How DERs can assist with PMAs

We've covered why working with a DER matters for certification projects in general. This post focuses on how that relationship works specifically for Parts Manufacturer Approvals.

A Designated Engineering Representative is an experienced engineer designated by the FAA to perform certain engineering functions on the agency's behalf — including reviewing and approving the engineering data in a PMA submission via Form 8110-3. For a PMA applicant, that means your DER isn't just a reviewer. They're the person whose approval closes the engineering side of your package before it ever reaches the FAA.

Here's what that looks like in practice across the PMA process:

Compliance path selection. Before any data is developed, a DER helps determine whether your part should follow the identicality or test and computations route. Choosing the wrong path wastes engineering resources and time. A DER who understands the part, the available data, and what the FAA expects can make that call correctly upfront.

Application review. A DER reviews your PMA application for completeness and accuracy — engineering drawings, material and dimensional data, test reports, quality control procedures. The goal is to ensure the package includes everything the FAA requires and that nothing generates a preventable comment.

Engineering analysis and substantiation. A DER performs or reviews the engineering analyses that support your application — stress analysis, comparative analysis, material equivalence, whatever the part demands. This is the substantiation work that proves the PMA part meets the applicable airworthiness standards, and it's where most of the technical depth in a PMA package lives.

Test witnessing. When testing is required, a DER can witness PMA testing and inspection to ensure tests are conducted properly and results support the certification case.

8110-3 approval. This is the central piece. When a DER is satisfied that your engineering data meets FAA requirements, they issue a Form 8110-3 — an approved data finding that carries the FAA's authority. That approval is what allows the FAA to process your submission without conducting the full engineering review internally, which is the single biggest factor in how long a PMA takes to get through the system.

The difference between a PMA package submitted with DER findings and one submitted without is usually measured in months. The FAA still reviews the submission, but the engineering approval is already done — and problems that would otherwise surface as formal FAA comments have already been found and resolved during the DER review. For a deeper look at why that changes a project, read our post on why working with a DER matters.

Where Prime Propulsion Fits

Our in-house DER has guided dozens of manufacturers through the PMA process and understands how to build a package the FAA will accept the first time. We help with compliance path selection, substantiation, 8110-3 approval, and everything in between — from initial scoping through final PMA issuance.

If you need assistance with your PMA certification, contact us — there's no cost to talk through where your project stands. You can also read the Ultimate Guide to FAA PMA Certification for a step-by-step look at the full process.

Prime Propulsion delivers expert FAA certification solutions for small to medium-sized aerospace firms. Our DER-led team specializes in PMA, STC, Test Cell Correlations, and Repair Specification support.