Proposed Repair Station Rule Could Interfere with Repair of PMA Parts

Today, the FAA issued a significant new proposed rule for repair stations. One of the elements that would be updated is the ratings system for repair stations.The proposed changes could have an unintended effect of limiting the ability of the repair station industry to repair PMA parts.

One significant difference is that FAA is proposing a new “Component” rating that would replace the Radio, Instrument, and Accessory ratings. The proposed “Component” rating would allow repair stations to work components that are not installed on an airframe, powerplant, or propeller (bench work). A repair station with a Component rating would be required to have an Airframe, Powerplant, or Propeller rating to install components or appliances. The FAA expects that such a product-level rating would be limited to only installation and removal. The preamble to the rule states that the FAA expects that Component-rated repair stations would have a list of their components in their operations specifications. In light of the difficulty now faced by some repair stations in amending their operations specifications, keeping the component list in the op specs would likely make it very difficult for a component repair station to add new components to their list of permissible components, which in turn would probably cause many smaller component shops to stagnate as new products come out but the operations specification amendment process limited their ability to add them as capabilities.

For PMA parts, this could raise an interesting difficulty. Even though most PMA parts are maintained in exactly the same way as the OEM corollary part, a repair station might not be permitted to maintain the PMA part if the part was not on its operations specifications. Because the population of PMA parts is smaller than the population ofOEM parts, it is reasonable to believe that some repair stations will not go through the op spec amendment process to add a PMA part number to their operations specifications.

This would have the unintended effect of decreasing the repair stations that are legally permitted to repair a PMA part, even though they are technically qualified.

The FAA will accept public comments on the proposed rule through August 20, 2012. Comments should reference FAA Docket Number “FAA–2006–26408.”