In an attempt to quash anti-parts manufacturer approval (PMA) safety concerns, the FAA released Special Airworthiness Information Bulletin (SAIB) NE-08-40 on Aug. 8, 2008. Wording in some OEM manuals drove the FAA to issue the bulletin as a closing statement in an ongoing argument about the validity of PMA parts.
According to Jason Dickstein, president of the Modification and Parts Replacement Association (MARPA), the SAIB was driven by the FAA’s dismay at the fact that some OEMs were using safety documents for competitive purposes. A MARPA release from Aug. 10, 2008, states that some manufacturers have made commercial statements designed to undermine public confidence in PMA parts.
“Nobody likes competition”
According to Dickstein, the attitude toward PMA parts was very different in the 1990s than it is today. He says that as some larger companies recognized that PMA parts could be a viable threat to their business, people became more reticent to accept them. Efforts to try to disadvantage PMA parts ensued in the Aviation Rulemaking Advisory Committee (ARAC).
“I think that there has been some anti-PMA sentiment in the past,” says Dickstein. “People who didn’t understand PMAs were averse to PMAs because they represented an unknown quality. Over the last decade or so, MARPA, the PMA parts manufacturers themselves, and even some of the government agencies have done a good job cooperatively of better educating the public, particularly the public within the industry, about what a PMA part is.
“Part of the reason the SAIB came out is because the FAA has been under a lot of pressure from OEMs who, quite logically, don’t like PMAs because they’re competition,” says Dickstein. “Nobody likes competition. It’s perfectly reasonable that they are opposed to PMAs, but they’ve been trying to enlist the FAA’s aid. As a consequence the FAA has put a lot of resources into really looking hard at PMAs to see whether the FAA has made a mistake.
“What they found is that the OEMs are starting to put information in their maintenance manuals and their instructions for continuous airworthiness (including the service bulletins) that were anti-PMA,” says Dickstein. “When an OEM puts in their manual that you’re not allowed to put PMA parts in a particular engine, you’re in a quandary. You’re supposed to follow the OEM’s instructions under Advisory Circular 43.13-1A, but 43.13-1B says you can use anything that will safely return something to its original condition.”
In response to OEM concerns, the FAA put its Aviation Safety (AVS) Repair, Alteration, and Fabrication (RAF) Team to work. Its task was to “provide recommendations to close any gaps existing in both current and in-process regulations, policy, and guidance necessary to ensure an acceptable level of safety commensurate with the criticality of affected parts.”
“What they concluded was that what the FAA has been doing is safe, that PMA parts are safe, and a lot of the OEM concerns are competitive, rather than safety-driven,” says Dickstein.
The air carrier barrier
“You have to prove that the quality assurance system is adequate before you get production approval, just like the OEM products are proven,” says Dickstein. “I think that as people begin to understand what the regulatory structure surrounding PMA parts is, those people begin to embrace PMA parts.”
This led purchasers within air carriers to understand that the PMA parts are safe and that, because they represent competition, PMA parts would bring prices down. That caused many air carriers to begin programs to identify and purchase PMA parts.
Dickstein says that British Airways had historically eschewed PMA parts until representatives from Hyco International Inc., a maker of hydraulic cylinders, sat down with them to explain the benefits of PMA parts. This education about PMA parts’ safety assurance “caused British Airways to turn around 180 degrees and begin purchasing PMA parts,” says Dickstein.
Pratt & Whitney was once a vocal opponent of PMA parts, sending letters calling the PMA industry problematic to the FAA. Within five years Pratt & Whitney began offering its own PMA parts on CFM 56-3 engines. Not only does it have PMA parts on CFM 56 engines today, it also has a program to develop more.
“Pratt & Whitney made a decision not to even develop an engine for the 787,” says Dickstein. “Instead, they took the resources that might have gone into developing an engine for the 787 and they put those resources into developing PMA parts for CFM engines. Instead of putting all the investment into creating a new engine, why not just make money off the existing engine and get PMA parts for the existing engine? I think it was a very smart business move on the part of Pratt & Whitney. It also represented a major shift in policy from them having been anti-PMA to them having suddenly become a PMA company themselves.”
Dickstein says that as the marketplace accepted PMA parts more and anti-PMA sentiments less, the air carriers themselves caught wind of the situation. “Air carrier representative are listening to this rhetoric and saying, ‘Hey, those parts are on my aircraft. I know they’re safe,’” says Dickstein. “They’re getting upset at the anti-PMA rhetoric.”
PMA parts are now accepted at the purchasing and quality assurance levels within air carriers because they have conducted investigations. “Air carriers had to investigate them to figure out whether or not they represented a good economic value,” says Dickstein. “When they did that investigation they found that, not only were they a good economic value, but they’re safe.”
According to a draft of FAA Order 8120.2F, “Manufacturing inspection procedures, materials, and/or special processes, such as hardening, plating, or shot-peening are not in and of themselves eligible for PMA.”
A PMA may be obtained for replacement parts for TSO articles that are approved as part of a product type design, provided that installation eligibility to that product can be shown. Approval of a part that would constitute a major design change to the TSO article cannot be done under a PMA and would require a new TSO authorization.
Even critical components can be PMAed in compliance with specific FAA guidance. “In fact, not only can you get a PMA on a critical part, but when you see a PMA on a critical part, chances are that critical part has gone through a level of FAA scrutiny that the OEM part didn’t go through,” says Dickstein.
Manufacturers usually have many designated engineering representatives (DERs) on staff to approve their data. “For critical components, the use of DERs is often times limited or potentially unavailable to the PMA house,” says Dickstein. “Since critical parts are, well, critical, and because of the press and public relations associated with critical parts, the FAA has decided that they’re going to keep a tighter rein on those parts. It can take a lot longer to work those through the FAA. DERs may be less available or unavailable to those applications because of the fact that the FAA is retaining more of the oversight.”
The FAA has to witness all trials of the most critical components. These will never be delegated to a DER. The FAA has to do its own analysis of all the data and make the individual regulatory compliance findings themselves.
The draft for FAA Order 8120.2F also states that once a PMA part has left a PMA holder’s quality system, the holder must establish a procedure to report any failure, malfunction, or defect of the part to the FAA.
The FAA’s final say
According to the FAA AVS RAF Team report from Aug. 6, 2007, all PMA parts “must comply with the applicable airworthiness standards and be repaired, altered, or fabricated such that they conform to the approved or acceptable data and be safe for operation.”
OEM decisions cannot override the word of the FAA. “If the FAA approved a PMA part for use under the current ICAs, the OEM is in no position to tell you that the FAA’s approval is invalid,” says Dickstein.
MARPA says that the FAA expects that the industry will treat its approval of PMA parts with the respect that an FAA decision deserves.
“We are an extremely risk-averse industry,” says Dickstein. “Many industries will go with a new product as long as they don’t see anything wrong with it. Our industry won’t go with a product unless we see everything right with it.”