Change Your Fabrication Inspection System to a Quality Control System to Meet the New Parts 21 and 45 Rule Requirements

With the newly issued 14 Code of Federal Regulation, Parts 21 and 45 rule, published in the Federal Register, dated October 16, 2009, the Federal Aviation Administration (FAA) has changed the requirements in which Part Manufacturer Approval (PMA) holders are required to implement their operating system. DB Aerospace can provide you with expert assistance in meeting these requirements.

Background on the New FAA Requirement

As required by the new rule, the following are key points:

1. PMA holders have 18 months from April 2010 to develop and implement the new Quality Control system requirements stipulated in Part 21. 
2. It is my understanding that the FAA will accept your manual any time prior to October 2011 as your intent/commitment that your company complies with the new requirements. 
3. Their assurance/verification will come at a later date via an audit/inspection which will or will not verify your compliance. 
4. If there are findings of non-compliance with your manual/operating system, the FAA has the option to disapprove your PMA authorization, issue a civil penalty, or both until such time you comply. 
5. Based on the number of PMA holders and other production approval holder issues your local Manufacturing Inspection District Office have to deal with, that reactivation of your approval could take months, which will impact your capability to produce your PMA article (article vs. part is one of the many changes imposed by the rule change).

As a result of the above and the importance to get your system converted to comply with the rule/policy changes well in advance of the deadline, and to avoid any findings of non-conformances with your operating system, I am offering my professional services.  I have a very good in sight to the FAA’s intent for the new quality system; the ability to modify your manual; and the experience to perform an internal audit of your system to determine compliance.