PMA Parts Prevail

FAA establishes legitimacy of PMA parts — Period.


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.

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