PMA’s

Gorham-Technical Workshop Series

FAA PMA – OLD 21.303 /NEW 21.303 RULES
Presentation By
DOMINICK P. DACOSTA

C.O.O. DERS GROUP SVC INC

FAA DER-T/RS-DER
FAA DAR-F

March 30, 2011San Diego, CA

FAA DER DISCLAIMER
• The Federal Aviation Administration
is not in any way responsible for the
data, or the opinions presented in
this presentation.
• The opinions and data presented
herein are the those of the presenter.
• The audience is responsible to
confirm all data, relative to FAR’s,
Orders, and Advisories for accuracy
and being the current revisions.
• The FAA Delegate’s that function as
a DER is defined in FAR 183, and
FAA Orders 8100.8C & 8110.37D
• FAA data may be obtained on Fed
world, at www.fedworld.gov
 FAA PMA BY ASSOCIATED MEANS
14 CFR Part 21.303…..

Workshop Syllabus
 General Understanding of what is a PMA really
 When and Why the PMA rules came into being
 What are the ways to obtain PMA’s
 Identicality
 ID by License
 ID by Design

 ID by Associative means
 Test and Computation
 General Analysis
 Comparative Analysis
 Testing

 The Process to obtain a PMA

 Logical Flow Chart
 The Data Linkage
 About your Instructor
Dominick P. DaCosta
• FAA DER-T Engines Chart E, Powerplant Chart B, Systems Chart C1, Structures Chart
A ~ PMA ID Findings Authority & Major Repair/Alterations Multiple Use Authority &
RS-DER Authority.
• FAA DAR-F ~ Class I, II, and III Parts .
• 28 years Aerospace Manufacturing Engineering
• 18 years Engine/APU Maintenance & Repair Engineering
• Worked with GE, P&W, Textron/Lycoming, Rolls Royce, Honeywell APU, Garrett Engine,
Bendix Fuel Cntrls/Brake/LG, CTL Inc., United Airlines, CRT, American Airlines, Exotic
Metals, Soundair, Lufthansa, MTU, Alitalia, Air France FedEx, Iberia, ITT, Hamilton Std.,
Parker, Rexnord, SR Technics, ACS, Eaton, SW Airlines and others.
• ASNT Level III Since 1976~2010
• Licensed FAA A&P Mechanic
• Certified by National Institute for the Certification of Technologist [NICET~NSPE]
• Senior Welding Engineering Technologist ~ 1979 ~ 2012
• Indiana University - BGS
• Ohio State University - Welding Engineering Certification Program
• Massachusetts Institute of Technology - Micro Mechanics Program
• Kings Aeronautical Institute of Technology – Powerplant Technology
Acronym’s
 Overview of the FAA PMA
VIEWS

What is a PMA ?

A PMA [Part Manufacturing Authority] Is A Modifications and Replacement

Part or commonly referred to as a (PMA)!
PMA is one of the eleven (11) ways the FAA uses to control and approve
replacement or modification parts manufactured for and installed on a
Type Certificated Product following its initial Airworthiness Approval.
 Historical significance of the PMA
Regulation’s amendments
Key Amendments to the PMA Regulations
 Amendment 21-38 issued May 19, 1972
Revised Part §21.303 by adding paragraph (c)(4) which states
in part that a PMA may be obtained by Identicality.

 Amendment 21-41 issued Dec. 4, 1974

Deleted the requirement that a person who holds a PMA must
be the manufacturer of the part covered by the PMA.

 Based on this Amendment a distributor may be the PMA

holder providing the distributor has a “Fabrication Inspection
System” in place that meets 14 CFR Part 21.303.

So we have had PMA Identicality Parts for over 26 years!

 Where are PMA’s Manufactured [Held]?

All PMA’s to date are held and controlled by U.S. based companies!
Ref: FAA Order 8110.42C Chapter 3b “Undue Burden”

b. Confirms Location of Manufacturer. If the FIS

is outside the United States, we at
the FAA will not issue or expand a PMA unless
regulatory oversight places no undue burden
on us. Work with headquarters, Production and
Airworthiness Certification Division (AIR-200),
to determine if the oversight poses an undue
burden. See Order 8100.11, Developing Undue
Burden and No Undue Burden Decision Papers
Under 14 CFR Part 21, for more details.
Can a PMA PAH sub contract manufacturing tasks to
vendors located outside the USA?

However, just like TC, TSO & STC’s all PMA companies can,
If done in accordance with FAA approved procedures, sub-contract any of the
manufacturing to qualified vendors with FAA MIDO agreement.

