Aircraft Maintenance

'The first obstacle was determining what type of FAA approval, if any, we needed. Initially (early 1990s) they told us we needed no approval because our product is 'non-hazardous,' i.e. it does not require any alteration of the airframe or engine and it does not function in-flight.'

Reiff explains that a few years later, the FAA said he now needed a PMA, but because the product is considered a 'minor alteration,' it does not require an STC.

He explains that the process of achieving the PMA required first applying for, and obtaining, engineering design approval from the Chicago Aircraft Certification Office. Reiff needed to submit engineering drawings of the parts and to perform tests proving the product would not adversely affect the airworthiness of the aircraft.

AMT asked a few of the PMA manufacturers who have been down the FAA-PMA path a number of times the following question: Your company has a lot of experience with the PMA process. If you were in charge of the PMA process, what would you do differently? Here are their responses:

RAPCO's Mike Lotzer says: 'The FAA should allow their FAA-DERs in the field to have more responsibility and more authority. We all have FAA-DERs that we work with or that are on staff and the FAA-DERs should have the final say or authority to approve the
FAA-PMA.'

Kelly Aerospace's Randy Knuteson says: 'It would greatly benefit our industry if the FAA would provide regular recurrent training sessions to manufacturers who work within the bounds of the PMA process. This training should be both FAA and industry sponsored. Additionally, we believe that the FAA should establish a standardized, in-house FAA-PMA procedure that must be utilized by all ACO engineers and managers and provide manufacturers with a checklist capable of accommodating that PMA cycle for a given product. And finally, the FAA should clarify any misunderstandings within the PMA process so as to eliminate any regional ACO interpretations/misinterpretations of the applicable FARs and Orders. This would assure that all regional ACO offices interpret the FARs and Orders the same.'

Superior Air Parts' senior vice president Tim Archer offers: 'We have been producing PMA parts since 1967 and it's been our experience that the FAA has made every effort to develop understandable guidelines for PMA certification. The biggest challenge facing both the FAA and PMA manufacturers is making sure that the certification guidelines are administered consistently between the various regions and within those regions themselves.