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aviation, FAA, FAA Design Approval, Manufacturing, PMA, Regulatory

What Should Be the Minimum Standards that Apply to Any Company that Holds Design Approval?

As many of you know, MARPA has been an active participant in the FAA’s efforts to develop both Design Organization and SMS regulations that would apply to the manufacturing community. This gives our members an exceptional opportunity to influence the regulations so that they will make sense and preserve safety.

The FAA is working on regulations that would require most design approval holders to be Design Organizations, which would be similar to EASA DOAs (under EASA subpart J in Europe).  FAA Engineering Division Manager Dave Hempe will be at the MARPA Annual Conference to talk to companies about the costs and benefits of such a requirement.

The smallest companies (including many PMA companies) could be excepted from those design organization rules.  But even those excepted companies will likely have to met some standard; the lower risk posed by excepted companies would mean that the standards applied to them could be lower.

This raises the question “how much of an organization SHOULD a small company be required to have as a minimum FAA standard?”  We will be looking to the PMA community to help answer this question!

Soon, we will be soliciting volunteers for a limited engagement subcommittee that will be tasked with recommending those minimum standards.  We anticipate that volunteers will be expected to commit to participate in between one and three one-hour-long telephone conferences – there will be no live meetings and no travel required.  The purpose of those calls will be to solicit input about minimum standards that could apply to all design approval applicants and holders (even the smallest ones).

We really are going to need your help on this so please consider donating your time in order to register your opinion about what is reasonable for your business to do.

We will be publishing more details soon, but please contact us if you think you would like to participate!

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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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