FAA/PMA Part Marking Requirements

C

Channi_Woods

#1
I work for an injection molding facility that manufactures parts for Boeing. Occasionally, we are asked by aftermarket suppliers for some of the parts we are on contract to make for Boeing. Our contract states that we are not authorized to sell parts off the Boeing owned tools to a third party, unless it is in support of a Boeing PO. No problem there.

These aftermarket suppliers are licensed to use Boeing's Engineering to produce these parts. (Not the tooling!) So they have asked us to build them tools and injection mold the same parts for them under their License. Ok, also not a problem.

One of these after market suppliers, places on their PO's to us to mark the parts with their FAA/PMA number. We do this, and do not find this a problem.

The second AfterMarket supplier is also a Tier 1 partner with Boeing and recently came in for a source inspection. They asked why we marked their parts with the FAA/PMA Number. It is not on their PO. (T%his is where the fun part begins.)

Apparently, they want to put the FAA/PMA Marking on the parts themselves. So if they are selling directly to the airlines, they would mark them with the FAA/PMA number. But if they are used for Boeing Production, they would not need it.

This almost sounds logical, except for the part about the orders coming through their After Market Division, and if they were using these parts in support of Boeing Orders, they wouldn't have needed to have their own tool built!

To me, it sounds like someone's left hand and right hand aren't quite connecting all the dots together.

What I need to know is what are we supposed to mark these parts with? The Boeing Part Number only? Or are we supposed to mark them with the FAA/PMA number as well? If so, what is supposed to dictate to us this requirement? Regardless of whether or not it's on the PO now, should it be on the PO ALL the time as these orders are coming from their AfterMarket Division? Like i said earlier, if they were working in support of a Boeing PO, they wouldn't have needed a tool of their own.

The Regulations that I was able to skim through google searches don't seem to address PMA parts manufactured by a sub-tier. They all seem to assume that the PMA holder is the one manufacturing the parts. They also don't take into account the contracted manufacturer also making aftermarket parts for other customers. We can't have the same part number used for both Boeing as well as the Aftermarket customer, or we run into the risk of co-mingling parts from the different tools. This makes inventory accountability interesting! (Which parts came from which tool?)

I'm sure I may be missing a few more details in this description of events, so feel free to ask away. Any guidance in this would be greatly appreciated.

Thank you.
 
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A

andygr

#3
In theory the one who should be marking the part is the actualy PMA holder. They are the one with the PMA approval not their subtiers and the ones who whould be issueing the 8130-3 tag. The regulations do not required the actual part be marked you can always bag and tag.
Boeing is VERY clear in their requirements that No parts with PMA marking be sent to them dirrectly since in theory someone can get a PMA with out a tech assist letter from Boeing and then Boeing would not be assured that the PMA part was indeed conforming to their approved design data.
The PMA marking is only for aftermarket.
SO
I would propose that if PMA markiing is required and you have one tool that has the markings and the other does not that there be differant internal part numbers to your that your customers would have to order to. The other option is to not have any molded PMA marking and inkstamp or bag and tag the PMA marking.
:2cents:
 
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