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 The Association also asked that any PMAs already issued on materials or processes be withdrawn.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
July 29, 2021 | Categories:
ARSA News & Updates
On July 8, ARSA Managing Director & General Counsel Marshall S. Filler underwent successful heart surgery. His ongoing recovery has included the usual challenges associated with major surgery. As he…Read More
July 27, 2021 | Categories:
, ARSA Works
, Aviation Policy
, Featured Post
For the use of its members and the larger aviation community, ARSA is maintaining this page as a resource for virus-related updates on policy initiatives and business needs. Please bookmark…Read More
To keep tabs on all of ARSA’s work related to the current pandemic, visit arsa.org/anti-viral-measures.
On July 26, the U.S. Department of Transportation announced it will re-open applications for the…Read More
On July 20, the FAA announced plans to host its 8th Annual Global Leadership Meeting in Washington, D.C. on Sept. 22-23. The event will have both in-person and online attendance…Read More
July 21, 2021 | Categories:
ARSA News & Updates
The House Aviation Subcommittee held a hearing July 20 to discuss enhancing diversity in the aviation workforce.
The witnesses were (click a name to download their written testimony):
Rebecca Lutte,…Read More