What is the Difference Between FAA PMA Parts and FAA STC Parts?

A member recently asked “what is the difference between FAA PMA parts and FAA STC parts.”

A PMA is a production approval.  14 C.F.R. § 21.1(b)(7).  The PMA gives the holder the power to produce articles for use on aircraft.  E.g. 14 C.F.R. § 21.9(a)(2).  Parts produced under an FAA PMA are approved parts.

A supplemental type certificate (“STC”) is a design approval only.  14 C.F.R. § 21.1(b)(4).  It does not provide any inherent production approval.  Thus, an STC holder who wants to produce articles for use on aircraft will need some other production basis (in addition to the STC).  When parts are offered for sale and described as “STC Parts” it is important for the buyer to understand the production approval basis for the parts.

STC Holder Options for Production

Generally speaking, if a person knows that a replacement or modification article is reasonably likely to be installed on an aircraft, engine or propeller, then the person may only produce that article under one of the categories listed in the FAA regulations – specifically in section 21.9(a) of those regulations. These represent the FAA-acceptable mechanisms for production.

STC holders can and do use production certificate (PC) and/or parts manufacturer approval (PMA) to obtain FAA production approval for parts where the design has been approved under an STC.  14 C.F.R. § 21.9(a)(2).  In these cases, the production approval permits the holder to produce articles that are likely to be installed on aircraft, engines or propellers.

An STC holder (or the licensee of such a holder) could produce parts for consumption during maintenance or alteration.  14 C.F.R. § 21.9(a)(6).  But if that company decides to sell those parts, instead of consuming them itself, then that may violate the regulations.  14 C.F.R. § 21.9.

An owner/operator could produce an article for maintaining or altering that owner or operator’s own aircraft, engine or propeller.  4 C.F.R. § 21.9(a)(5).  An STC could serve as the design basis for the article.  So this is another possible way to produce parts based on STC data.

It is also possible for an article that is called-out in an STC design to be produced as a commercial part or a standard part; but when such articles are produced under one of these categories, they are typically not called “STC parts.”

Conclusion

I have seen situations where STC holders mistakenly believe that they have the authority to produce and sell aircraft parts under the STC (alone).  This is, of course, not true.

Because of this history, whenever someone tells me they intend to buy STC parts, I always want to follow-up to identify the production approval basis of the parts.

New FAA Guidance Available for Comment on PMAs

The FA A has published two proposed guidance documents on PMAs.  While they are primarily aimed at the community of companies that manufacture PMAs, it would be useful for the distribution community to review them to make sure that they are consistent with our needs as well.  Some distributors may be inspired to enter the PMA world themselves!

The first of the guidance documents is Draft Order 8110-42D. This is the latest revision to the PMA guidance for FAA employees who review and approve PMA applications.  One of the most significant additions to this revision level is the inclusion of risk based resource targeting (RBRT).

Comments on the draft order can be emailed to the FAA at robert.sprayberry@faa.gov .  Please send a copy of your comments to ASA, too, so we can be sure to echo our members’ concerns.  You can also mail comments to:

Federal Aviation Administration
Aircraft Engineering Division
Engineering Procedures Office AIR-110
950 L’Enfant Plaza, SW, 5th Floor
Washington, DC 20024

The second of the guidance documents is Draft AC 21.303-PMA.  There was no previous AC on PMA procedures, but there was plenty of guidance on the old Order (8110.42C).  This takes the guidance that is useful to PMA applicants and pulls it out of the order and gives it a home in a public document.

The draft AC makes it clear that the FAA will issue PMAs for materials like sealants, and for modified standard parts, but that it will not grant PMA for raw materials, processes or inspection procedures.  Many companies in the ASA community have found that developing a PMA manufacturing infrastructure is a convenient way to supply parts that used to be considered “commercial parts,” but that under the newer rules are considered unapproved parts when procured from the “OEM” [a distributor can develop an quality assurance process, treat the producer as a supplier, obtain a PMA and supply the part as an approved part].

Comments on the draft advisory circular can be emailed to the FAA at john.milewski@faa.gov . Please send a copy of your comments to ASA, too, so we can be sure to echo our members’ concerns. You can also mail comments to:

Federal Aviation Administration
Aircraft Engineering Division
Engineering Procedures Office AIR-110
950 L’Enfant Plaza, SW, 5th Floor
Washington, DC 20024

Remember – distributors are concerned about parts safety, too!  Don’t be afraid to raise your concerns or ask your questions if you see some thing in the proposed guidance that you think deserves more attention!  Comments are due to the FAA by September 1, 2013.