Marking Parts Manufacturing Approval (PMA) Parts with a 8130-3 Tag

[quality24]

We mark "FAA-PMA" on PMA parts we have that we ship with the 8130-3 Tag. Should the parts have "FAA-PMA" on them even if we are not using an 8130-3 tag. As an example if we ship the parts to the OEM that installs our part into their box.

My understanding is the "FAA-PMA" goes on all the PMA parts no matter who it goes to.

 

[BadgerMan]

Re: Marking PMA Parts

I believe you are correct. However, with the recent changes to Part 21, I don't believe you need to mark the product with the specific eligibility.

 

[quality24]

Re: Marking PMA Parts

Thank you for your help.
I was aware of not needing the eligibility any longer.
At one time the "FAA-PMA" was coming off also. The class I went to the video said the "FAA-PMA" was coming off but at the end of the video they had changed their minds on it. They were going to a have every part of the engine be marked. They appear to listen to industry and backed off much the FAA wanted.

 

[BadgerMan]

Re: Marking PMA Parts

From AC 21-42:

e. Section 45.15, Marking requirements for PMA articles, TSO articles, and critical parts.
(1) The former title of this section “Replacement and modification parts” was changed to “Marking requirements for PMA articles, TSO articles, and critical parts.”
(2) This section standardizes and consolidates marking requirements for PMA articles, TSO articles, and critical parts, including an identifier of the person who manufactured the part and the part number. In addition, TSO articles require the TSO number and letter of designation; any marking specifically required by the applicable TSO; and the serial number or date of manufacture or both, unless otherwise specified in the applicable TSO.
(3) This rule relocates the requirements of previous § 45.15(b) to paragraph (d) of this section. The rule requires marking information to be attached to any article that the FAA finds is too small or otherwise impractical to mark on the article and clarifies that this provision applies to all PAHs.
(4) This final rule retains the current “FAA-PMA” marking requirements. However, installation eligibility is no longer required on the article.

 

[quality24]

Re: Marking PMA Parts

I have read this part and I am not clear on when it is a PMA part. We do have PMA on these parts. When we send these parts to the OEM (EX. Honeywell) they take our part and install it in their system. The OEM does not need our PMA to install it since they have qualified their assembly with our part in it.

Is your understanding that the FAA-PMA should always be on the part even if it is going to the OEM? Sorry I am the DMIR but the FAA really confuses me. The instructor at the Part 21 changes class appeared to believe that "FAA-PMA" should be on all parts that have a PMA.

 

[Marc]

FAA 8130-3 Tag and Information

Extra Info - See attachments, and FAA order 8130 21f 053008.pdf (From 2008 - the instructions deactivate block nine by requiring persons completing the form to insert “N/A” into this block in all cases. The revision also includes significant new instructions for establishing an electronic data system that will permit the exchange of electronic airworthiness authorization information).
.

 

[quality24]

Re: Marking Parts Manufacturer Approval (PMA) Parts with a 8130-3 Tag

Thank you I have reviewed the information. I guess the concern of the production people is when the OEM see the "FAA-PMA" they will realize that we have cut them out as the only option to purchase the part we manufacture. We are going after the aftermarket. We sell to then for $1000 they sell to the airline for $4000. We sell to the airline for $2000. Everyone is happy except for the OEM.

The OEM could have looked it up on line to see what PMA's my company have.

 

[BadgerMan]

Re: Marking PMA Parts

Is your understanding that the FAA-PMA should always be on the part even if it is going to the OEM?

That is my interpretation based on everything I have read and been told by our MIDO.

I guess the concern of the production people is when the OEM see the "FAA-PMA" they will realize that we have cut them out as the only option to purchase the part we manufacture.

We have this challenge with TSOA product in that the OEM wants their own name, address, and part number on the product's label. They (the STC holder) don't want to be cut out of the loop (and the profits) when units come back from the field for repair/overhaul.

 

[Al Rosen]

Re: Marking Parts Manufacturer Approval (PMA) Parts with a 8130-3 Tag

Thank you I have reviewed the information. I guess the concern of the production people is when the OEM see the "FAA-PMA" they will realize that we have cut them out as the only option to purchase the part we manufacture. We are going after the aftermarket. We sell to then for $1000 they sell to the airline for $4000. We sell to the airline for $2000. Everyone is happy except for the OEM.

The OEM could have looked it up on line to see what PMA's my company have.

I've been out of this part of the business for 10 years but when I was in it, the most expeditious means to obtain a PMA was through a licensing agreement with the original approval holder (OEM) and very difficult through test and computation or identicality.

 

[errhine]

Re: Marking Parts Manufacturer Approval (PMA) Parts with a 8130-3 Tag

We get our PMAs through letters of assist from the OEM but we also have an AMOC (Alternate Means of Compliance) that allows us to mark PMA on all of our products on our paperwork only.