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It hasn't changed significantly. There have been a few instances, and I'm not sure where they stand now, especially after the 737 Max incident. As I mentioned earlier, there's a production approval that follows a design approval. In the production approval process, a lot of delegation happens to manufacturers, including Jet Parts Engineering. For instance, when Jet Parts Engineering inspects a part after manufacturing and issues certification paperwork for that specific serial numbered part, if it is serialized, that inspection is delegated to the JPE employees. At some point, Wencor and Heico received approval from the FAA to have their designs approved by their in-house Designated Engineering Representatives (DERs), rather than having to go to the FAA. These DERs are different from the ones for repairs. One approves a repair design, while the other approves a manufacturing design of a part.
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As part of the MIDO approval for Jet Parts Engineering, a quality plan is required. This plan stipulates that you must control your subcontractor manufacturers. Additionally, the FAA has the authority to inspect these subcontractors. Furthermore, if you choose to have a manufacturer outside the United States for a specific part, you must obtain FAA approval for that country to manufacture that part. For instance, one of the challenges for PMA companies subcontracting parts to China is that for that washer, nut, or shaft, you would need to arrange for a US government employee, an FAA employee, to inspect a Chinese manufacturer. Does that make sense?
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