Peter wrote:
OK; so PMA is accepted for simple parts, but this is not a blanket acceptance of FAA-PMA.
So here’s my challenge to you. Find me a critical part that is manufactured under PMA.
Alan_South wrote:
So here’s my challenge to you. Find me a critical part that is manufactured under PMA.
Magneto’s for are example are also produced under FAA PMA. As well as many components for magneto’s.
The ‘shall’ issue is interesting, because FAA is correct in there being two uses for the word: the traditional US contractual shall (meaning must) and the largely UK version (e.g. shall we dance? = may we dance?) which has nothing like the same meaning and isn’t in common US usage. The use of ‘must’ by FAA in its regulations cannot be so easily be misinterpreted, particularly by non-US speakers. That aside, I’d suggest the last thing anybody should criticize FAA for doing would be using discipline to issue documents without ambiguous wording, particularly when you see the unparalleled mess that ambiguous English language wording has created in EASA regulation.
I’d suggest that major aircraft engine and brake components produced under PMA are ‘critical’ but perhaps I don’t understand the meaning of the word as defined by EASA 
Magneto’s for are example are also produced under FAA PMA. As well as many components for magneto’s.
Most of my D3000 magneto is made under PMA – as Jesse says. It was only the existence of PMA parts, after Bendix stopped making these mags, which prevented large scale grounding of the Lyco/Conti powered fleet.
Silvaire wrote:
The ‘shall’ issue is interesting, because FAA is correct in there being two uses for the word
Shall has more uses than that. I have looked into a couple of dictionaries and all of them state that in law shall is used to express something mandatory. And EU has a document that states this (shall = must) explicitly (it’s sort of a guideline on the usage of language in regulations, etc.).
The issue with EASA regulations sometimes seems to me that they are too liberal for some people at national authorities so they invent restrictions because, surely, they couldn’t have seriously meant the most liberal interpretation. 
It leads to some interesting nonsense. And since a lot of those people have to work with translations that can and do introduce mistakes, all the blame can’t fall on them. Yes, the regulations do have holes (for example, there are provisions for converting LAPL(S) with TMG extension to LAPL(A) or PPL(A) but no such provision exists for SPL with the same extension), but most of the issues I noticed were invented downstream where they refuse to use common sense.
PS: However, I’m aware of a study that found “shall” is often misused in EU regulations.
A piece of said guide:
10.19 The use of verbs, in particular the modal verb shall, in legislation often gives rise to problems, since such uses are rarely encountered in everyday speech. Consequently, writers may lack a feel for the right construction. The following section is intended to provide guidance.
10.21 For a positive command, use shall: This form shall be used for all consignments. Note that this provision expresses an obligation. However, this is not always the case: This Regulation shall enter into force on… Theoretically, must could be used instead of shall in the first case, while will could be used in both cases. However, this is not the practice in EU legislation.
I wonder whether there is another factor in play here: EASA needs to “sneak in” the more controversial regulation, by the use of ambiguous language. That reduces the opposition. Look at the EASA FCL “dual papers” attack on N-regs and the “operator residence” wording. That’s straight out of a Cologne bar. But it has made most of Europe’s IFR community (which is N-reg) crap itself. I get emails almost daily from pilots asking me what I think they should do. The positive thing is that EASA blew most of its political capital getting that crap through (especially getting it past the Transport Committee using dishonest means – lying about an imminent FAA treaty) and that probably led to the positive changes we have seen since, starting with the departure of Goudot, Sivel, etc. and leading to the successive delays in implementation of the aforesaid regulation. I am also certain that the process was facilitated by the general reduction in the power of the EU (the economic near-meltdown… Greece, etc).
Picking up the LED replacement threads e.g. here is a pilot authorised to make the judgement on applicability?
Case 1: A PMA replacement part is by definition the same as the original, but is a pilot authorised to make that interpretation? IMHO yes. There is no “EASA PMA” process under EASA but FAA-PMA parts are routinely installed on EASA-reg planes.
Case 2: An STC replacement part is also an authorised replacement (IAW the STC) but is a pilot authorised to make that interpretation? IMHO no; he needs an A&P to make the decision and he needs an A&P/IA to check the job and sign the 337 which is then mailed with the STC to Oklahoma. In the case of an EASA STC, what is the process there?
But taking Case 2, is a subsequent replacement of that part OK under pilot privileges? For example the replacement of a bulb is OK under pilot privileges (in most cases; not bulbs internal to instruments and requiring complex dismantling, for example) but what if the bulb was an STC installation? Then, its replacement is covered by the Continued Airworthiness provision on the back of the 337
It does get a bit ridiculous (most people just install the thing, including Concorde batteries in place of Gill ones) but there are Part 21 firms in Europe who have STCs (or something like that) for LED lamp installations.
I wonder if anyone has input on this one…
Can a pilot, performing maintenance within pilot privileges, substitute a PMAd or STDd part?
I don’t think he can substitute an STCd part because – on an N-reg – that needs an IA to inspect and sign and send the 337 to Oklahoma. On an EASA-reg I don’t know what the STC installation process is.
But a PMA part is a replacement.
It has been repeatedly stated (e.g. here ) that EASA accepts FAA-PMA parts in most cases.
However I have just read a disturbing story of a UK maintenance company forcing a G-reg TB9 PMA fuel pump to be replaced before they will sign off the Annual.
That is 1000 quid chucked out, just for a laugh. The item is a FACET 476284E fuel pump, which was replaced with a PMA part. The pump seems to have an interesting original use
Does anyone have a reference to the EASA FAA-PMA acceptance regs?
