Similar PMA system within Europe (EASA)

In the EASAland, there is a thing called Production Organisation Approval (POA). However, you’ll also need a holder of a DOA (Design Organisation Approval) to design it.

There is no PMA system in EASA-land, but bear in mind that the FAA PMA system is to enable the manufacture of an identical part, not an improved part.

The PMA part can be more reliable, which is great, but aviation certification is nothing to do with reliability A product which is absolute crap in reliability can (and often does) get TSOd etc.

So unless your colleague’s product is functionally etc identical, it would not quality under a PMA system, AIUI.

Your best bet is to go for an FAA STC or whatever. For the certified market it will need to be TSOd (in general) and then to sell it easily you want an STC because too many people in the industry cannot read and write well enough to want to do a Field Approval.

I looked into this for various bits in years past. One was a PMA item and there was a big overhead in getting that for a Europe based business. Another was an STC and that was a bit more doable. But unless you have something earth-shaking, there are not many opportunities in GA, with Garmin owning most of the universe and everybody else eating what is left over.

The European GA market is really quite poor and the dealers are massively loyal to the big names (i.e. Garmin) because they can phone them up if the installation doesn’t work.

There is also a basic problem here: proving that a PMA product is identical may involve reverse engineering which may involve a breach of copyright. With something trivial e.g. a magneto spring, proving same function is easy, but it’s not so easy for something complex, hence most PMA parts are simple bits.

Peter, if you have something you want to PMA or STC, actually doing it through EASA is the best way. Once approved by EASA, it’s a much easier process into FAA approval. Doesn’t have to cost that much either. Many US companies seek EASA certification these days first, so they can bypass a lot of the rigmarole in approvals in FAA land.

I’ve thought about numerous improvements there would be a market for, if one just had the time to do it. Like switches. How come you can’t get FAA approved replacement switches? Well, there is one company, but they charge almost $450/piece for an illuminated switch! Switches are certified with the airframe, so on old planes you’re stuck with either what’s in there from factory forever, or you buy the $450/piece one. Surely, there must be a market there. Everyone who does their old panel up would love to switch to a more modern type of switch, yet they’re stuck with these old military type standard toggle switches that look like cr*p and don’t illuminate.

There is no EASA PMA system so that is a no-go. One could go for an EASA STC and then get an FAA STC on the back of that (in theory). The data used to obtain the STC can be used to get the other one. The STC itself can’t be used – that would be political dynamite in EASA-land.

Regards the switch (maybe better to start a new thread?) who says you have to use the same one? What is wrong with the Minor Alteration decision chain? Not a “basic change” to the electrical system → Minor Alteration (for a simple part, anyway). I have read this “have to use the same part” on US forums too but it is IMHO just illiteracy on the part of the average A&P, and FUD within the industry.

A milspec switch (APEM are IMHO the best ones) is of the order of $50 – $100, with a CofC. With a Form 1… well, yeah, you will get ripped off. These are used on e.g. a TBM. On a SEP – even a $1M SEP – you get the $5 ($50 with a Form 1) crappo ones.

The combined switch+CB thingies are a different thing… there really are very few alternatives. A lot of people are getting worried about these.

jxk wrote:

Does anyone know whether such a procedure exist within the European environment (EASA)?.

As indicated by others, no, at least not compareable with the FAA/PMA systems. Sometimes you can get away with a minor change approval. This is how some of our products are certified, as well as others Golze WX system, Garrecht TRX, Flarm etc. Unfortunatly FAA doesn’t accept parts with minor change only. So FAA-PMA stations have basically a world wide market, while with EASA you would be limited to EASA aircraft only.

Ultranomad wrote:

In the EASAland, there is a thing called Production Organisation Approval (POA). However, you’ll also need a holder of a DOA (Design Organisation Approval) to design it.

This would be a full approval, which is insanely expensive. I have checked this before in the Netherlands (fees are different between countries) at ours the POA alone is 24180 Euro annually + 2190 Euro per item. You never can get return on some simple / cheap parts. This is the whole reason why FAA-PMA is so succesfull.
Then if you get back a faulty unit you will have to have a Part 145, to maintain/repair.

Under FAA-PMA they can’t repair either, so you will get exchanged (by new parts)

Peter wrote:

but bear in mind that the FAA PMA system is to enable the manufacture of an identical part, not an improved part.