Usually the requirement will be two the these elements:

 The location of the Vendor should be in a country that has a Bi-lateral
agreement with the FAA.
 That you have an acceptable auditing procedure of work performed at vendor.
 FAA QUALITY SYSTEM REQUIREMENTS NOW
but change after 4-16-2011
FAA-PMA
Fabrication Inspection System(FIS)
FAR §21.303 (h)
(1) Incoming material used in the finished part must be as specified
in the design data.
(2) Incoming materials must be properly identified if their physical
and chemical properties cannot otherwise be readily and
accurately determined.
(3) Materials subject to damage and deterioration must be suitably
stored and adequately protected.
(4) Processes affecting the quality and safety of the finished product
must be accomplished in accordance with acceptable
specifications.
(5) Parts in process must be inspected for conformity with the
design data at points in production where accurate determination
can be made. Statistical quality control procedures may be
employed where it is shown that a satisfactory level of quality
will be maintained for the particular part involved.
(6) Current design drawings must be readily available to
manufacturing and inspection personnel, and used when
necessary.
(7) Major changes to the basic design must be adequately controlled
and approved before being incorporated in the finished part.
(8) Rejected materials and components must be segregated and
identified in such a manner as to preclude their use in the
finished part.
(9) Inspection records must be maintained, identified with the
completed part, where practicable, and retained in the
manufacturer’s file for a period of at least two years after the
part has been completed.
Approved Production Inspection
System (APIS)
FAR §21.125
Establish a Material Review Board
(1) Incoming materials, and bought or subcontracted parts, used in
the finished product must be as specified in the type
design data, or must be suitable equivalents.
(2) Incoming materials, and bought or subcontracted parts, must
be properly identified if their physical or chemical properties
cannot be readily and accurately determined.
(3) Materials subject to damage and deterioration must be suitably
stored and adequately protected.
(4) Processes affecting the quality and safety of the finished product
must be accomplished in accordance with acceptable industry
or United States specifications.
(5) Parts and components in process must be inspected for
conformity with the type design data at points in production
where accurate determinations can be made.
(6) Current design drawings must be readily available to
manufacturing and inspection personnel, and used when
necessary.
(7) Design changes, including material substitutions, must be
controlled and approved before being incorporated in the
finished product.
(8) Rejected materials and parts must be segregated and
identified in a manner that precludes installation in the finished
product.
(9) Inspection records must be maintained, identified with the
completed product where practicable, and retained by the
manufacturer for at least two years.
(10) Materials and parts that are withheld because of
departures from design data or specifications, and
that are to be considered for installation in the
finished product, must be processed through the
Materials Review Board.
There are two types of PMA’s by Rule and by Order
MAJOR – PMA – Developed from
an STC. Invoked under 14 CFR
Part 21.95, & 21.97, and guidance
given under Order 8110.4C. This
PMA which is developed from a
STC is a Major Change Designed
Component. When this STC-PMA
is installed you should follow 43
Appendix B, and issue to the TC
product a Form 337, and the 8130-
3 should be annotated in Box 13,
that it is a Major Design Change
Component, in some Bi-laterals
this statement is mandatory.
MINOR – PMA – Developed from a TC or
TSO sub component which does not go
beyond 14 CFR Part 21.93, and is
considered under Order 8110.42C as a
minor change to the original TC or TSO.
With the exception of LLP’s most Bi-
laterals allow the use of these types of
PMA’s without restrictions or re-
validations.
Only a 8130-3 be executed upon
installation to a TC product.
Note: Licensed PMA on LLP’s are
normally accepted without restriction in
most Bi-laterals.
 A PMA [Parts Manufacturing Authority] therefore is
a specific way to obtain FAA approval to replace or
modify a component to be installed onto a Type
Certificated Product.

There are two (2) fundamental ways to apply for a PMA.

1. Identicality [Which has three (3) subsets]

• Identicality by License Agreement
• Identicality by Design without a License agreement
• Identicality by Associative Means [OCM evidence]

2. Test & Computation Method [Which has three (3) subsets]

• Comparative Analysis Method
• General Analysis Method
• Testing
PMA ID PMA T&C

PMA Comparative
License Analysis

PMA ID General
Design Analysis

PMA ID by
Testing
Association
 Basic Requirements to Obtain a PMA

1. Fabrication Inspection System

(FIS) per FAR §21.303(h)

2. Design Approval
From: Aircraft Certification Office (ACO)

3. Production Approval
From: Manufacturing Inspection District
Office (MIDO)

These requirements are defined in Order 8110.42C Chapter 2

What to expect from the applicant
FAA ORDER 8110.42C PMA Approval
Procedures, Chapter 2
How many different ways can you obtain an APPROVED
part?

