ARSA Questions Issuance of PMA for “Consumables”
November 08, 2011
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 The Association also asked that any PMAs already issued on materials or processes be withdrawn.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
November 19, 2024 | Categories:
Act Now,
ARSA News & Updates,
ARSA Works,
Aviation Policy,
Drug and Alcohol,
EASA,
FAA,
Legislative,
Operations,
Press Releases,
Regulatory,
Rulemaking
ARSA members are encouraged to follow the association’s example and engage the White House Office of Information and Regulatory Affairs (OIRA) as it reviews the FAA’s final rule regarding expanding…
Read More
On Nov. 19, ARSA submitted a pair of draft advisory circulars for FAA consideration to replace its proposed update to AC 43-9, Maintenance Records.
The documents divide overlapping responsibilities previously…
Read More
Next March, as it prepares for the 2025 ARSA Annual Conference, the association’s team will make a special appearance at the inaugural edition of VERTICON (formerly HELI-EXPO) in Dallas, Texas.…
Read More
November 05, 2024 | Categories:
ARSA News & Updates,
Regulatory
The U.S. Department of Transportation’s Aerospace Supply Chain Resiliency Task Force delivered its final report on Nov. 4. The task force was created by Congress in 2023 to identify risks…
Read More
November 01, 2024 | Categories:
Act Now,
ARSA News & Updates
March 18-21, 2025
Arlington, Virginia and Washington, D.C. with Livestream Options for Online Participants
Event Information | Registration Coming December 2024
The repair station community’s premier substantive event returns; help ARSA’s…
Read More