using the only instructions that the FAA says are acceptable, then there could be no remaining acceptable standards for inspection the parts. This creates a conflict between what the FAA has approved for safety purposes, and what is permitted by contract. Such a tension threatens safety and is therefore unacceptable. The FAA retains the power to influence the method of distribution for ICAs, because the regulatory appendices that describe the minimum standards for such ICAs require the ICA-publisher to have a mechanism for distributing the ICAs and their amendments, and to submit that mechanism to the FAA. This permits the FAA to establish standards for what will be considered acceptable or unacceptable among such distribution mechanisms. The FAA policy will make it clear that it is not acceptable for manufacturers to license their ICAs using restrictive licenses that preclude competition. For example, an engine manufac- turer may not license its ICAs on the condition that the licensee agree not to purchase FAA- approved PMA parts for the engines.
Better Resource Utilization Aircraft parts generally cannot be produced in the United States unless they are FAA approved. This approval helps to ensure
continued application of safety standards. But with an aviation community that is growing faster than the FAA’s budget, how does the FAA keep up with the work? The FAA has released for public comment an Order that would help to streamline the aircraft parts approval process in way that uses risk-based analysis to better allocate approval resources. The Order is entitled “Streamlined Process for Parts Manufacturer Approval (PMA).” The purpose of the order is to create
a streamlined process for the review of applications for non-complex PMAs in order to reduce FAA workload on such projects. Applicants who want to take advantage of this program would have to provide information that is not required by the regulations and they would have to meet requirements that are not required by the regulations, in order to facilitate the expedited review process. In return for applicants meeting those higher standards, the FAA would seek to turn-around those applications in under 30 days.
A key element of the program would be for applicants to assemble their PMA applications for non-complex parts according to a standard published by the Modification and Replacement Parts Association (MARPA), which would make it is easy to identify the
information that supports the compliance showing (and also easy to quickly recognize whether necessary information is missing). The MARPA standard is known as the “Streamlined Program for PMA Applications of Non-Critical Articles Submitted by Experienced Applicants with a Qualifying
Performance Record,” or MARPA 1100. This program is limited to non-complex parts that have a low safety impact; it is intended to permit the FAA to quickly process such applications, so that the FAA can then better focus their review resources on the parts and products that are more complex and that are more likely to raise airworthiness issues. This new focus would permit the FAA to use risk-based resource allocation to better focus their limited resources to maximize their ability to support aviation safety. In addition, the FAA is also keeping its docket open to receive comments about their proposed sequencing policy. The are welcoming ideas about how to best focus FAA resources on the highest safety risks without jeopardizing safety or inhibiting the aviation industry’s ability to show compliance. These aren’t the FAA activities that tend to make the headlines, but all of them are examples of the detail-level work that the FAA (and other regulatory authorities) do every day to keep aviation safe. AM
Aviation Maintenance |
avm-mag.com | February / March 2012 47
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