Opinion: Misused Aviation Terms Can Have A Regulatory Impact

Words matter. They shape thought, drive behavior, evoke emotion, influence action and reflect values. Why, oh why, does the civil aviation industry, which is controlled by national aviation safety authorities, persist in using words that do not matter?

I challenged the establishment in January by calling out the erroneous use of the acronym “OEM” (Inside MRO January-February, p. MRO 8). It is pervasive, well recognized and a perfect example of something that means nothing in civil aviation. The words represented by those letters—“original equipment manufacturer”—are equally meaningless. The same can be said for “MRO.” Somehow, though, these terms persist and even thrive . . . and it matters.

“In civil aviation, there are no OEMs, only design and production approval holders,” I wrote in that ARSA Update column. “Using ‘OEM’ is misleading and can create potential violations by producers. Commercially, the term has little impact without a contractual definition that does not contradict the requirements of the civil aviation authorities for the producer of the article to hold an approval.”

Stay out of that trouble by revisiting the fundamentals of regulatory definition. Starting broadly: Civil aviation authorities control the design, production, operation and maintenance of civil aircraft. To produce a part that is used in civil aviation, one must have authorization or the privilege to manufacture that article. In America, the producer that knew, or should have known, that a part is used on a civil aircraft must have the authority or privilege to make it.

The approval to manufacture is provided by the FAA and includes a production certificate (PC), parts manufacturer authority (PMA) or technical standard order authorization. If the part is produced by or for the owner/operator or a maintenance provider, the article must be made to an approved design and eligible for installation. The people who make installation decisions must have maintenance authority, in the form of an air carrier, repair station or mechanic certificate.

Most PMAs are issued to companies that also provide parts to other production approval holders, which makes them, in fact, those euphemistic “OEMs.” Some PMAs are obtained through licensing agreements, while others are reverse-engineered. Even the original supplier of assemblies to PC holders does not hold the design rights or intellectual property to all the individual spare parts inside those units.

When a line replaceable assembly does not meet the reliability expected by the customer, that operator often looks for alternatives. The options include repairs and the replacement of internal parts that are failing unexpectedly or frequently. Often, those changes make the article and the aircraft more reliable and safer to operate.

Words matter, so use the right ones. In aviation, an approved manufacturer is a design and production approval holder, not an OEM. Maintenance includes repair, overhaul and the replacement of parts—so “MRO” is redundant. Maintenance providers have the authority to perform maintenance and alterations. It is not unusual to perform both maintenance and alteration on aircraft or components.

Contracts in civil aviation need to use the words associated with regulatory compliance, not those derived from common usage and laziness.

Sarah MacLeod is managing member of Obadal, Filler, MacLeod & Klein and a founder and executive director of the Aeronautical Repair Station Association. She has advocated for individuals and companies on international aviation safety law, policy and compliance issues since the 1980s.

The views expressed are not necessarily those of Inside MRO.