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Aircraft Parts, aviation, Continued Operational Safety, FAA, FAA Design Approval, FAA Production Approval, Legal, Manufacturing, PMA, Regulatory, Safety Management Systems

Your Input Needed: How Can the FAA Manufacturing Regulations Better Protect Safety?

The FAA is working to incorporate Safety Management Systems (SMS) elements into the existing Part 21 regulations for design and production.  As part of this endeavor, they have asked MARPA to assist them in an Aviation Rulemaking Committee (ARC).

MARPA has long been involved in SMS, having taken steps to educate the membership about the elements of SMS as well as been involved in drafting proposed regulations to implement SMS for FAA certificate holders, generally.

This new ARC represents an opportunity to ensure that the Part 21 regulations better reflect the safety needs of the industry and the public. It is a potential opportunity to remove regulations that no longer add value and to add regulations that would better ensure safety.

Following is a list of questions that we’ve developed that will help us to identify potential changes to Part 21 that might be made in the context of implementing SMS in the Part.  We would appreciate your answers to any or all of them.  While we cannot promise than any particular proposal will be implemented into the regulations, your thoughtful answer will help guide our participation on the ARC and will help us develop constructive recommendations to advance the regulatory revision process.  Where it is relevant, separating or distinguishing your answers with respect to the design, production, or other elements of the Part 21 regulations would be helpful.

Question One: What does the FAA do that you think is not necessary to safety?

  • design
  • production
  • other

Question Two: What does the FAA require you to do that you think is not necessary to safety?

  • design
  • production
  • other

Question Three: What additional activities do you think regulated aviation businesses should accomplish to better support safety?

  • design
  • production
  • other

Question Four: What additional support or information could the FAA provide that would better support safety?

  • design
  • production
  • other

Question Five: What information do you submit to the FAA that you think is not necessary to safety?

  • design
  • production
  • other

Question Six: What additional information could you submit to the FAA that you think would help promote safety?

  • design
  • production
  • other
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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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