(File 4 of 5)
Barbara Capron, Production and Airworthiness Division, AIR-200
Narration text: This segment covers major changes to subpart L.
Global acceptance & movement of parts
Subpart L - Subpart L has been completely restructured to:
- Facilitate global acceptance & movement of products & articles,
- Remove prescriptive requirements, that will be moved to policy &
- Delete the definitions & usage of the terms, Class I, II, & III products. Use terms for product & article consistently throughout part 21.
Use of export approval documents changed to match most other countries:
- Export C of A (FAA Form 8130-4) will be issued [by the FAA] only for aircraft.
- ARC (Authorized Release Certificate, FAA Form 8130-3) will be used to export engines, propellers, & articles.
- Removes the §21.323(b) restrictions related to who may obtain an Export A/W Approval for former “Class III products.” Facilitates global movement/acceptance of parts.
- Removes the §21.325(b)(3) export requirement that Class II & III products be manufactured & located in the U.S.
- thereby allowing the manufacture of U.S. products & articles in foreign locations
- Addresses a recurring exemption
- Use designees to reduce burden on FAA
Global acceptance & movement of parts, cont.
- Allows export approvals for used engines, propellers, and articles under certain conditions
- Removes the requirement that used engines & propellers be newly overhauled. Intent is to allow importing airworthiness authorities to decide what is acceptable for importing.
- Relocates the requirements of importing countries to policy. We are still obligated to comply with importing country requirements prior to issuance of an export airworthiness approval if those requirements are specified in:
- A bilateral agreement, or
- A document formally submitted to us for publication in AC 21-2
Nathan Leonard, Part 21 Course Manager, FAA Academy and Barbara Capron, Production and Airworthiness Division, AIR-200
Presenter: Greg Edwards, Aircraft Engineering Division, AIR-100
Narration text: This segment covers major changes to part 45.
Part 45, Identification and Registration Marking - Part 21 contained, in numerous locations, part marking requirements. We are taking this opportunity to consolidate all the marking requirements into one place, part 45, Identification and Registration Marking. These requirements apply to all production approval holders, including persons who export their products to the United States.
The marking requirements identify the person authorized to produce that product or article, and also provide a reference to the corresponding approved design data. Furthermore, these markings constitute a representation from that person that the given product or article conforms to its approved design. Only the person authorized to produce the product or article may make this representation.
This does not preclude a supplier of a production approval holder from applying markings in accordance with requirements from that production approval holder and procedures approved by the FAA. Further, it does not preclude applying in-process markings throughout the manufacturing process if necessary.
It does preclude a person from identifying a product or article in accordance with this subpart unless that product or article conforms to its approved design, and is in a condition for safe operation; and, for a TSO article; that TSO article meets the applicable performance standards.
Marking of Products - There are changes to aircraft identification plate location requirements of § 45.11, Marking of Products. A new paragraph (g) provides relief from the aircraft data plate location requirement of paragraph (a).
In the past, we have granted exemptions to §45.11, allowing operators to locate the data plate near the entrance of the aircraft rather than on the exterior of the aircraft near the tail. We have consistently determined that the justifications for granting these exemptions are valid and that granting these exemptions is in the public interest.
Rather than continue to issue exemptions, we have created an exception to the requirement. Aircraft produced for air carriers, commuter ops, gliders, & export may now place the data plate at an accessible location near the aircraft entrance.
Change to PMA article marking requirements
Marking Requirements for PMA Articles, TSO Articles, and Critical Parts - The changed § 45.15, Marking Requirements for PMA Articles, TSO articles, and Critical Parts standardizes and consolidates marking requirements for PMA articles, TSO articles, and critical parts, including an identifier of the person who manufactured the part and the part numbering.
In addition, TSO articles require the TSO number and letter of designation; any markings specifically required by the applicable TSO; and the serial number or date of manufacture or both, unless otherwise specified in the applicable TSO.
The requirement to mark PMA articles with “FAA-PMA” remains in effect. However, “installation eligibility” has been removed. Installation eligibility remains a part of the PMA supplement.
Greg Edwards, Aircraft Engineering Division, AIR-100 and Russell Burke, Course Manager, FAA Academy