The definition of APPROVED part is found in several regulations

and FAA Orders and AC’s…

Here are the 11 [Eleven ways] to obtain an approved Part that can be installed
onto a type certificated product [Airplane, Engine or Propeller]
FAA HAS AMENDED CERTAIN CERTIFICATION PROCEDURES

SUMMARY: The FAA is amending its certification procedures and

identification requirements for aeronautical products and articles. The
amendments will update and standardize those requirements for
production approval holders (PAHs), revise export airworthiness approval
requirements to facilitate global manufacturing, move all part marking
requirements from part 21 to part 45, and amend the identification
requirements for products and articles. The intent of these changes is to
continue to promote safety by ensuring that aircraft, and products and
articles designed specifically for use in aircraft, wherever manufactured,
meet appropriate minimum standards for design and construction. As a
result of this action, the FAA's regulations now better reflect the current
global aircraft and aircraft products and articles manufacturing
environment.

DATES: This rule is effective April 14, 2010.

Background To The Rule Changes:
Over the last several decades, the aircraft manufacturing industry has evolved
significantly. Years ago, most transport category aircraft were manufactured in the United
States. A typical business model consisted of a production certificate (PC) holder with a
relatively small number of suppliers. Today, the number of aircraft manufacturing suppliers
has increased dramatically. Conversely, through the years, the aircraft industry has seen a
steady decline in the number of U.S.- based transport category aircraft manufacturers.
Those manufacturers, who once predominantly oversaw the production of replacement
articles for their aircraft, now witness the ever increasing production of replacement and
modification articles by independent parts manufacturers. Suppliers, including parts
manufacturers, were located mainly in the United States decades ago; now, they are
located all over the world. Suppliers are manufacturing greater percentages of aircraft
products and articles. As a result, aircraft are now manufactured in an
increasingly global environment.
BACKGROUND CONTINUED:

When the certification rules were first promulgated in 1964 we don’t think the FAA
envisioned the rapid growth and globalization of the aerospace industry. This is
substantiated by the present numerous International Bilateral Agreements. This rule
change incorporate is the FAA's response to the changing dynamics of the aircraft
manufacturing industry, and this final rule contains requirements that reflect the current
global environment. Evolution of the manufacturing industry prompted the FAA to publish
in the Federal Register a notice of proposed rulemaking (NPRM) on ``Production and
Airworthiness Approvals, Parts Marking, and Miscellaneous Proposals'' (71 FR 58914,
October 5, 2006). Comprehensive changes to certification procedures and identification
requirements for aeronautical products and articles
In general, the FAA proposes to:

1. Standardize quality system requirements for all Production Approval Holders

(PAH)
2. Require PAHs, including those producing under Type Certificate, to mark all
articles, including sub-assemblies and components
3. Require PAHs to issue airworthiness approvals for aircraft engines,
propellers, and other aviation articles;
4. Require PAHs to create a certifying staff to issue those approvals; and
5. Revise export airworthiness approval requirements to facilitate global
manufacturing.
PRIMARY AREAS BEING AMENDED BY THE NEW
21 RULE CHANGE

List of Amended Rules Change Subjects:

14 CFR Part 1 “General Definitions”

14 CFR Part 21 “Production Aircraft, Aviation safety, Exports,

Imports, Reporting and
recordkeeping requirements.”
14 CFR Part 43 “Aircraft, Aviation safety, Reporting and
recordkeeping requirements”

14 CFR Part 45 “ Parts Marking, Aircraft Identification, Exports,

Signs and symbols”
Example Of Definition CFR 1.1, Changes:

Approved, unless used with reference to another person,

means approved by the FAA or any person to whom the
FAA has delegated its authority in the matter concerned,
or approved under the provisions of a bilateral agreement
between the United States and a foreign country or
jurisdiction.
Example Of PART 21 Changes -CERTIFICATION PROCEDURES
FOR PRODUCTS, ARTICLES, AND PARTS;

Removing the word ``Administrator'' and adding in its place the

word ``FAA'' wherever it appears.

Removing the word ``shall'' and adding in its place the word
``must'' wherever it appears
NEW FAA PART 21 RULES CHANGES TO PMA
FAA REQUIRES AN EVEN PLAYING FIELD FOR PAH QUALITY SYSTEM
FAA HAS INITIATED A GAME CHANGER BY THIS IMPOSITION
Implying Suitability for installation can be grounds for violation
14 CFR Part 21 Sub Part K - NEW Existing Sub Part K
21.301 Applicability
21.303 Replacement and modification parts.
21.305 Approval of materials, parts,
processes, and appliances.
21.307 [Deleted.]
Federal Aviation Regulations

Part 21
Certification Procedures for
Products and Parts

Defines

Eight (8) ways to obtain new parts

that are considered to be approved,
plus
Three (3) special conditions

A total of 11 ways.
 New Approved Parts
1. FAR §21.123
Production Under Type Certificate Only (TC)
 Operate under TC only for 6 months unless extended by the
Administrator.

