FAA Issues UPN Against Safran Cabin (galley and lavatory parts)

June 7, 2025 by Leave a comment

The FAA has issued an unapproved parts notice (“UPN”) against Safran Cabin, which is located at 7330 Lincoln Way, Garden Grove, CA. The UPN affects these Safran Cabin parts (descriptions pulled from the UPN):

  • “Galley refresh modification kits manufactured and sold by Safran for installation on FAA type-certificated Boeing 737-800 and 737-900ER series airplanes from May 2023 to July 2024.”
  • “Lavatory flush switch assemblies manufactured and sold by Safran for installation on FAA type-certificated Airbus A320 and A321 series airplanes from August 2021 to June 2024.”

The UPN states that the parts were produced and sold “without Federal Aviation Administration (FAA) production approval.” The UPN also states that the parts may have been marked FAA-PMA and been accompanied by 8130-3 tags. This is particularly disturbing, because the UPN statements suggest that the markings and documentation were misleadingly incorrect. The industry relies on the accuracy of these statements and documents to help assure airworthiness.

The UPN has a more detailed list of affected parts. If you find the affected parts in your inventory, the FAA’s advice from the UPN is this:

“If these articles are found in existing inventory, the FAA recommends that they be quarantined to prevent installation until a determination can be made regarding their eligibility for installation…. In addition to the above recommendations, the FAA would appreciate any information concerning the discovery of the above-referenced parts from any source, the means used to identify the source, and the actions taken to remove the parts from the aircraft and parts inventories”

This is an important lesson that having a well-known name like “Safran” is no guarantee of compliance. Safran Cabin holds a significant number of PMAs. Actual PMAs appear to be unaffected. If you are wondering whether a part with a PMA marking is actually FAA-approved, then you can verify the PMA online at the FAA’s Dynamic Regulatory System.

Filed under Uncategorized Tagged with , , ,

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

March 9, 2017 by 3 Comments

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.

Filed under Uncategorized Tagged with , , , , ,

PMA Parts Exported to Europe

January 6, 2016 by Leave a comment

An ASA member asked for information about how to export, to the EU, subcomponents of PMA components. This sort of question arises when the PMA-ed component is made up of subcomponents and there may be a market for the individual subcomponents, such as when they are required as replacement parts.[1]  It is important to bear in mind that FAA regulations require that when any component parts, or replacement articles, of the PMA article leaves the PMA manufacturer’s facility as ‘FAA approved,’ then that component part or replacement article must be identified with (a) the manufacturer’s part number and (b) the manufacturer’s name, trademark, symbol, or other FAA approved manufacturer’s identification. This identification may be something other than a marking where the design approved by the FAA does not include a marking requirements for that subcomponent.

Generally speaking, EASA 145 organizations may accept PMA replacement and modification parts[2] when accompanied by an FAA Form 8130-3 with appropriate certifying statements.[3] The appropriate certifying statements are described in the Technical Implementation Procedures (TIP).

The TIP explain that EASA directly accepts PMA approvals without further showing, for modification and/or replacement parts intended to be installed on EASA-certified/validated products.[4] Additional requirements that apply to PMAs exported from the US to the EU are also described in the TIP.

Subcomponents of PMA parts would be included as replacement or modification parts produced under a PMA approval, so the EASA acceptance of the PMA approval would be sufficient to permit import into EASA of the subcomponents, as long as they meet the other requirements for PMA parts.

In all cases of PMA parts and their subcomponents, the part must fit into one of these three categories:

  • The PMA part is not a critical component.[5] The vast majority of PMA parts are not critical components.
  • The PMA part is a critical component and it conforms to design data obtained under a licensing agreement from the TC or STC holder;[6] or
  • The PMA part is a critical component and the PMA holder holds an EASA STC that incorporates the PMA part.[7]

Parts are required to be accompanied by an FAA-signed 8130-3 tag.[8] The remarks block of the 8130-3 tag should[9] be annotated with language that reflects the category into which the part falls:

