufficient: [IPC, & ESM, AMM, SRM, MML, SB, or SIL] You need to SHOW, Compliance to ALL applicable Airworthiness Regualtions [8110.42C ], in your design. If the component goes into an engine then all applicable FAR 33 design issues apply etc. [33.4, 33.15, 33.19a, 33.62, 33.63, & 33.75] You need to show that component is NOT critical, or Life Limited [8110.42C + national Policy memo’s] This is accomplished three [3], ways: 1. Perform SDR/AD search, 2. Perform [S&CA] analysis per 23.1309.1C, or 25.1309.1A, 3. Perform comparative analysis of your MRP, against TC Part. [More on this “Criticality assessment”] Prepare a Compliance plan & check list You need to Prove a Test Plan is NOT needed [8110.42C] 51

PMA FLOW CHART 52

What are the Key Steps for PMA Data [continued] Prepare ALL design data [ie. Drawings, sketches, manufacturing & Inspection procedures. Identify outside vendors [especially special or critical processes] You also need to disclose method for controlling quality of these vendors RFC [8120.10] proposal must be planned RFC “Part Conformity” RFC “Installation Conformity” RFC “Special Testing” You must show compliance to 14 CFR Part 45.15 [Part ID/Marking] [8110.42C] Get FAA ACO design approval, and then FAA MIDO manufacturing approval [FIS] that meets 21.303(h). YOU THEN GET A Supplement letter authorized to sell your PMA design parts. Then you could depending on “Criticality” have a “Post PMA” Review by FAA ACO/MIDO 53

FAA & DER Inter-Action & Regulatory Hierarchy It is very important to both applicant and designees to understand these inter- actions, and chain of commands What is chain of command or better put “Hierarchy” between Applicant, FAA, Designee, and the rules, orders, advisories, and policies? Lets look at FAA to Designee relationship first! 54

What Branches of The FAA are Responsible for various Designee’s FAA HQTRS AEG MIDO ACO FSDO ALL DESIGN ENGINEERING DER-T, DER-Y FAR 21, 23, 25, 27, 29, 33, & 39 etc. TC STC PMA TSO Repairs, Alterations DAS, DOA, SFAR 36 NEW PARTS MFG INSP DAR-F, DMIR FAR 21, FAR 45 TC STC PMA TSO Maintenance & Flight Std DAR-T FAR 43, 45 FAR 91, 121, 125 FAR 129, 133, 135 FAR 145 DAS, SFAR 36 55 55

Regulatory Heirarcy Federal Aviation Regulations [LAW][Must Do] FAA ORDERS [Should do] Airworthiness Directives [Should do] Advisories [May do] Notices [May do] Policy Memo’s [may do] 56

Safety Assessment Safety Assessment Definitions (cont’d)‏ Functional Hazard Assessment A systematic, comprehensive examination of airplane and system functions to identify potential Minor, Major , Hazardous, and Catastrophic Failure conditions that may arise as a result of a malfunction or a failure to function. 57

Safety Assessment Critical Parts The criticality of a part is determined after preparation and review of the Safety Assessment (the FMEA). The FMEA presents a clear understanding of the part in question, its function, and its impact to the NHA and end item installation. If a part is determined critical, it must be addressed differently than a “non-critical” part. Places limitations on DER authority Requires ACO to ACO coordination Determination / Evaluation of additional requirements 58

NEW FAA NATIONAL POLICY ON PART 21 The FAA has released changes to 14 CFR Part 21 “Product Rules” These changes will affect 21.303 [Modification and Replacement Parts Rules] PMA Part 43 rules, Part 45 rules and several other airworthiness rules. These changes become permanent and effective April 16, 2011. Notice of rule making has already been published. Several National Policies have been Released with more to follow: AC 21-42, AC 21-43, AC21-44, and Order 8120.17 If you are presently a PAH [PMA holder] your FIS system must be converted from a FIS, to a FAA “Approved” PC Quality by April 16th 2011

SUMMARY OF PMA’s There are Eleven ways the FAA allows parts to be installed unto a type certificated product, and PMA is “ONE” of the eleven ways. After April 16th 2011 there will be no difference between an TCH OEM PAH QA System, and that of a PMA PAH QA system. There are “TWO” types of PMA’s [Identicality], and Design equivalent [Test and Computation]. Effective May 01, 2011, New EASA Bi-lateral allows use of FAA PMA unto SOD USA product without restrictions, and on to EASA SOD, all but LLP without restrictions. New Part 21 rules change “Increases” over-sight on PAH suppliers and vendors.

INFORMATION ON WORKSHOP DATA & COPIES Presentation will be available electronically at : Gorham-Tech.com website. All Referenced FAA materials can be obtained from: RGL.FAA.GOV Any other data can be obtained by sending a request to: DERS-GROUP.COM Anyone attending wishing a CEU / FAA AC65.25C certificate can contact Gorham-Tech and be sure you have registered at with the facilitator for that certificate course request.

QUESTIONS