2. FAR §21.125
Approved Production Inspection System (APIS)
 After 6 months TC holder obtains (APIS) Ref. §21.123 (c)

3. FAR §21.131
Production Certificate (PC)
 Eligibility for PC Ref. FAR §21.133
a. Current TC holder
b. Rights to a TC under Licensing Agreement
c. Supplement Type Certificate (STC) holder
 New Approved Parts
4. FAR §21.303 (h)(4)
Standard Part
 A part manufactured in complete compliance with an established
industry or U.S.government specification which includes design,
manufacturing, and uniform identification requirements. The
specification must include all information necessary to produce and
conform the part and be published so that any party may
manufacture the part. Examples include but are not limited to
National Aerospace Standards (AS), and Military Standards (MS).
Definition per A/C 20-62D
Order 8110.42
Order 8120.10A
5. FAR §21.303 (b)(2)
Parts produced by Owner Operator
 The Owner-Operator controls the design, manufacture, or quality of
parts produced. These parts may only be sold to the Owner-Operator
who has approved the parts.
 New Approved Parts
6.FAR §21.502
Imported Parts
 Produced in accordance with an Approval under a Bilateral
Airworthiness Agreement (BAA).

7. FAR §21.601
Technical Standard Order (TSO)
 Parts produced in accordance with a (TSO) authorization issued by
the Administrator.

8. FAR §21.303 (a)

Replacement and Modification Parts
 Parts Manufacturer Approval (PMA)
 Order 8110.42C establishes procedures for the evaluation and approval
of Parts Manufacturer Approval.
 Special Conditions for MRP Part Approval

9. Parts sold prior to the issuance of a Type Certificate (Provisioning).

 A manufacturer with a APIS or PC may ship replacement parts prior to
the issuance of TC or STC provided the parts are segregated at their
destination and identified as “Not for Revenue Service - Type
Certificate Pending”. Ref. Advisory Circular 21-32A.
 Special Conditions for MRP Part Approval
(cont.)

11. Repair Station Production of Replacement or Modification Parts.

 AC 43-18 Chg 1 Allows Maintenance personnel to fabricate replacement
components consumed in the repair when the data for that component has been
FAA approved.
 SUMMARY

FAA “Approved Parts”

Defined as:

Parts which are acceptable for installation

on an FAA Type Certificated (TC) Aircraft
or other TC products, which have been
produced in accordance with the
requirements or exceptions of 14 CFR,
Part 21, maintained in accordance with parts
43 and 91, and meet applicable design standards.
There are 11 [Eleven] Legal Ways!
 FAR §45.15
Replacement and Modification Parts
a. Except as provided in paragraph (b) of this section, each person who produces
a replacement or modification part under a Parts Manufacturing
Approval issued under §21.303 of this chapter shall permanently and legibly
mark the part with -
1. The letters “FAA-PMA”;
2. The name, trademark, or symbol of the holder of the Parts Manufacturing
Approval;
3. The part number, and;
4. The name and model designations of each type certificated product on
which the part is eligible for installation.
b. If the Administrator finds that a part is to small or that it is otherwise impractical
to mark a part with any of the information required by paragraph (a) of this
section, a tag attached to the part or its container must include the information
that could not be marked on the part. If the marking required by paragraph
(a)(4) of this section is so extensive that to mark it on a tag is
impractical, the tag attached to the part or the container may refer to a specific
readily available manual or catalog for part eligibility information.
 What are the Key Steps for PMA Data

• You need to PROVE, Installation Eligibility [8110.42C]

• Any combination of two of these will usually be sufficient: [IPC, & ESM, AMM, SRM,
MML, SB, or SIL]
•You need to SHOW, Compliance to ALL applicable Airworthiness Regualtions
[8110.42C ], in your design.
• If the component goes into an engine then all applicable FAR 33 design issues apply etc.
[33.4, 33.15, 33.19a, 33.62, 33.63, & 33.75]
•You need to show that component is NOT critical, or Life Limited [8110.42C +
national Policy memo’s]
• This is accomplished three [3], ways: 1. Perform SDR/AD search, 2. Perform [S&CA]
analysis per 23.1309.1C, or 25.1309.1A, 3. Perform comparative analysis of your MRP,
against TC Part. [More on this “Criticality assessment”]
• Prepare a Compliance plan & check list
• You need to Prove a Test Plan is NOT needed [8110.42C]
PMA FLOW CHART
What are the Key Steps for PMA Data [continued]

