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 The Association also asked that any PMAs already issued on materials or processes be withdrawn.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

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