New Rules in Development for Aircraft and Parts Manufacturing
By Fred Workley
The Depart-ment of Transportation, Federal Aviation Administration 14 CFR Part 1, 21, and 45 covering production, certification, and parts manufacturing are currently being rewritten and will eventually appear in a Notice of Proposed Rulemaking (NPRM). As is, this draft is expected to establish a single production approval process to replace the various methods of approval that are now used for products, parts, and appliances. The proposal is also expected to separate the design approval and production approval aspects for the present Parts Manufacturer Approval (PMA) parts and Technical Standard Order Authorization (TSOA) articles. Additionally, the proposal would revise the aircraft parts marking requirements to improve traceability of aircraft parts and to revise certain other requirements to better reflect the current manufacturing environment.
The committees indicate that the proposed revisions are needed to standardize the design and production approval processes, to recognize the global nature of aircraft and parts manufacturing, and to help eliminate the potential for installing unapproved parts on FAA type certificated aircraft. These statements result from a cooperative effort of the aviation industry and the FAA through the Aviation Rulemaking Advisory Committee (ARAC).
The draft preamble and rule, as developed to this point in time, has been a committee activity which has relied on both negotiation and consensus building, but it does not represent where the preamble and rule may eventually end up. The committees continue to receive input, and in late November 1997, the FAA AGC (office of the chief council) gave the working group an enormous set of significant comments.
Also, AIR-200 management called a special meeting of the directorate staff which developed a long list of comments — many of which are very significant. These will most certainly change the preamble and possibly the substance of the proposed rule. Both working groups, which are now combined, effectively have a new starting point. It will probably be some time before the final rule draft is available and is in the form of a NPRM which will be then submitted to the ARAC Interest Group for review and forwarding as a final recommendation to the FAA.
Why change it? Currently, four types of production approvals are available under Part 21. They include an Approved Production Inspection System (APIS) (subpart F); Production Certificates (subpart G); Approval of Materials, Parts, Processes, and Appliances, also known as PMAs (subpart K); and Technical Standard Order Authorizations (subpart O).
In part because the rules governing each production approval were developed at different times, each production approval has a different quality assurance system and different procedural requirements. As a result, persons producing the same part to the same design standards under different production approvals, may have different requirements. Though it is primarily the terminology of the requirements that differ rather than the substance, these differences in the regulations have created interpretation differences within the aviation industry and among FAA field office personnel that have resulted in a lack of standardization among types of production approvals.
The FAA does not have evidence that these inconsistencies have resulted in any different levels of safety among products or parts, nor does the FAA have evidence that the design approvals have not always been made to the appropriate airworthiness standard. However, the inconsistencies have led to administrative problems and have contributed to a perceived difference in standards by some individuals in the aviation community.