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FAA, FAA Production Approval, Manufacturing, PMA, Regulatory

Time is Running Out to Get Your New FAA-PMA Quality Manual Approved

Have you submitted your new quality manual to the FAA, yet, for approval?

Under the new Part 21 regulations (which become effective April 16, 2011), every PMA holder will be required to have an approved quality manual.  14 C.F.R. 21.138.  That rule was changed in a rulemaking that was originally published in its final form in the Federal Register on October 16, 2009.  Production and Airworthiness Approvals, Part Marking, and Miscellaneous Amendments, 74 Fed. Reg. 53368 (October 16, 2009).

Dorenda Baker, the FAA Director for Aircraft Certification, has gotten in touch with MARPA to let us know that the FAA has not heard from 47% of the existing production approval holders.  This is a concern, because time is running our to get FAA approval of the new manuals that will be necessary in mid-April.

To facilitate timely review and approval of PMA quality manuals, the FAA has recommended that the manuals (and organization descriptions) should be submitted well in advance of the April 16, 2011 compliance date.  FAA guidance on transitioing to the new regulations is available in AC 21-42.

The FAA has stated that a production approval holder may not continue to operate after April 16, 2011, unless it does so under a FAA-approved quality manual that meets the new requirements.  See AC 21-42. Given the volume of manuals that still need to be approved, it is important to get your manual into the local office NOW if you have not already submitted it.

The FAA has said that where a PMA company has an existing arrangements (like a MOU) with the FAA that permits the company to operate under a manual amendment in advance of FAA-approval of the amendment, this may permit the company to operate under the new changes in advance of the FAA-approval, but we recommend that the company seek written verification of the applicability of this policy with the local MIDO before relying on it.

Baker seems ready to take the position that  failure to provide a copy of your new manual to the FAA by or before April 16, 2011 is an indicator that the company’s quality  system may no longer comply with FAA requirements.  This could  be used as a criterion for targeting enforcement resources.

If you have not yet submitted your new quality manual for FAA approval, you may also wish to request a copy of the MARPA checklist that we circulated last year, as an aid to ensuring that all of the new elements are included in your manual. MARPA members can call us at (202) 628-6777 and ask for a copy.

The FAA also has some additional resources to assist in making the transition:

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About Jason Dickstein

Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.

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