I don’t think this true. For example Slick magneto’s are FAA PMA parts (and you can service them with FAA PMA parts). Or Sky-Tec starters are PMA parts. These are not identical parts.

Peter wrote:

Your best bet is to go for an FAA STC or whatever. For the certified market it will need to be TSOd (in general) and then to sell it easily you want an STC because too many people in the industry cannot read and write well enough to want to do a Field Approval.

For TSO you will need the FAA variant of POA/DOA, which is expensive as well. This is why FAA-PMA system is nice for some products.

Peter wrote:

One was a PMA item and there was a big overhead in getting that for a Europe based business. Another was an STC and that was a bit more doable.

I doubt this is correct. I once investigated PMA route as well, which was only possible at that time when the manufacturing was done in the USA. A full certification is surely far more expensive.

Peter wrote:

The European GA market is really quite poor and the dealers are massively loyal to the big names (i.e. Garmin) because they can phone them up if the installation doesn’t work.

I don’t think this is true either. See Flarm products, or Golze products for example they are quite common.

Have stated before, but having an FAA-PMA like system under EASA (and also acceptable to FAA) would lead to more business in Europe. Lets face it, why couldn’t European companies produce these kind of products? The main reason because it so extremely expensive to start. When you could start with FAA-PMA and grow to an DOA/POA that would be great.

Maybe some developers should step up and make a combined proposal for EASA. I did propose it in the past myself.

Peter wrote:

that would be political dynamite in EASA-land.

Why for EASA, this is both ways, so is similair for EASA and FAA….

Peter wrote:

A milspec switch (APEM are IMHO the best ones) is of the order of $50 – $100, with a CofC. With a Form 1… well, yeah, you will get ripped off.

This is nonsense as well. You don’t need an Form 1 for mil spec parts, as these are standard parts (like MS / NAS / DIN / ISO / AN parts) don’t require an Form 1 at all. Please stop bashing EASA at least with invalid arguments.

Why for EASA, this is both ways, so is similair for EASA and FAA….

because in Europe there is a rubbish “field approval” system, which forces everybody with anything bigger than an ingrowing toenail to go to an EASA 21 company, which is expensive (4 figures plus).

In the USA you can get a Field Approval for almost nothing (well, zero fee to the FAA) and you can get an STC for not much more.

In Europe, an automatic acceptance of FAA STCs would be dynamite which is why it has been talked about for many years and has never arrived. The bilateral treaty we now have is largely empty because to get the EASA STC, the application hs to be made by the US manufacturer (not by the prospective aircraft owner customer) and the US mfg has little incentive to put in the effort for what they see (usually correctly) as a tiny market which is moreover full of complications. The treaty is good for using FAA DER 8110 design data (usually billed to the customer at some stage) to get an EASA STC which can then be sold to other EASA avionics shops

This is nonsense as well. You don’t need an Form 1 for mil spec parts, as these are standard parts (like MS / NAS / DIN / ISO / AN parts) don’t require an Form 1 at all.

Switches are FAA standard parts? Adam would be most interested

All milspec parts are standard parts (which is what you wrote, literally)? That would be useful too. Actually there has been a long debate in the USA about the use of milspec parts. Many believed that they are automatically “approved” in some way, but they aren’t. They do offer some useful concessions. I will see if I can dig it out.

I once investigated PMA route as well, which was only possible at that time when the manufacturing was done in the USA.

I looked into it a few years ago and there was no such requirement, but it was difficult because one would have to host delegations of FAA inspectors, as well as implementing various QA stuff acceptable to them.

Anyway this is nothing to do with PMA.

Peter wrote:

because in Europe there is a rubbish “field approval” system, which forces everybody with anything bigger than an ingrowing toenail to go to an EASA 21 company, which is expensive (4 figures plus).

This is not true. You have CS-STAN and minor changes, which both don’t require an EASA Part 21. You will need an EASA Part 21 when you would also require an STC in the USA according FAA Part 21.

Peter wrote:

Switches are FAA standard parts?

If they are MIL spec as you suggest, yes.

Peter wrote:

n Europe, an automatic acceptance of FAA STCs would be dynamite

So FAA does automatically accept EASA STC right? Or would this by dynamite in USA? It is bilateral Peter, the same on both sides.

Peter wrote:

Anyway this is nothing to do with PMA.

I guess it does, if you can get FAA PMA in Europe, you would be able to have the same privileges and have both EASA and FAA market.