Production Approvals

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The three ways an avionics manufacturer can build and ship airworthy parts per 14 CFR are: 

(1) - Under an aircraft OEM's FAA production certificate (i.e., shipping direct to the OEM); 

(2) - Under an FAA Parts Manufacturer Approval (PMA) production certificate, or;

(3) - Under a Technical Standard Order Authorization (TSOA) production certificate 

While any manufacturer can ship anything an OEM wants as an approved supplier to that OEM, that doesn't authorize that manufacturer to ship to anyone other than that OEM. It also doesn't enable a manufacturer to certificate that a part is airworthy (which is done via issuing a form known as an 8130-3 Airworthiness Certificate).

The other two ways require that the manufacturer obtain a production certificate themselves from the FAA specifically for their manufacturing facility. This can be accomplished by manufacturing under an FAA Parts Manufacturer Approval (PMA) or an FAA Technical Standard Order Authorization (TSOA) issued by the FAA. There are well defined requirements necessary to obtain these production approvals but knowing how much flexibility you have in your processes can be key to having a cost-effective manufacturing system that meets the requirements of 14 CFR Part 21. It’s very common for manufacturers to inadvertently add unnecessary complexity in their quality management systems that go well beyond what Part 21 requires. 

The aviation industry quality standard AS9100, for example, includes requirements for your quality management system (QMS) that go beyond anything the FAA requires. But once those complexities are incorporated into your FAA approved quality system, the FAA will require you to follow them whether they are related to 14 CFR or not. My favorite quote from a senior FAA branch manager is “Be careful what you put in your FAA approved manuals, because if you document doing stupid things we’ll require your to do those stupid things!” While noncompliances to AS9100 may cause you to lose your registration, noncompliances to the FAA approved quality system can make you subject to civil penalties. 

I’ve also dealt with the quality management flow down requirements from OEM manufacturers like Boeing, Airbus, Embraer, and Gulfstream. One advantage in knowing what the FAA (and foreign regulatory agencies) require of the OEMs is that it provides insight into what the OEM flow down requirements are really trying to ensure. That’s particularly helpful in understanding what an OEM is requiring in addition to regulatory requirements, as those requirements can be altered or even waived by the OEM. 

In summary, whether it’s obtaining your first PMA/TSOA production approval from the FAA, obtaining PMA or TSOA, finding ways to simplify your existing quality management system to optimize compliance while providing you with the maximum flexibility, or helping understand OEM flow down requirements, I can provide you with a broad perspective and potential improvement areas.