Parts Manufacturing Approval: Negotiating through the PMA process can be daunting but help is available
PAMA News
Parts Manufacturing Approval
Manufacturing Approval
By Michelle Gardner
October 2004
With nearly 2,000 PMA (parts manufacturing approval) holders and more than 200,000 part numbers out there, it is hard to believe that there could be many more opportunities for new products and services. But, a good idea for an improvement to form, fit, and function shouldn't be quickly dismissed. While it can be daunting to take on such a project, there is plenty of help available from FAA and associations such as Modification And Replacement Parts Association (MARPA) in obtaining parts manufacturing approval.
By the numbers
According to Kevin Michaels, principal with AeroStrategy LLC in Ann
Arbor, Michigan, the total market makeup of engine, airframe, and
components available to PMAers is $1 billion out of $13 billion spent on
maintenance materials; of this $1 billion, PMAers garner approximately
$250 million in competitive PMA sales. Current sales of PMA parts is
$200 to $250 million or roughly 20 percent of the total air transport
spares market. While these figures do not include DER repairs or
licensed PMA revenue, with only one-fifth of the market covered it would
appear PMA manufacturers have room to grow.
If AeroStrategy's forecasts pan out, the available PMA market for all segments will double by 2008. Michaels' group cites higher customer acceptance of PMAs with a jump from 40 to 70 percent and an MRO demand growth of nearly 40 percent as the two main drivers affecting such a dramatic shift for the PMA side.
OEMs need not quake in their chocks as even a doubling of the PMA's take still will not alter much the reach OEMs have on the spares market.
MARPA, based in Apache Junction, Arizona, is a nonprofit organization dedicated to promoting the replacement parts industry. George Powell, president of MARPA, works closely with the FAA regarding PMAs, PMA holders, as well as regulations and revisions to those regulations that affect the PMA industry. Powell and the FAA know that PMAs are here to stay but there is still much work to be done to enhance the profile and acceptance of PMA parts.
'Standards for PMA have to be flawless,' says Powell. He explains that if there is a problem, the reaction from an error or failure is immediate and powerful from the NTSB, FAA, and OEMs. Powell offers that the PMA industry is no longer in its infancy with nearly 2,000 PMA holders. MARPA's mission, in part, is to move this maturing industry toward a more universal acceptance in the modification and replacement parts market, but knows there still will be challenges ahead. Currently, Powell is working with the FAA on a revision to Order 8110-42A, the document that drives the PMA process. 'It's a continual process,' says Powell, 'but the major change is readability and project specific certification plan.'
PMA or STC?
So you have an idea you would like to pursue the PMA process but don't
really know where to begin or what you need? The Federal Aviation
Administration's Aircraft Certification Service Products and Services
Home Page www.faa.gov/certification/aircraft
is a good place to start as it covers the definitions and guidelines.
Appendix 3.
PMA Process Flow Chart
Parts manufacturer approval falls under the Code of Federal Regulations Title 14 (14 CFR) Part 21 Subpart K, ' 21.303 FAA Order 8110-42A. Order 8110-42A is a 74-page document that offers detailed explanations, sample letters, and checklists to help work through the process. It also has a flow chart outlining the steps of applying and obtaining a PMA. (Please refer to graphic on page 35).
PMAs came about initially after World War II in response to aircraft manufacturers who did not want to keep making parts for older aircraft. The focus at that time was on designing and developing new aircraft and the older aircraft market was left behind.
A PMA is issued for the production of modification or replacement parts, which includes materials, parts, processes, and appliances.
PMAs differ from a supplemental type
certificate (STC) as an STC is a type certificate issued when an applicant
has received FAA approval to modify an aircraft from its original design.
The supplemental type certificate, which incorporates by reference the
related type certificate, approves not only the modification, but how that
modification affects the original design.
When a PMA is issued to an applicant, the PMA is both a design and
production approval. The PMA holder must adhere to design and production
obligations in order to maintain the approval.
The path to PMA
Robert Reiff, president of Reiff Preheat Systems in Fort Atkinson,
Wisconsin, tells his story on how his company achieved the PMA for its
engine preheat system.
"The first obstacle was determining what type of FAA approval, if any, we needed. Initially (early 1990s) they told us we needed no approval because our product is 'non-hazardous,' i.e. it does not require any alteration of the airframe or engine and it does not function in-flight.'
Reiff explains that a few years later, the FAA said he now needed a PMA, but because the product is considered a 'minor alteration,' it does not require an STC.