• Prepare ALL design data [ie. Drawings, sketches, manufacturing & Inspection procedures.
• Identify outside vendors [especially special or critical processes]
• You also need to disclose method for controlling quality of these vendors
• RFC [8120.10] proposal must be planned
• RFC “Part Conformity”
• RFC “Installation Conformity”
• RFC “Special Testing”
• You must show compliance to 14 CFR Part 45.15 [Part ID/Marking] [8110.42C]
•Get FAA ACO design approval, and then FAA MIDO manufacturing approval [FIS] that
meets 21.303(h).
• YOU THEN GET A Supplement letter authorized to sell your PMA design parts.
• Then you could depending on “Criticality” have a “Post PMA” Review by FAA ACO/MIDO
 FAA & DER Inter-Action
&
Regulatory Hierarchy

•It is very important to both applicant and designees to understand these inter-
actions, and chain of commands
•What is chain of command or better put “Hierarchy” between Applicant, FAA,
Designee, and the rules, orders, advisories, and policies?

• Lets look at FAA to Designee relationship first!

 What Branches of The FAA are Responsible for
various Designee’s

FAA HQTRS
AEG

MIDO ACO FSDO

• ALL DESIGN ENGINEERING

• NEW PARTS MFG INSP • DER-T, DER-Y • Maintenance & Flight Std
• DAR-F, DMIR • FAR 21, 23, 25, 27, 29, 33, & • DAR-T
39 etc.
• FAR 21, FAR 45 • FAR 43, 45
• TC
• TC • FAR 91, 121, 125
• STC
• STC • FAR 129, 133, 135
• PMA
• PMA • FAR 145
• TSO
• TSO • DAS, SFAR 36
• Repairs, Alterations
• DAS, DOA, SFAR 36
 Regulatory Heirarcy

Federal Aviation Regulations [LAW][Must

Do]

FAA ORDERS [Should do]

Airworthiness Directives
[Should do]

Advisories [May do]

Notices [May do]

Policy Memo’s [may do]

Safety
Assessment
• Safety Assessment Definitions (cont’d)
– Functional Hazard Assessment
• A systematic, comprehensive examination of airplane and system
functions to identify potential Minor, Major , Hazardous, and
Catastrophic Failure conditions that may arise as a result of a
malfunction or a failure to function.
Safety
Assessment
• Critical Parts
– The criticality of a part is determined after preparation and review of the Safety
Assessment (the FMEA).
• The FMEA presents a clear understanding of the part in question, its
function, and its impact to the NHA and end item installation.
– If a part is determined critical, it must be addressed differently than a “non-critical” part.
• Places limitations on DER authority
• Requires ACO to ACO coordination
• Determination / Evaluation of additional requirements
NEW FAA NATIONAL POLICY ON PART 21

The FAA has released changes to 14 CFR Part 21 “Product Rules”

These changes will affect 21.303 [Modification and Replacement Parts Rules] PMA
Part 43 rules, Part 45 rules and several other airworthiness rules.

These changes become permanent and effective April 16, 2011.

Notice of rule making has already been published. Several National Policies have been
Released with more to follow:

AC 21-42, AC 21-43, AC21-44, and Order 8120.17

If you are presently a PAH [PMA holder] your FIS system must be converted from
a FIS, to a FAA “Approved” PC Quality by April 16th 2011
 SUMMARY OF PMA’s

• There are Eleven ways the FAA allows parts to be

installed unto a type certificated product, and PMA
is “ONE” of the eleven ways.
• After April 16th 2011 there will be no difference
between an TCH OEM PAH QA System, and that of
a PMA PAH QA system.
• There are “TWO” types of PMA’s [Identicality], and
Design equivalent [Test and Computation].
• Effective May 01, 2011, New EASA Bi-lateral
allows use of FAA PMA unto SOD USA product
without restrictions, and on to EASA SOD, all but
LLP without restrictions.
• New Part 21 rules change “Increases” over-sight
on PAH suppliers and vendors.
 INFORMATION ON WORKSHOP DATA &
COPIES

• Presentation will be available

electronically at : Gorham-Tech.com
website.
• All Referenced FAA materials can be
obtained from: RGL.FAA.GOV
• Any other data can be obtained by
sending a request to: DERS-
GROUP.COM

Anyone attending wishing a CEU / FAA AC65.25C certificate

can contact Gorham-Tech and be sure you have registered at
with the facilitator for that certificate course request.
QUESTIONS