Tuesday, March 1, 2005
PMA Industry Facing Maturity Challenge
For many years, the people who created and built the PMA parts industry have been holding their collective breath, hoping that this day wouldn't come but knowing that it was inevitable. (PMA or parts manufacturer approval is an FAA regulation permitting an entity other than the original manufacturer of the part or aircraft or engine to replicate and sell aircraft parts.) Anyone who has spent time with the PMA folks has heard them talk about the potential problem of a fatal accident in which a PMA part was involved. The concern was always that while PMA parts have proven over and over again to be safe, if there ever were a serious accident with a PMA part, whether or not it was that part's fault, that the FAA would crack down on the PMA industry.
Unfortunately, that is exactly what has happened, and the PMA parts industry is facing some increased scrutiny and questioning by the FAA due to a fatal accident. The FAA attention even has its own label: the PMA maturity challenge.
The maturity challenge is a result of the crash of a McDonnell Douglas Helicopter 369D during a tourist flight over Hawaii's Volcanoes National Park June 15, 2003. The pilot and three passengers died in the accident, which resulted from the failure of the helicopter's Rolls-Royce 250 engine. While the National Transportation Safety Board's full report on the accident remains pending, investigators are trying to determine if a part that was PMAed had something to do with the accident.
The engine's compressor splined adapter coupling was a PMA part made by Extex, a long-time manufacturer of PMA parts for Rolls-Royce 250 engines. Nine months after the accident, the FAA issued three special airworthiness information bulletins against three different couplings. One was for the original Rolls-Royce coupling, one for Extex, and one for PMA manufacturer Alcor Engine Company (now Timken Alcor Aerospace Technologies). Superior Air Parts made the couplings as well, but its turbine parts division split off to form Extex. SAIBs are non-regulatory advice issued by the FAA to inform the maintenance community about safety problems. SAIBs are supposed to cover items that don't warrant a mandatory airworthiness directive.
Nevertheless, the FAA did issue an AD on the Rolls-Royce compressor splined adaptor coupling, effective February 8, 2005. AD 2004-26-09 applies to couplings made by Rolls-Royce, Extex, Alcor, and Superior Air Parts. "This AD results from nine reports of engine shutdown caused by coupling failure," the AD stated. "We are issuing this AD to reduce the risk of failure of the compressor adaptor coupling and subsequent loss of all engine power."
Where does the so-called "maturity challenge" fit into all this? The maturity challenge emerged in an FAA-sponsored meeting of the Joint Management Team held May 2004. The team includes people from the FAA, the Modification and Replacement Parts Association, Aerospace Industries Association, General Aviation Manufacturers Association, and Air Transport Association. The FAA's concern is that PMA manufacturers need to develop a more comprehensive attitude toward something called "continued operational safety."
Many PMA parts, including the adaptor couplings mentioned above, are made through a process called test and computation. In this process, a part that a PMA manufacturer wants to duplicate is analyzed dimensionally and carefully scrutinized for its material makeup. Using appropriate tools, a PMA manufacturer can learn exactly what materials a part is made of and the precise shape of the part, such that the FAA will agree that this part duplicates the original so precisely that the agency will certificate it as a legitimate replacement. This is the most common PMA process, and it has been used for simple parts like gaskets to highly complex and quality-dependent CFM56 turbine blades.
A key feature of the test and computation process is that because the part duplicates the original manufacturer's part, the FAA has allowed the PMA industry to use the OEMs' maintenance procedures. In other words, if a PMA manufacturer makes, say, a replacement turbine engine combustion liner that is a duplicate of the original via test and computation, the instructions for continued airworthiness (ICA) for that part are simply the maintenance procedures issued by the OEM. The PMA manufacturer, essentially, doesn't have to develop an ICA for the part because it's not really necessary and it would complicate the operator's requirement to track, revise, and reference duplicate maintenance manuals.
But what if there is a problem with a PMA part and the original ICA doesn't really address the problem? What if there is a part like the Rolls-Royce 250 coupling made by three different manufacturers and this part causes a problem and it's not clear whether the original design is the issue? Shouldn't the PMA manufacturers address the continued operational safety of their products after they enter service? This was the focus of the Joint Management Team meeting. Nothing was decided at the meeting, just discussed, and it's not clear whether the FAA is going to add some new ICA or continued operational safety requirements for PMA manufacturers.
In the case of the Rolls-Royce coupling, the AD clearly affects every part, not just the PMA parts. Rolls-Royce has developed a new part with a new silver coating to replace the original and this does satisfy the requirements of the AD.
What is interesting about this AD is that it requires the removal from service of the PMA couplings quite soon, from within the next 50 hours service for the Extex coupling to within 50 hours for Superior or Alcor couplings that have flown more than 600 hours. The Rolls-Royce couplings don't need to be removed until the next time the compressor is disassembled "for any reason" or not later than March 1, 2012. There is no hour or cycle limitation on the Rolls-Royce couplings.
