PMA Today & Tomorrow Federal Aviation Administration

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Date:

Federal AviationAdministration

PMA Today & Tomorrow

Policy Refinements & Ramifications

Gorham Conference 2009

John Milewski, AIR-110

March 25, 2009

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Topics

• PMA Today• Regulatory Impacts on PMA• Safety Management in PMA• Streamlined PMA Update• Pending Guidance Improvements• ACO Outreach Program

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PMA Today – Two Orders

• Order 8110.42C – Applicant & ACO Guidance– Test & Computation– Identicality without License Agreement

• Order 8120.2F– Production Approval Guidance– STC & License Agreement– Safety Management

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Regulatory Impacts on PMA

• SFAR 88 – Fuel Tank Safety• Part 26 – Continued Airworthiness• Part 21 – Certification Procedures

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SFAR 88 & PMA

• Review of Fuel Tank Safety– Comply with 25.981(a) and (b)– Produce maintenance requirements– Critical Design Configuration Control Limitations

• Implemented via Airworthiness Directives– Fuel Tank CMMs became airworthiness limitations– Restricted use of PMA in fuel systems– AMOC for PMA

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Compliance Approach for PMA

• Show the PMA replacement part has at least equivalent ignition source prevention features as the respective original part listed in the CMM. That is, the replacement part does not increase the ignition source potential above that of the CMM part.

• Also the PMA replacement part does not compromise the ignition source prevention features of the next higher assembly and associated fuel system component.

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Part 26 and PMA

• Retroactive damage tolerance development for STC holders

• Many elect to surrender their STC• What happens to any associated PMA?

– Possible termination– Revise supplement to delete modification parts

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Part 21 and PMA

• Still awaiting final rule……

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Safety Management in PMA

• Order 8120.2F, Appendix C– RBRT Indicators

• Expect Similar Indicators for 8110.42

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RBRT in PMA

InputCertification basis, requirements, criticality

Output Evaluation & compliance findings

RBRT

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Streamline PMA Process Update

• Reconciling Risk/Action disparity• Refine types of non-critical part• Develop level of review matrix

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Policy Clarifications

• PMA on TSO articles• PMA on PMA• Generic PMA AC

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PMA Advisory Circular

• Build on applicant guidance in 8110.42C

• Use a part from a small aircraft as an example

• Advocate an applicant compliance summary table

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ACO Outreach Program

• Workshop format– Type Validation– Change Product– PMA– TSO

• Open discussions on policy & guidance

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Questions?