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Aircraft Parts, FAA, FAA Design Approval, FAA Production Approval, Manufacturing, PMA, Regulatory

Part 21 is Coming … Really!

The Part 21 rulemaking—a complete overhaul of the Part 21 manufacturing rules—has been released from OMB and will be published in the Federal Register in a matter of days.

This new set of rules is expected to have a number of small effects on PMA manufacturers … but when you put a few small effects together they can add up to a big effect, so we are cautiously awaiting the final language.

MARPA was active in the public elements of the rulemaking process. MARPA’s three founders all participated in the ARAC Rulemaking Committee that proposed the rule to the FAA in February 1999. We also filed public comments during the notice-and-comment period.

MARPA will continue to be actively involved in the rule change. We are working with the FAA to help arrange a series of public meetings at which the FAA can introduce the major features of the new rule, to better support the compliance process. Look for these meetings happening in the last two months of 2009. MARPA also plans to host a Winter meeting with the FAA, so that companies can talk about the hurdles they may be facing in implementing the new standards in their own facilities.

Of course, we will also maintain a regular dialogue with the FAA about this rule, so if you recognize problems in the new rule (e.g. new rule encourages unsafe practices, higher-than-expected costs, unexpected impediments to implementation, etc.), then please alert us immediately so we can be sure to begin working with the FAA on resolving any such problems.

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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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