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S-TECH ENTERPRISES AND THE FAA PMA PROCESS



The following is a brief discussion of S-Tech Enterprises' philosophy regarding the implementation of a Parts Manufacturer Approval (PMA) program.   Certain elements would be modified or deleted to meet the client's specific requirements.


1.0   GENERAL PROCESS

Subsequent to the client obtaining design approval from the FAA, S-Tech Enterprises will provide assistance to the client so that they can establish themselves as a Production Approval Holder (PAH) by obtaining a Parts Manufacturer Approval (PMA) from the FAA.   This will be accomplished by implementing and maintaining a Fabrication Inspection System (FIS) as required by federal regulation (Title 14 CFR §21 Subpart K).   Furthermore, S-Tech Enterprises will act as the point of contact for the client with the FAA for issues pertaining to obtaining and maintaining the PMA.


2.0   DESCRIPTION OF THE FABRICATION INSPECTION SYSTEM

The Fabrication Inspection System (FIS) will be in accordance with Title 14 Code of Federal Regulations (CFR) §21.303(h).   The proposed system will also meet the additional requirements for the reporting of failures, malfunctions, and defects under Title 14 CFR §21.3 and the provisions for identifying the product as called for by Title 14 CFR §45.15.

Should the client desire to out source the fabrication of the PMA product, special emphasis will be placed on Supplier Surveillance Procedures.   Provisions can also be made for the product fabricator to be granted direct ship authorization to simplify and speed distribution of the product.   Procedures would then be put in place to ensure that the contractor's quality system complies with FAA requirements and that the client has adequate control over the contractor producing its product.


2.1  SETTING UP THE FABRICATION INSPECTION SYSTEM

Activities pertaining to setting up the FIS will include, but are not be limited to:

  1. flow charting and documenting the client's internal processes to ensure that its product meets FAA requirements,
  2. make recommendations for changes to the client's internal processes to align them with industry practices acceptable to the FAA,
  3. if required, flow charting and documenting the processes for the manufacture of products by outside contractors,
  4. make recommendations for changes to the outside contractors' internal processes to align them with industry practices acceptable to the FAA,
  5. developing organizational charts for the client and their contractor(s),
  6. if required, establishing the processes and procedures whereby the client's principal contractor will be granted "direct-ship authorization" by the FAA,
  7. writing the FIS manual,
  8. if required, writing a manual detailing organizational authorities and responsibilities,
  9. if required, writing a manual detailing engineering procedures that includes procedures for the configuration control of engineering documentation and the incorporation of changes into approved products,
  10. developing and presenting training material to guide the client's administrative and production personnel during the initial phases of acceptance of the FIS by the FAA and during subsequent audits.


3.0   OBTAINING PRODUCTION APPROVAL HOLDER STATUS

S-Tech Enterprises will act as the point of contact with the FAA for issues pertaining to obtaining Production Approval Holder (PAH) status and will submit all required documents to the FAA to obtain the PMA and will produce the FIS manual for initial acceptance by the FAA.   All manuals and procedures will be written to be in accordance with current Tile 14 CFRs and the latest FAA guidance material.


3.1   INITIAL PRODUCTION APPROVAL HOLDER STATUS TASKS

Tasks regarding obtaining PAH status include, but are not be limited to:

  1. submission of the application for PMA and any additional supporting documentation to the cognizant FAA Aircraft Certification Office (ACO),
  2. submission of the FIS manual and any additional supporting documentation to the cognizant FAA Manufacturing Inspection District Office (MIDO) for acceptance,
  3. acting as the client's representative during the FAA's review of the client and , if required, the manufacturing contractor(s) and throughout the entire approval process.
  4. conducting training for the client's administrative and production personnel concerning their responsibilities as a PAH and manufacturer of FAA approved products.


4.0   MAINTENANCE OF THE PMA AND THE FIS

S-Tech Enterprises will act as the point of contact with the FAA for all issues regarding the maintenance of the client's PAH status and its FIS.


4.1   PMA AND FIS MAINTENANCE ACTIVITIES

Activities include, but are not be limited to:

  1. revision of the FIS manual and submission to the FAA for acceptance as required,
  2. revision of the PMA supplement pages and submission to the FAA as required,
  3. maintaining configuration control of the product,
  4. submitting revised documentation to the FAA,
  5. obtaining concurrence from the FAA regarding issues of major versus minor changes to the product,
  6. reporting of failures, malfunctions, and defects to the FAA as required by regulation,
  7. representing the client during all activities requiring contact with the FAA (i.e. routine surveillance),
  8. developing documentation to guide company personnel during FAA routine surveillance and scheduled audits, including FAA Aircraft Certification Systems Evaluation Program (ACSEP) audits,
  9. acting as the client's official representative and company focal point during FAA ACSEP audits,
  10. conducting internal audits at scheduled intervals,
  11. conducting recurrent training for the client's administrative and production personnel concerning their responsibilities as a PAH and manufacturer of FAA approved products,
  12. generation of any additional documentation requested by the FAA in connection with the maintenance of the PMA.


5.0   RESPONSIBILITIES

The client will be responsible for ensuring compliance with all federally mandated regulations and FAA guidance material.   The client will also be responsible for ensuring the same from their contractor(s).   The client will be further responsible for informing their contractor(s) that by accepting a contract to manufacture products as part of a PMA program, the contractor is also subject to FAA surveillance.   S-Tech Enterprises will advise the client with regard to FAA compliance issues and assist the client with its responsibilities as previously noted.   Please note that S-Tech Enterprises will not be able compel others to change their internal procedures to comply with FAA requirements.




149 AZALEA CIRCLE • LIMERICK, PA 19468-1330

610-495-6898 (Office) • 484-680-0507 (Cell)

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Web page created by S-Tech Enterprises.   Last revised: December 18, 2003