He explains that the process of achieving the PMA required first applying for, and obtaining, engineering design approval from the Chicago Aircraft Certification Office. Reiff needed to submit engineering drawings of the parts and to perform tests proving the product would not adversely affect the airworthiness of the aircraft.
AMT asked a few of the PMA manufacturers who have been down the FAA-PMA path a number of times the following question: Your company has a lot of experience with the PMA process. If you were in charge of the PMA process, what would you do differently? Here are their responses:
RAPCO's Mike
Lotzer says: 'The FAA should allow their FAA-DERs in the field to have
more responsibility and more authority. We all have FAA-DERs that we work
with or that are on staff and the FAA-DERs should have the final say or
authority to approve the
FAA-PMA.'
Kelly Aerospace's Randy Knuteson says: 'It would greatly benefit our industry if the FAA would provide regular recurrent training sessions to manufacturers who work within the bounds of the PMA process. This training should be both FAA and industry sponsored. Additionally, we believe that the FAA should establish a standardized, in-house FAA-PMA procedure that must be utilized by all ACO engineers and managers and provide manufacturers with a checklist capable of accommodating that PMA cycle for a given product. And finally, the FAA should clarify any misunderstandings within the PMA process so as to eliminate any regional ACO interpretations/misinterpretations of the applicable FARs and Orders. This would assure that all regional ACO offices interpret the FARs and Orders the same.'
Superior Air Parts' senior vice president Tim Archer offers: 'We have been producing PMA parts since 1967 and it's been our experience that the FAA has made every effort to develop understandable guidelines for PMA certification. The biggest challenge facing both the FAA and PMA manufacturers is making sure that the certification guidelines are administered consistently between the various regions and within those regions themselves.
'The problems that companies entering into the PMA arena encounter are often caused when they try to cut corners in the certification process. That reflects poorly on the company and the PMA industry as a whole, but if you know and understand the regulations, the FAA has proven itself to be a willing and helpful partner in bringing PMA parts to the market.'
HEICO's Val Shelley says: 'We used to joke that the FAA's aircraft certification offices were 'independently owned and operated.' That has improved considerably, but we still encounter FAA offices with practices that are not consistent with standard practices, or no time to review our PMA application. HEICO's been doing T&C PMAs for several decades and we've developed a uniform engineering process across our nine PMA development companies. When we present a T&C package to an FAA office, we're proud of the research and skills that are put into each package. We even have our own research scientists and specialized instruments like scanning electron microscopes, Fourier transform infrared spectrometer, etc. But, when we submit these uniform PMA applications, there seems to be very different criteria for review and approval among the different FAA offices. I'd like to see some consistency.'
'We also had to apply for and pass a Conformity Inspection to prove the product conforms to the drawing and can be installed properly per our instructions,' says Reiff. 'This was a difficult step because I did not own an aircraft at the time, and everyone I knew who did, declined to allow it to be used for this inspection because of a natural reluctance to have an FAA inspector poking around their airplane.' Luckily for Reiff, a generous relative allowed his C-172 to be used as the guinea pig, and the inspection went fine. The next step involved applying for and obtaining approval of the production system and fabrication inspection system (quality control program) from the Minneapolis Manufacturing Inspection District Office (MIDO).
Reiff says the entire process took about a year and that it probably helped that his company had already been selling the product for a couple of years before applying for approval. He offers that the FAA personnel he has dealt with have all been very professional and helpful.
To maintain the PMA, the MIDO through an ACSEP (Aircraft Certification System Evaluation Program), periodically inspects Reiff's facility and audits his fabrication inspection system and records to ensure the company remains in compliance. Any test equipment used must be periodically calibrated by a certified shop and records kept. Any changes made to the products must be submitted for PMA approval.
'My advice to anyone contemplating it is to do your homework first,' says Reiff. 'Compared to a 'normal' business, an aircraft parts manufacturer has some additional obstacles and costs and the businessman needs to determine if the profit potential for the product is worth the hassle and the costs involved. General aviation is a small market and if the type and volume of product you anticipate selling precludes pricing it at a level that allows you to be adequately compensated, then it would be a poor decision to go ahead with it. This factor (and liability) largely explains why aircraft parts cost more than many people feel they should.'
Additional Resources
AeroStrategy LLC
202 E. Washington, Suite 610
Ann Arbor, MI 48104
(734) 821-0220
www.aerostrategy.net
FAA
www.faa.gov
MARPA
320 W. Superstition Blvd.
Apache Junction, AZ 85278
(480) 994-3353
www.pmamarpa.com
Reiff Preheat Systems
P.O. Box 5
Ft. Atkinson, WI 53538
(262) 593-5292
www.ReiffPreheat.com