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Aircraft Parts, aviation, FAA, FAA Design Approval, Manufacturing, PMA, Policy

FAA Rules for Which Project Comes First

The FAA has published a draft Sequencing Standard Operating Procedure (SOP) for public comment.

The draft SOP would provide local Aircraft Certification Offices with guidance on how to sequence approval, certification, and validation projects.

The first category of projects are those than can be completed in 40 hours or less.  This includes all FAA time spent on the project, including ACO staff time, MIDO staff time and Directorate Standards Staff time.  Projects that are expected to be completed in 40 hours or less remain in the ACO in which they were submitted and are worked without going through the sequencing process.

All other projects receive a safety index (SI) and are sequenced based upon an adjusted SI that is based on the original SI, further amended by additional points added each week (so that projects will eventually rise to the top of the list, even if their original SI was quite low).

One thing that remains unclear under this protocol is how category one projects (non-sequenced projects) are ranked against all other projects.  For example, if an ACO is working on an existing major project (600+ hours) and then gets four new 30 hour projects (below the sequencing threshold), how does the ACO allocate its staff – will any of the staff time be allocated to the new projects, and if so then how much staff time will be allocated to such projects?

Safety Index:

For sequenced projects, the safety index (which provides the project’s initial ranking) appears to be based on the following factors (these are the values established for certification and approval projects):

Safety Index = Safety Impact x Passenger Impact x Affected Fleet

Safety Impact Values

  • 8: Prevent/mitigate accident or near-term safety impact
  • 6: Program of defined strategic importance (programs defined by Congress of the FAA as high priority)
  • 4: Longer-term safety impact
  • 2: Negligible safety impact

Passenger Impact Values

  • 7: > 20 passengers
  • 6: 11-20 passengers
  • 5: Public safety aircraft (e.g. firefighting aircraft)
  • 4: 0-10 passengers
  • 0: public use aircraft [note that this means that all public use aircraft projects start with a value of zero]

Affected Fleet Values

  • 5:incorporation into product line
  • 3:five or more
  • 1: less than five


The FAA website says that comments are due to the FAA by September 25 (the Federal Register gives us until October 3).  MARPA will be filing comments, so we would appreciate hearing from our members by the end of this week with their feelings.

One topic that concerns the Association is whether the industry feels that the Safety Index values assigned to different fact patterns are fair and reasonable.

For example, in Appendix One, the FAA has assigned safety index values for certification and validation projects.  One of the variables in this equation is the “Effected fleet index” [sic].  The suggested values provided in that calculation assign a value of “3” where the affected fleet consisted of 5 or more aircraft. They assign a value of “1” where the affected fleet consisted of fewer than 5 aircraft.  But regardless of the size of the affected fleet, if the project will be incorporated into a production line then it is assigned a value of “5.”  This may permit very different SI values to be assigned to two similar projects that are only different because of the type of production approvals currently held by the applicants.


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 Air Carrier Purchasing Conference, and the Modification and Replacement Parts Association. He also represents private clients drawn from the spectrum of the aviation industry.


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