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

Early Notice of an Opportunty to Influence the Future of Aviation Manufacturing

Last month, we asked members and readers to respond to a series of questions designed to help guide MARPA as to how the regulations are working, how they are not working, and what we can do to make the aviation manufacturing regulations work better to protect safety.  Thank you to those of you who sent in emails in response!

The questions and answers were meant to support MARPA’s work as part of the FAA Safety Management Systems (SMS)/Part 21 Aviation Rulemaking Committee (ARC).  Jason Dickstein of MARPA and Dennis Piotrowski of BELAC are both representing the PMA community on that ARC.

The ARC is undertaking a major project to review Part 21 to make it consistent with ICAO Standards for Safety Management Systems.  The ARC also plans to recommend a number of clean-up and house-keeping changes to Part 21 – some of which have been waiting many years for an opportunity for implementation.

There is still time to answer last issue’s questions and let MARPA know what you think needs to be changed in the regulations; but this month we are giving you early notice of an opportunity to participate more directly in the rulemaking process.

In mid-February, the FAA ARC will publish Terms of Reference describing the work of each of several working groups that will be helping to craft the Part 21 language as well as developing a new paradigm for FAA oversight of systems.  At that time, we will be seeking MARPA members who would like to volunteer to be on these committees.  The first working group meetings will likely be in early April.

So be on the look-out for a mid February announcement about those working groups—we would like to get PMA representatives on every one of the working groups to make sure that the industry’s interest are protected—and we will be looking for statements of interest so that we can nominate some members.


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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