PMA by Identicality per licensing agreement... Same part? 3

[KirbyWan]

Howdy all,

So front line carriers often prohibit PMA parts for repairs without approval. Some PMA parts are approved by Identicality per a licensing agreement, and these usually have the same part number. It is a PMA part and should say PMA on the ID tag and the 8130, but with the same P/N I could see this easily slipping by as an OEM part. We can track these different parts by creating a part record specific to a manufacturer so Boeing is the OEM and has one part record and Goodrich has licensed the part so they can make it and we have created a different part record to track them.

For the folks who work at a front line carrier and prohibit PMA parts without approval, are these parts produced by identicality an issue? I always thought it was a concern that the parts produced by test reports and computation were the concern that they may not have the same level of quality as the OEM. Those parts have to have a different part number, usually the base number with a prefix for the company making it so they are not easily confused.

Would an OEM use a PMA part produced by a licensed vendor? It would broaden the manufacturing base.

Thanks,

-Kirby

Kirby Wilkerson

Remember, first define the problem, then solve it.

 

[Sparweb]

PMA seems to be one of the most abused and misunderstood approval categories.
When done correctly, a PMA has the quality and weight of a STC approval.
Since many PMA's have slipped through with no more than "photocopier" equivalency, the problem has to be acknowledged.

Identicality is NOT the definition of a PMA.
A PMA should not be granted because a part is identical to the original.
Finding an identical part and relabeling it does not make it a part worthy of a PMA.
There are so many ways to say the same thing.
These misunderstandings, and the justifiable response of some operators to that abuse is being mistaken for the rule. Sadly.

The value of the PMA does not need to come from the licensing of data, although that could be one way. The potential PMA holder could instead examine the part, its function and where it is installed, determine what is needed in the design to produce an approved part as rigorously as the OEM did, carry out that design, analysis, and/or test activity, produce it with the aviation standard of quality control, and submit that data to FAA/DER/ODA for approval. That meets the standard of a PMA and is almost equivalent to a STC.

One sign of a bogus part is that it masquerades with a part number identical to the OEM's part number and no other sign of its approval status. This is how the PMA system is abused. An honest PMA holder will mark their part as a PMA part and include the equivalency to the OEM part number so that the identification is clear.

Unfortunately, brutally applied PMA policy will filter out the honest PMA holders and still let the bogus ones slip through.

OK. Wheww... got that off my chest.

Now. On to your specific question...
An OEM using a PMA part is cart before the horse. The OEM defines the standard for fit, form, and function when they design and certify the aeronautical product. That definition includes the maintenance procedure needed to maintain all of the parts on the aircraft. All of these engineering activities have to be complete before the conditions for a PMA are established. So the OEM doesn't care.
Later, when the OEM is done making money off of its customers through airframe sales, the replacement parts business may also dry up, too. The OEM can tap a small revenue stream by licensing out the 20-year-old approval data to small companies that want to make PMA parts.

 

[KirbyWan]

SparWeb,

I think you misunderstand how I've framed the question, or my understanding of what I'm trying to ask about is lacking. From my understanding there are 4 ways to get a PMA per FAA order 8110.42, Identicality with a licensing agreement, where the OEM data package is provided for all manufacturing requirements to produce the part. Identicality without a licensing agreement. Comparative analysis where a part is reverse engineered and shown to be equivalent to the original. And general analysis where the core requirements of the part and used and a clean sheet design that functions equivalently to the OEM part is produced.

I'm only referencing the first one here, identicality with a licensing agreement, so the OEM data package is used to produce the part. Per 8110.42:

...
Parts Manufactured Under License. When the PMA basis is identicality by showing evidence of a licensing agreement, the PMA part may have the same number as the type-certificated part. However, we require the applicant to meet the requirements of 14 CFR §§ 45.15(a)(1) and (2) by permanently marking the part with “FAA-PMA” and the PMA holder’s name, trademark, or symbol.
...

So I'm not talking about suspect unapproved parts or people abusing the PMA System, this is about parts whose manufacture is approved by the FAA based on licensed data from the OEM and that have the same part number which is allowed per the FAA, though it should still have a mark that says "FAA-PMA" on it.

My question was about how would a front line carrier, who has specifically said no PMA parts without prior approval, address PMA parts with identical part numbers because they were approved by identicality with a license agreement.


My concerns are, while I feel we have an excellent quality system, we order a part, it has the same part number and we miss that it is a PMA part and install it on a front-line carriers aircraft without their approval of a PMA part. I was poking around this question, wondering if the OEM would use a PMA part? Could we receive a part from the OEM that uses PMA parts already installed on it? I would guess the OEM could order the parts from a vendor and receive them as OEM parts, but if the same vendor sold the same part separately it would be labeled as a PMA part.

Thanks for your response.

-Kirby

Kirby Wilkerson

Remember, first define the problem, then solve it.

 

[SWComposites]

the OEM could order the parts from a vendor and receive them as OEM parts, but if the same vendor sold the same part separately it would be labeled as a PMA part. > Exactly how it works.

 

[der8110]

As a practical matter, nearly all PMA's by Identicality per a Licensing Agreement are made by the supplier to the OEM. Either the OEM does not want to bother with the support supply chain, or the supplier made permission to sell in the aftermarket part of the original agreement of selling to the OEM. Same design, materials, processing, quality checks - just one gets received by the OEM and sold as a Production Certificate part, and the other gets labeled PMA.

