In recent weeks the FAA has released final versions of two important pieces of guidance. FAA Order 8110.42D – Parts Manufacturer Approval Procedures, which cancels revision C, was published on April 10, and FAA AC 21.303-2 – Application For Parts Manufacturer Approval Via Tests and Computations Or Identicality, was published on April 7. Both of these documents have a direct effect on PMA producers.
MARPA submitted comments addressing issues in these guidance documents in September, 2013. Among the issues MARPA noted was the intended use in Order 8110.42D of the FAA’s Risk Based Resource Targeting Tool (RBRT tool) to prioritize PMA projects. MARPA observed that the RBRT tool as intended relied on subjective assessments of project risk that could result in unfair treatment of certain PMA projects. The FAA agreed that the RBRT tool was not quite ready for prime time and has removed it from the Order. MARPA will remain vigilant, however, as guidance for use of the RBRT tool will be addressed in a future Order.
MARPA also worked with its members to offer comments and feedback to the FAA regarding AC 21.303-2. This new AC consists primarily of guidance to PMA applicants that formerly appeared in the now-cancelled Order 8110.42C. MARPA offered comments addressing the expected sample sizes needed for PMA applications based on test and computation, origins of samples, and discretion for establishing sample sizes. The FAA’s adoption of these comments should better help square the advisory guidance with the realities of industry sampling.
MARPA also commented that references to Order 8110.119 - Streamline Process for Parts Manufacturer Approval (PMA) should be included in both documents to encourage use of the Streamlined PMA process when applicable. We are pleased that the FAA agreed and adopted references to the Order in both guidance documents. We are hopeful that the inclusion of references to Order 8110.119 in both Order 8110.42D and AC 21.303-2 will further promote ACO acceptance and PMA applicant use of the Streamlined PMA process.
Both of these guidance documents are now active. Members should familiarize themselves with the guidance, as it will inform the nature of the application process and the relationship with the FAA and your ACOs. In reviewing the two documents, if you notice anything troubling or that seems out of place, please bring it to our attention so that we can work with the FAA to find a solution. Send your thoughts on Order 8110.42 revision D and AC 21.303-2 to [email protected].
