Questions & Answers: 14 CFR Amendments
Part 45 – Identification and Registration Marking
§45.15 - Marking requirements for PMA articles, TSO articles, and critical parts.
- With the change to PMA eligibility marking requirement, will I have to re-mark my existing inventory? No. Those articles marked prior to the effective date need only be marked in accordance with the requirement in effect when they were marked.
- What is the difference between "Identification" and "Marking"? (Reference §45.15(c)) Pursuant to the new part 21 rule, portions of products and articles produced by a production approval holder (PAH) or under a type certificate (TC) that leave the manufacturers facility must include specific identification information (part number and name, trademark, symbol, or other FAA-approved identification). These portions of products and articles include sub-assemblies, component parts, or replacement articles. Identification can be accomplished by marking, tagging, placing in a container, providing a document with the required information, or other FAA-approved methods.
Marking refers to the physical, permanent, and legible application of information such as attaching a data plate, etching, or stamping of a product or article. Required marking information can be found in part 45, subpart B, Marking of Products and Articles. Marking is only required to be applied to the product or article for which the approval is granted and to critical parts, as defined in §45.15(c).
- a. Will the PMA letters be re-issued in order to remove installation eligibility? No. However, all new PMA approval letters will be issued in compliance with the new part 21 rule. In addition all subsequent revisions of current approval letters will comply with the new part 21 rule.
b. What do they do in the interim (since the requirement went away but supplements still list it)? Nothing. The PMA supplements will continue to list the installation eligibility information, even though it is not required on the part.
- Will the 8130-3 be changed to delete the block for installation eligibility? Yes. This will be done upon successful harmonization with European Aviation Safety Agency (EASA) Form 1.
- Is "critical parts" defined? No. Critical parts are referenced in §45.15, however, there is no definition.
- Does guidance allow for installers or suppliers to part mark the parts (i.e. TSO holder for hoses)? If a PAH has authorized a supplier to mark articles, then yes, a supplier may apply the markings required by 14 CFR part 45. With regard to "installers," there is guidance concerning the marking of parts after it has left the manufacturing facility.
FAA Notice 8900.74, Parts marking provides guidance for the re-marking of part when performing maintenance.
Advisory Circular AC 43-18, Fabrication of Aircraft Parts by Maintenance Personnel provides guidance for owner produced parts.
Also a new part 43 AC, titled Parts Marking, has been approved and should publish before the end of the year. The AC will provide guidance for marking parts after leaving the manufacturers facility.
- a. Is it necessary to remove the applicability from the part marking going forward? No. It is not necessary to remove the installation eligibility from the information that is marked on an article.
b. Can we leave the applicability if we choose to? Yes. You may leave the installation eligibility information on the article. However, the installation eligibility must be marked on applicable parts that are delivered before April 16, 2011.
- Is it necessary to issue new (3) page PMA letters to all of our PMA holders in support of the April 14, 2010 compliance date when we will have to issue new PMA letters to all our PMA holders in support of the April 16, 2011 compliance date? Is there a methodology by which existing PMA letters could remain in place until the April 16, 2011 compliance date, thereby necessitating only (1) issuance instead of (2)? No. It will not be necessary to reissue current PMA letters in support of either the April 14, 2010 or April 16, 2011, compliance dates. However, all new PMA approval letters should be issued in accordance with the rule in effect at the time of issuance.
- The eligibility marking in the part is going away requiring only "FAA-PMA." Does the PMA holder still need to provide a document with the eligibility (packing list, tag, etc.) of the part to the customer when shipping the part? No. Although not required, you may send the eligibility in shipping documents if you choose.
- Are PMA marking requirements applicable to commercial parts? No.
- Did AIR-200 address the format for marking an article when it has both a TSO and a PMA? No. When an article is being delivered from the PAH, PAH must specify under which design and production approval the article was manufactured. This is done by identifying the article with either the PMA markings or the TSO markings.
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