So is the FAA saying that it's kind of a design issue with the Rolls-Royce couplings, but that the PMA couplings are a little bit worse? What really happened is that the PMA manufacturers asked the FAA to impose more stringent requirements in the AD for removal of their parts from service. Rolls-Royce is dealing with the issue in its own way, with a new part and stringent assembly procedures that are aimed at taking care of the coupling problem.
"Every company got to put in their recommendations," said Barry Stonehouse, general manager at Timken Alcor Aerospace Technologies. "I wanted to see some parts," he added, explaining why Alcor wanted the couplings removed fairly soon, in order to see if the Alcor couplings were cracking. " I needed to see parts to see if I had the same problem. The only way I could do that was to make my requirement almost immediate because I had no data."
There was some concern with the couplings made by other companies at Alcor prior to the Hawaii crash, according to Stonehouse. "I heard of the problem and started looking at parts before the crash and had a fix proposed. I still had no warranty parts [from Alcor users]. We looked at our coupling, the Extex, and Rolls parts. And we came up with a solution. We proposed it to the FAA, they gave the go-ahead, then the crash happened."
After the crash, Alcor's proposal was tabled by the FAA, but Alcor issued its own service bulletin shortly after the crash. This was done even though Alcor had not been able to find any problems with its couplings. "We haven't any warranty problems," Stonehouse said, "or any failures." Extex issued an alert service bulletin dated May 4, 2004.
The coupling situation precipitated the maturity challenge issue and highlighted the fact that the FAA wants PMA manufacturers to become more mature in terms of their approach to in-service issues.
Many companies within the PMA industry are well aware of the FAA's maturity challenge and have been addressing this at conferences and within the ranks of the PMA association, the Modification and Replacement Parts Association or MARPA.
"MARPA's view of the PMA industry," said a MARPA statement issued last year, "is one that is rapidly moving from its beginnings to a full-fledged and mature industry. The swell of PMA holders has now expanded to nearly 2,000 individuals and corporations producing an astonishing array of critical and noncritical parts. No longer is the PMA industry in its infancy, but its obvious success is moving it continually toward more universal acceptance as a legitimate player in the modification and replacement parts market. This success, in MARPA's view, must be accompanied by a focus toward meeting the challenges of a maturing industry."
MARPA has issued the following challenge to all PMA holders, including its membership (and OEMs, as well, because most OEMs hold PMAs for their own parts):
- Accepting and executing full responsibility for the FAA approved parts performance in-service regardless of the basis of FAA approval and regardless of the degree to which OEM design features are integrated.
- Providing timely feedback to the FAA on any service problems and taking immediate initiatives to prevent problems regardless of the root cause being design, manufacturing, or maintenance.
- Stressing the operators' needs: should the service performance indicate the need for a production approval holder (PAH) to issue an alert service bulletin (which could become an airworthiness directive), the PAH should meet the goal to keep operators' products available and safe. The PAH must work closely with the FAA to assume timely safety assurance with minimum schedule and cost disruption for the operator, whether air carrier or general aviation, domestic, or international
- Embracing the principal of exemplary design, production, and support.
"To meet the maturity challenge, PAHs need comprehensive procedures and self-audit but most of all, they need talent, experience, and commitment commensurate with the complexity and failure consequence of the type of parts they are delivering to industry.
"The PMA maturity challenge means the PAH is responsible for the operators' continued operational safety and aircraft availability as impacted by the PMA parts."
For their part, PMA companies say they are meeting the maturity challenge.
"We are strong believers in that initiative and we're trying to push beyond what most people are considering doing," said Robb Baumann, executive vice president marketing and sales for PMA manufacturer Heico. "If you're going to sell the parts, you're going to need to support the parts. Heico is taking that seriously."
"I think everybody in MARPA has taken PMA seriously from the beginning," said Pat White, president of PMA company Rapco and board chairman of MARPA. Being a member shows that they are embracing the maturity challenge."
Growth Industries, which specializes in expendable parts for large-aircraft landing gear and noncritical interior parts, maintains a database that tracks serialized parts. "We have a good history of PMA parts that we've been manufacturing for some time," said John Droege, vice president of marketing. "One of the most important things," he added, "is that I visit customers once a month, to see how our parts are doing. And also to find out new opportunities. With people who have their hands on [the airplane], you get the true story about parts, where a part was wearing [for example], and maybe you can tighten up the tolerances some and help them out."
"The challenge is a whole lot of things wrapped up into one big word," said Alcor's Barry Stonehouse. "We've got to come up with a support system for our parts like the OEM, whether it's service centers or warranty centers. We have three companies appointed as warranty centers [for Alcor]. The challenge is taking responsibility. Don't just make a part and send out an invoice and think you're done. That's really where your job starts. It's an industry now, not just people making parts because they're mad at an OEM."
Alcor does have its own parts-tracking system, but that isn't necessarily the solution to continued operational safety, according to Stonehouse. "The biggest thing," he said, "is a very good relationship with our customers. You can put all the tracking in place you want, if the customer is not willing to use it or exchange information freely, it's worthless."