  • If the PMA part is not a critical component, then the text should state: “This PMA part is not a critical component.”[10] Remember, the vast majority of PMA parts are not critical components.
  • If the PMA part is a critical component and it conforms to design data obtained under a licensing agreement from the TC or STC holder, then the text should state: “Produced under licensing agreement from the holder of [INSERT TC or STC NUMBER].”[11]
  • If the PMA part is a critical component and the PMA holder holds an EASA STC that incorporates the PMA part, then the text should state: “Produced by the holder of the EASA STC number [INSERT THE FULL REFERENCE OF THE EASA STC INCORPORATING THE PMA]”;[12] or

The word used repeatedly in association with the remarks block annotation is “should” and not “shall.” The permissive “should” is used in both the header language[13] and the subparagraphs identifying the specific recommended text.[14] Typically, required items are described with the imperative “shall”[15] while the term “should” typically describes recommended actions that are not required. As a practical matter; however, European customers often treat this TIP language as if the “shoulds” were mandatory and not merely permissive.

Subcomponents of PMA parts generally ought to follow the same documentation rules as the complete PMA parts, because the FAA approval basis for the subcomponents is still the PMA. Thus, there should be some marking on the 8130-3 tag that is consistent with the design approval holder’s designation. Again, most PMA parts are non-critical and the subcomponents of those parts will also be non-critical.

A very small amount of PMA parts are critical. If the subcomponent is also a critical component, then the language about licensing agreement or the language about an EASA STC number should be included on the 8130-3 tag.

In those very rare cases where the PMA is a critical component but the subcomponent replacement part is not a critical component, there is some ambiguity about how to categorize the part for purposes of identifying the remark-block annotation. When exporting such non-critical PMA subcomponents to the EU, it is unclear whether the annotation should be based on the classification of the PMA itself, because the documentation required by category is based on “the PMA part” (and it is unclear from the text whether this means the top-level assembly or the subcomponent).[16] The most reasonable interpretation of this language is that when the subcomponent itself is not a critical component, then the non-critical language should be used on the 8130-3 tag; however because of the vagueness in the existing language, there is room for the FAA and/or EASA to interpret this position in a different way in the future.

In most cases, though, subcomponents will belong to non-critical PMA parts, so their categorization will remain non-critical at the subcomponent level.

There is one additional documentation requirement for subcomponents of PMA articles; FAA Order 8130.21H explains that the remarks block must reference the fact that the article is a subcomponent of a PMA part:

“When used for an export for a new subcomponent of a PMA/TSO authorization article higher assembly, complete FAA Form 8130-3 with the subcomponent information, and enter a statement in Block 12 indicating the part or article is a subcomponent of a PMA or TSO authorization (for example, “This part is a subcomponent of a PMA/TSO authorization”). (Refer to appendix A, figure A-15, to this order.)”[17]

The parts must be appropriately marked.[18] This means marked in accordance with the TIP.[19] The TIP requires all replacement and modification parts to be marked in accordance with EASA Part 21; however EASA Part 21 does not intend that all parts be marked. The requirements that are applicable to PMA parts are those that apply to all replacement and modification parts, which is that they are marked in the in a manner identified by the applicable design data.[20] Guidance material clarifies EASA’s intent with respect to this provision by explaining that

“It is not the intent of 21.A.804(a)(1) to introduce an obligation for a production organization (manufacturer) to mark new parts or appliances with information which is not identified by the design approval holder. Therefore, the physical marking of parts and appliances is only required when established by the design approval (TC, STC, ETSO, repair, change) holder.”[21]

PMA parts are specifically exempt from the EPA marking requirement;[22] but they are required to be marked in accordance with their approved designs. This means that so long as the complete PMA part is marked in accordance with FAA-approved design requirements, the fact that the subcomponent does not bear the marking (because the marking should be elsewhere) is not a bar to export of the part from the US to the EU. This is consistent with rules that apply to parts manufactured under production certificates, where those parts do not need to be specifically marked unless they are required to be marked according to the approved design.

[1] The PMA holder is permitted to Identify any portion of the PMA article (e.g., sub-assemblies, component parts, or replacement articles) that leave the manufacturer’s facility as FAA approved, so these subcomponents are approved parts. 14 C.F.R. § 21.316(e).

[2] The term “replacement and modification parts” is interpreted as it is used in the Technical Implementation Procedures (TIP).

[3] Agreement between the United States of America and the European Union on Cooperation in the Regulation of Civil Aviation Safety, Annex 1, page CE/USA/Annex 1/Appendix/en 44 (English Version).