The "no PMA parts" policies are quite silly and often have no more basis than a buyer did not get a coffee mug or other trinket, and can only survive in organizations that can afford to ground an airplane when perfectly good parts are available. Hard to believe they can survive in the world's largest free market. Remember, first create a problem, then suck it dry.

SCOTUS will be ruling soon on the "right to repair", and like everything else aviation, will take decades to affect aircraft. But on the other hand, PMA is here now, and it is working. Horror stories abound, to be sure, but for the most part it's a success.

To your specific questions:
are these parts produced by identicality an issue? >> No, they are about the "same" as same can get
Would an OEM use a PMA part produced by a licensed vendor? >> Yes they already are, just washing it through a PC

 

[mfgenggear]

quote" So I'm not talking about suspect unapproved parts or people abusing the PMA System, this is about parts whose manufacture is approved by the FAA based on licensed data from the OEM and that have the same part number which is allowed per the FAA, though it should still have a mark that says "FAA-PMA" on it. unquote

1st off to my experience all PMA parts have to be approved by the FAA and are clearly marked with a different part# and serial #, the part number may have a different prefix, or suffix or both.
there are OEM parts produced by contract by their supplier chains, and are OEM, but are manufactured to the original OEM drawings and are not PMA.
I have forgotten the correct nomenclatures, but there are two types PMA parts, reverse engineered from existing OEM parts, and reverse engineered to OEM drawings that are government owned drawings.
in both cases the PMA manufacture has to create their own drawings and have to be FAA approved. an to my experience are clearly have a different parts mark. due to the freedom of information act.
government owned draws have to be release to the PMA manufacture when requested, and follow all FAA regulations to obtain PMA approval. and it is not a cake walk.

 

[Sparweb]

Hi Kirby,
You make a good point, I can get the details of the CAN system mixed up with the USA system. In Canada we don't allow all of the stuff that is permitted in the USA. The regulations are set up differently.

 

[WKTaylor]

Hey guys... because I'm military oriented and situation with parts manufacturing/self-manufacturing/certification is 'somewhat different'... appreciate some orientation. I'm aware of these documents relevant-to/supporting/similar-to[?] for this discussion [numerical order]… ...

AC21-29 Detecting and Reporting Suspected Unapproved Parts

AC29-62 Eligibility, Quality, and Identification of Aeronautical Replacement Parts

AC43-18 Fabrication of Aircraft Parts by Maintenance Personnel

Sooooo… Please advise... What other data [ACs, ANMs, FARs, etc] are relevant...???

NOTE. Being a materials/processes guy, I understand how mind-boggling difficult it is for the under-informed to reverse engineer or even translate relatively straight forward drawings to even make 'simple parts/Assys'... as a 3rd-party parts-manufacturer... relative to how the OEM intended/certified... often-times decades ago. Concepts are often obscured in the cryptic languages of supporting specifications and unique drawing practices and 'standard practices' that are not always obvious practices... of another 'era'.

Regards, Wil Taylor
o Trust - But Verify!
o We believe to be true what we prefer to be true. [Unknown]
o For those who believe, no proof is required; for those who cannot believe, no proof is possible. [variation,Stuart Chase]
o Unfortunately, in science what You 'believe' is irrelevant. ["Orion", Homebuiltairplanes.com forum]

 

[mfgenggear]

Wtalor

I believe it depends on the product. commercial vs military contracts. Life flight vs Non Life flight vehicles
I don't remember the specific specifications and or regulations.
I could dig them up but not for conversation.
the engineering government drawing and related specifications are available from the freedom of information act of as I last notified.
what every the requirements are it still has to be adhered to and including all material, heat treat, dimensional requirements, NDT, and coatings.
except the PMA manufacture has to create their own design drawing meeting or exceeding the original engineering.
all fabrication requires first articles, and serial numbers, I processed manufacturing for PMA companies.
the tolerance are twice as tight than the original design. I did mostly fabricated loose gears for transmission and what not. so that is all I can discuss.
far as reverse engineering, there has to spectral analysis of the material and metlap evaluations of the heat treat and material.
all dimensions have to be documented and recorded. and it is required to change the part# can not use the same part #, it's a tough game.

 

[rb1957]

For my money, an identical part should be clearly marked as a PMA to distinguish from an OEM part.
The approach of the part, being identical to the OEM part, is quick and simple.

another day in paradise, or is paradise one day closer ?

 

[mfgenggear]

Rb1957
It has to part mark with
Cage code, part number, FAA/PMA
And serial number. If not it is not
Legal and it is a felony.
And not the original part #.

 

[KirbyWan]

mfgenggear

If it's PMA by identicality with a licensing agreement it can have the same part number as the OEM. That is specifically noted as acceptable in FAA order 8110.42 as I quoted above, though yes it does still need "FAA-PMA" stamped on the tag as well. This is what led me to ask this somewhat ill-formed question because I was kind of confused that the PMA part database the FAA provides had PMA parts with the same part number as the OEM. This lead me to dig through the FAA order and learn that it was acceptable.

-Kirby

Kirby Wilkerson

Remember, first define the problem, then solve it.

 

[mfgenggear]

Kirby
To my knowledge a company licensed by the oem can and does use the same part # and is legit. To my knowledge. Does not require FAA/PMA, Unless it is required by the contract to have FAA/PMA. To my knowledge it is not required because it uses the same cage code and a mfr code of the mfg.. But any thing is possible
To make sure they are legit contact the OEM and make sure they are licensed. like said before, shady companies out there.