ARSA RSS Feed ARSA LinkedIn
Contact Us Payment 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 The Association also asked that any PMAs already issued on materials or processes be withdrawn.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

ARSA Supports Effort to Increase Part 147 School Flexibility

On April 18, ARSA submitted supportive comments to the Federal Register notice related to a Southern Utah University petition for exemption from the curriculum requirements of Title 14 Code of…Read More

ARSA, Industry Allies Seek Objective Criteria for Operations Specifications

On April 13, a coalition of aviation industry organizations delivered a letter to the FAA seeking objective criteria for adding and reviewing paragraphs to any certificate holder’s operations specifications. The…Read More

House FAA Bill is “At the Gate and Boarding”

After almost a year in limbo, FAA reauthorization legislation is finally on the move again on Capitol Hill. The FAA bill is important because it provides several years of budget…Read More

ARSA at MRO Americas – Seeing the Sights

On April 10-11, Vice President of Communications Brett Levanto returned to Orlando for MRO Americas. During the event, held at the Orange County Convention Center, Levanto facilitated an invitation-only session…Read More

AIR Transformation by Another Name: ARSA Helps Kick Off SOC-ARC

On April 3, the Safety Oversight & Certification Aviation Rulemaking Committee (SOC-ARC) held its initial meeting at the MITRE Corporation in Vienna, Virginia to discuss the committee’s charter and plan…Read More
ARSA