[4] Technical Implementation Procedures for Airworthiness and Environmental Certification, para. 2.8.2(a) (rev. 5; Sept 15, 2015).

[5] Id. at para. 2.8.2(a)(1). For PMAs, a critical component is “a part identified as critical … by the exporting authority.” These are parts for which a replacement time, inspection interval, or related limit was specified in the Airworthiness Limitations Section of the Instructions for Continued Airworthiness. Id. at para. 1.6(i). Among those that are, the limitation that makes it critical will be tied to the PMA design approval.

[6] Id. at para. 2.8.2(a)(2)

[7] Id. at para. 2.8.2(a)(3); see also id. at para. 2.8.2(b) (describing the process for obtaining EASA STC).

[8] Note that the language of section 5.1.10(a) suggests that PAH 8130-3 tags, issued in accordance with 21.137(o), would not be acceptable for export to the EU because they are not signed by the FAA and therefore fail to reflect an FAA certification.

[9] The text uses the permissive phrasing “one or more of the following statements should be written in the remarks block”

[10] Technical Implementation Procedures for Airworthiness and Environmental Certification, at para. 5.1.10(b)(1)(i).

[11] Id. at para. 5.1.10(b)(1)(iii).

[12] Id. at para. 5.1.10(b)(1)(ii).

[13] Id. at para. 5.1.10(b)(1).

[14] Id. at para. 5.1.10(b)(1)(i, ii, and iii).

[15] E.g. 14 C.F.R. § 1.3(b)(1) which explains that in the FAA’s regulations, “Shall is used in an imperative sense.”

[16] E.g. Technical Implementation Procedures for Airworthiness and Environmental Certification at para. 5.1.10(b)(1).

[17] Procedures for Completion and Use of the Authorized Release Certificate, FAA Form 8130-3, Airworthiness Approval Tag, FAA Order 8130.21H, para. 4-5(l)(6) (Aug 1, 2013).

[18] Agreement between the United States of America and the European Union on Cooperation in the Regulation of Civil Aviation Safety, Annex 1, paragraph 3.5.2(d), page CE/USA/Annex 1/en 14 (English Version).

[19] Technical Implementation Procedures for Airworthiness and Environmental Certification, para. 5.1.10(a)(3) (rev. 5; Sept 15, 2015) (requiring marking); see also id. at para. 5.5.2(a) (explaining the marking requirements).

[20] EASA 21.A.804(a).

[21] EASA GM 21.A.804(a)(1) (Identification of parts and appliances).

[22] Agreement between the United States of America and the European Union on Cooperation in the Regulation of Civil Aviation Safety, Annex 1, paragraph 3.5.7, page CE/USA/Annex 1/en 15 (English Version).

Filed under Uncategorized Tagged with , , , , , , , ,

New Definition of “Parts”

July 6, 2011 by Leave a comment

The FAA’s most recent change to AC 43-18 includes a new definition of the term “part” that will be of interest to everyone in the aerospace industry.

The AC defines the term “part” to mean:

Part: For the purposes of this AC, is an article that could be produced under the provisions of 14 CFR part 21 and is eligible for installation on a certificated aircraft without further manufacturing processes.
NOTE:The definition of a part for the purposes of this AC would not include raw materials or repair segments being utilized for the repair or alteration of a part. (i.e., sheet metal stock, sealants, lubricants, raw forgings, or castings, billet material, etc.

The fact that the definition is limited to only this particular Advisory Circular is an important limit, but it is fairly normal for definitions like this to take on a life of their own.  FAA employees will cut-and-paste this definition into other documents over time, and they will also rely on it, in the absence of any other guidance, when trying to decide what is – and what is not – a “part.”

The definition may become a problem, in that it is self-contradictory.  It includes “an article that could be produced under the provisions of 14 C.F.R. part 21;” however the FAA has issued PMAs for sealants and lubricants, which it claims are not “parts.”

AC 43-18 is the Advisory Circular that provides guidance for Fabrication of Aircraft Parts by Maintenance Personnel.  The most recent change (change two) which added this new definition was issued on June 7, 2011.

Filed under Uncategorized Tagged with , , , ,