Alcor employs three experts, each with 20 years of experience on the Rolls-Royce/Allison 250 engine. They speak with Alcor's customers every day, Stonehouse said, "and that's how we found out about the [coupling] problem."
The investigation into the Hawaii accident launched the PMA maturity challenge. In fact, MARPA's George Powell said he saw an internal FAA document, which wasn't supposed to be public, that captured the FAA's concern about a year after the accident. The document, Powell said, included this statement: "When are PMAers going to grow up and assume their responsibility?"
The PMA industry has responded, and MARPA has formed a committee to address continued operational safety. Heico's John Hunter is committee leader, and Alcor's Stonehouse is on the committee as is Powell. The FAA's Jay Pardee, who has worked closely with MARPA, is serving as an advisor to the committee. And not all invitees to the committee are MARPA members.
At the Joint Management Meeting in 2004, Stonehouse and Powell attended and noted that one of the PMA companies suggested that if there is a design problem with an OEM part that has been duplicated under PMA, then the responsibility should belong solely to the OEM. Stonehouse didn't agree and made his opinion clear. "We've got to deal with it. PMAers need to be responsible for their parts," he said. "It's something we have to do."
Heico has a long history in the PMA business and sells many critical aircraft parts to a variety of customers, including large airlines such as American Airlines, Delta Air Lines, and Lufthansa (which is also a Heico part-owner). The company has certificated more than 3,500 parts so far and has plenty of background monitoring the in-service experience of its parts.
"From small things can come big problems," said Steve Szpunar, Heico's senior vice president technical services and responsible for after-sale support. "All these problems have precursors, and it's important to keep our ear on the rail, to see if something is coming early. If you have a problem, you want to find it before you make 1,000 of them."
Heico keeps field representatives on-site at its major customers, and any time there is a returned part, data about that gets entered into Heico's tracking system. "If there's a problem," Szpunar said, "we're going to find out about it."
Szpunar, who came to Heico about nine years ago after many years at engine manufacturer General Electric, is convinced that PMA companies like Heico can better react to information about parts problems than giant OEMs. "Being smaller," he explained, "we can put the pieces together faster. With OEMs, sometimes things can get brushed under the rug. There have been nagging problems at OEMs for years that PMAers have had to solve, and they aren't a big issue to the OEM. They don't have the resources to address it like we do. We've got a little sharper focus. They probably have a more of a global fleet reliability viewpoint. Unless something is causing an inflight shutdown problem, they'll just manage it as best they can."
Of more interest to Szpunar is that PMA parts still aren't a safety problem in aviation. The Extex coupling remains unindicted in the Hawaii crash. The NTSB is examining whether the Extex coupling played a role, and whether that was due to the engine's design, the original design of the coupling, or the test and computation replication of that design. The NTSB report is pending and no blame has officially attached to the Extex part.
"Even with all the PMA parts in the field," Szpunar noted, "[industry-wide] inflight shutdown rates and reliability, all have gotten better. If PMA parts were such a problem, we'd know."
Szpunar feels that despite PMA parts' exceptional safety record, it remains important for PMA buyers to ask critical questions of PMA suppliers, in order to keep quality at a high level. Buyers should ask, he said, if the PMA company can provide support if there is a problem with the part, no matter whether it's the PMA's or the OEM's design problem. If there is a failure, can the PMA company investigate properly and test its parts to find the root of the problem? Does the PMA company have a deep understanding of failure modes, does it track the parts it sells, does it keep accurate traceability back to the raw materials? "Most PMAs can do this," Szpunar said, "but the customer's got to review that."
"The tough part of it is, if you get into [making a PMA] part," said MARPA's George Powell, "you've got to know as much about that product as the people who originally designed it. It's possible that you don't need to know about the [OEM's] entire product. Pat White [of Rapco] knows more about brakes than any OEM."
"The FAA," said White, "has grown reliant on OEMs as the people who give answers. The FAA [now] wants the PMA manufacturers to prove to the FAA their technical competence. PMAers need to be responsible for the part, on the individual application. There's a widely held belief that PMAs just cherry pick [the easy to make parts], and that PMA companies say, `we just make it, if there's a problem, you've got to talk to the OEM.' But that is what responsible PMA companies avoid doing. Now they're saying, `this is what we do if there is something wrong.'
"All the PMAs are getting the word. It's number-one of our priorities. We as PMA companies get bunched together. So when somebody, a MARPA member or nonmember, any PMA, has a misstep in this industry, it reflects on all of us. A mistake made by somebody else makes all our lives difficult."
The upshot of this whole maturity challenge is that not only will PMA manufacturers become more educated, but so will the consumers of aircraft parts, the owners and operators and maintenance companies. "It's fairly consumer-driven," White concluded. "They're going to dictate to the manufacturer [whether OEM or PMA] what they require, what's the procedure if they have issues down the road."