Join ARSA Ask ARSA Pay ARSA

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 The Association also asked that any PMAs already issued on materials or processes be withdrawn.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

Championing the Industry at MRO Americas

On stage and behind the scenes at the Georgia World Congress Center, ARSA leaned into the 2025 MRO Americas convention theme: Shaping the future of aviation maintenance. Brett Levanto, association…Read More

Weston Award Recognizes Crowley’s Commitment to Learning

On March 20, ARSA recognized Jerry Crowley with its Leo Weston Award for Excellence in Government Service. Crowley is a long time FAA aviation safety inspector who was a professional…Read More

Industry Requests More Time to Comment on FAA Order 8130.21J

Update: On April 17, the FAA notified the industry signatories that it had extended the comment deadline to June 6, 2025. On March 28, ARSA joined 11 ally trade associations…Read More

Small Biz Recruitment by Repair Stations

The National Skills Coalition and its partner organization Business Leaders United invite the repair station community to support a study of small and mid-sized business recruiting practices. The study seeks…Read More

Maintenance Industry Surpasses Pre-Pandemic Peaks, Enters “Supercycle”

On March 19, ARSA used its Annual Legislative Day gathering to release its 2025 Global Fleet & MRO Market Report. The analysis provided for the association by Oliver Wyman Vector,…Read More
ARSA