production approval). FAA Inspector Carlos Grillo was an important participant at the FAA training session. He reminded attendees of important points and gave useful answers to audience questions. But his most important contribution came at the end, when he summarized the day’s meeting with text from an FAA Chief Counsel’s Opinion Letter that states: Before a part may be approved or accepted for use on a type certificated aircraft the airworthiness of that part must be established. One method of accomplishing this is to establish positive traceability to the production approval holder and then determining that the airworthiness of the part has not been compromised. New production parts are approved for use on type certificated aircraft if they are produced pursuant to a parts manufacturer approval or otherwise meet the production requirements of 14 CFR § 21 J03(b). A modification or replacement part produced under a PMA must contain detailed marking information that identifies the part as PMA produced, identifies the producer, and identifies the part number as well as the product on which it is eligible for installation. See 14 CFR § 45.15. New production parts sometimes may be accompanied by identifying
documentation from the manufacturer such as a shipping document, a manufacturer’s certificate of conformance or material certification, or an FAA Airworthiness Approval Tag, Form 8130-3 evidencing that the part conforms to its design data and is airworthy. In the absence of identifying documentation, the markings required by § 45.15 may suffice to identify the origin of the part. If both the markings and other identifying documentation are absent the airworthiness of the part must otherwise be established. If positive traceability to the production approval holder cannot be made, the part may be submitted for inspection and testing to determine conformity. Once inspection and testing results confirm that the part conforms to its type design and is in a condition for safe operation, the part may be considered acceptable for use on a type certificated aircraft.
I underlined the sentence in the FAA opinion letter about part markings. Regulated markings, like PMA markings, are extremely useful to identify a part as having come from a production approval holder (like a PMA holder). This makes new PMA parts more exportable, because it is easier to issue an 8130-3 tags for them, even in the absence of documentation.
I am a firm believer that a primary culprit behind many of the industry’s problems is inadequate or incorrect information. Most in the aviation industry want to comply with the regulations and want to be safe. The few bad actors are easily squeezed out by the good actors. But when the standards are not well understood, then there is tremendous room for unintentional non-compliance. When we know what to look for, we are able to root out the fraudulent actors and put them out of business. Thus, two important solutions to the industry’s issues are education and dialogue. The South Florida FSDO did all of the right things today by sticking to the regulations and educating the South Florida community about the standards that apply to documentation of aircraft parts with export 8130-3 tags. The FAA pledged to provide training session like this for the South Florida DAR community on April 3. That training session is supposed to be focused on the same issues as the public session. Most importantly, that April 3 session will echo the notion that back-to-birth traceability is not required, and that part markings or other documentation can provide adequate evidence the part was produced under a production approval. AM
Aviation Maintenance |
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