More PMAs may be coming, but the FAA regulatory path is long and difficult

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The forecast of increases in the PMA market, almost 8% over the next five years, as noted in this report, may attract firms with technical aeronautical engineering competence to the field. Clearly there is a strong demand for lower priced aviation replacement parts. Unlike the automotive equivalent of the plane PMA business, there are “barriers” to entry— the FAA process of determining the airworthiness of the product (for which there is no car comparison) plus its production approval.  Further, such a surge in requests for approval is not likely to be matched by an increase in agency staffing to review these difficult applications.

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Unless the submission is accompanied by the original drawings and/or permission from the TC/PC holder, the FAA must determine that the original part and the PMA part are identical. Since the TC/PC holder asserts that its drawings are proprietary, it is obviously problematic to show that both have the same design and form/fit/function. The reverse engineering, laser reproduction technology and 3D printer manufacturing may minimize that challenge, but not all field offices have the confidence/ competence to accept that proof.

While technically the FAR Part 21 Subpart K (§21.301–§21.320) process is not “competitive,” it is not unusual for the OEM to become aware of the PMA request and do all to deter the “replication” of its part. Such defense efforts are not completely paranoid. The whole SUP campaign by the FAA and industry reflects concerns that “knock off” products may be responsible for failures for which there can be no attribution for the unairworthiness.

Similarly, the precision of the dimensions (interior and exterior) defined by the new technology of reverse engineering is absolutely accurate. That replication of the drawings does not capture the manufacturing processes and for some critical parts (i.e. components  subject to extremely high temperatures or stress), the techniques are essential to their capacity to endure those conditions AND the methods/sequences/etc. are not intuitive.

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Once past that hurdle, the next issue is personnel related. The aircraft certification service is already insufficient to review the basic work. The existing imbalance between TCs in the ACO inboxes and their work product has been brought to the repeated attention of Congress and even precipitated a very innovative proposal to reduce the work load of Part 23 grants. (NOTE: even the processing of that NPRM is delayed.)

The forecast of more PMA applications will exacerbate an already slow certification process. The demand may be there but the capacity to review as well as the complexity of the review may not be able to meet this PMA surge. It is well worth the time and money of a PMA new entrant to work with those who understand the tortuous path of the regulatory labyrinth.

 

ARTICLE: Commercial aircraft PMA market set to grow by 2019 according to forecasts

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