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

Seeking Working Group Members to Help Develop New FAA Manufacturing Regulations: Apply Now!

Have you ever wanted to influence the regulations that affect your business?  Well, NOW is your best opportunity to do so!

In January, we provided early notice to the PMA community that the FAA would be seeking industry experts to volunteer for working groups that will be rewriting the manufacturing regulations.  Now, we are collecting names and submitting them!  This is a tremendous opportunity to make sure that the regulations reflect the current state of the art for certification and approval processes.

The Part 21/SMS Aviation Rulemaking Committee (ARC) is undertaking a major project to review Part 21 and (1) to make it consistent with ICAO Standards for Safety Management Systems, (2) add regulations to create a design organization and (3) update the regulation as necessary.

The Part 21/SMS ARC has recently completed charters for four (4) working groups that will be helping to craft the Part 21 language as well as developing a new paradigm for FAA oversight of systems.  These worknig groups will report to the ARC, and will be where the real ground work occurs in changing the manufacturing regulations.  We are seeking MARPA members who would like to volunteer to be on these committees.  The first working group meetings will likely be April 3-5 and working group members will need to support the working group efforts through 2013 (final Reports are due December 10, 2013).

The four working groups are:

(1) Design Organization: This working group will develop regulations for design organizations, similar to the DOA regulation in Europe.  Design organizations will have more safety responsibility and accountability, and in turn would receive greater privileges.  The goal of this group will be to help the FAA create design organizations that can serve as the backbone for safety management.

(2) Safety Management Systems (SMS): This working group will help to integrate requirements for safety management systems in to the FAA manufacturing regulations.  The goal of this group will be to better align the FAA’s regulations with the requirements of SMS.

(3) Oversight: This working group will develop a new model for FAA oversight that will better reflect risk management in an era with shrinking government budgets and expanding industry need for government approval and/or certification.  The goal of this group will be to help the FAA create a program to ensure a consistently high level of safety with a dwindling resource pool.

(4) Cost-Benefit Analysis (CBA): This working group will examine the work of the first three working groups and will help develop the data and other tools that the FAA will need to perform a cost-benefit analysis.  The work of this group will be critically important to ensuring that the product from the entire ARC makes good safety sense and good economic sense.

This effort could reflect the most significant change in the U.S. aviation manufacturing regulations in over 50 years.  The results of this effort will touch all of us.  If you think you would like to serve on one of these working groups then please contact us immediately so we can send you more information.  We need to submit our recommendations to the ARC by the end of next week, so we need to hear from you by not later than Thursday, March 7.

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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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