ARSA RSS Feed ARSA LinkedIn
Contact Us Online Portal

ARSA Questions Issuance of PMA for “Consumables”

In an Oct. 28, 2011 letter, ARSA Executive Director Sarah MacLeod questioned an FAA “policy” regarding issuing Parts Manufacturer Approvals (PMA) for “consumables.” ARSA’s concern spawned from an FAA-issued PMA for a material (specifically a sealant under 14 Code of Federal Regulations (CFR) part 21, subpart K.

ARSA’s letter asserts that 1) materials do not require approval when used in the original production of articles because they are approved as part of the design; 2) it is impossible to fulfill the requirements of § 21.303 with respect to materials or processes because there is no drawing for a material and therefore no associated specifications to establish configuration; 3) there no airworthiness standards applicable to stand alone “materials”; and 4) the regulations do not support issuance of PMA for a material merely because it has an identification (or part) number.

MacLeod requested that the FAA issue guidance to establish the definitions for “material,” “part,” “component,” “appliance” and “process”, and clarify when an article needs to be approved under parts 21 and 43. The Association also asked that any PMAs already issued on materials or processes be withdrawn.

~~~ posted 11/8/11 ~~~



More from ARSA

Ongoing Human Factors Training Series – The Dirty Dozen in Depth

ARSA is growing its library of human factors-related training sessions. ARSA is growing its library of human factors-related training sessions. In addition to the those already available on demand, the…Read More

Home Stretch for “Dirty Dozen in Depth” Training

Now that the Oct. 8 session on “Lack of Assertiveness” and the Oct. 10 session on “Stress” are both available on demand, ARSA’s ongoing human factors training series exploring “the…Read More

ARSA Training

Stay smart. Stay current. Stay out of trouble with ARSA training. The experts from Obadal, Filler, MacLeod & Klein, PLC (OFM&K) – the firm that manages ARSA – provide training sessions and materials…Read More

Hotline Highlight – Erickson Earns Master Mechanic Distinction

The hotline – ARSA’s premier member newsletter – contains news, editorial content, analysis and resources for the aviation maintenance community. All members should ensure they receive their edition the first week of…Read More

Quick Question – Credit Card Fees

ARSA’s management team is preparing the association’s 2020 budget. As it does every year, the team is exploring every way to limit expenditures and is considering the $20,000 that must…Read More
ARSA