Manufacturing Regulators& Distributors
Recently, a question was posed to the Airline Suppliers Association (ASA) from a distributor that works closely with several United States manufacturing companies. A manufacturer had obtained PMA on an aviation part. This same company also made similar parts for use with ground support equipment. The distributor's query concerned the separation between the aviation and non-aviation quality systems, and the extent to which this production quality system had to be extended through the quality procedures of the distributor.
Separating Aviation and Non-Aviation Fabrication
It seems that one of the manufacturers with whom the distributor worked was wondering whether the aviation regulations required it to do anything special because it made non-aviation parts in the same facility as the one in which aviation parts were made.
Every FAA production approval requires a quality system that imposes certain minimal controls on the production process. Such controls include recordkeeping requirements. For this reason, there will be specific requirements for any manufacturer's production quality system associated with the aviation parts manufactured under a FAA Parts Manufacturer Approval (PMA).
A PMA manufacturer is required to show that each article manufactured under the production approval conforms to an FAA approved design (the design component of the PMA). Obviously, the manufacturer will need to have some way to separate PMA parts from those that do not meet the design requirements of the PMA; but this should not necessarily imply that non-aviation parts do not meet the same engineering requirements as the PMA parts.
When a manufacturer produces both aviation and non-aviation parts, this does not always require separate production lines. It is possible for the manufacturer to produce non-PMA parts to the same design parameters as those produced under a PMA. From an engineering standpoint, the only difference between the PMA parts and the non-PMA parts would be the markings on the parts - the production line may be split at the part-marking phase, with lots being chosen for PMA marking or other marking, depending on their intended final market. This is a common practice in some facilities that manufacture both civil aviation and military aviation parts.
There may be business reasons for a manufacturer to plan a system that separates parts created under a PMA from those created outside the scope of the PMA. The real decision should take into account liability concerns, manufacturing efficiency, quality concerns, and customer needs.
In at least one case reported to ASA, an FAA representative told the manufacturing company that it was required to keep records of where all of the parts it manufactured were sent to support the claim that certain parts were manufactured without the intent that they be installed on aircraft (and were therefore exempt from the FAA-PMA rules). This "requirement" is not supported by the regulations, even though it may have represented sound business advice for that particular company. Like all "sound business advice" received from a United States Government representative, it is optional. The FAA does not have the power to require a company to keep records concerning non-aviation parts, and no regulation requires a PMA holder to maintain destination records on PMA parts - instead, the regulations require the PMA holder to maintain inspection records on completed PMA parts, which must be kept for two years.
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The FAA has issued a special bulletin reminding the industry that PMA parts are perfectly valid for use, and that competitors’ rhetoric questioning FAA-approved PMA parts is contrary to FAA...