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

Revised Guidance for Rotating Parts (Continued Rotation And Rotor Locking)

The FAA is proposing to issue a revision “B” to its Advisory Circular 33.74/92-1B (Turbine Engine Continued Rotation And Rotor Locking).  This AC provides guidance on how to demonstrate compliance with the continued rotation and rotor locking requirements of 14 C.F.R. §§ 33.74 and 33.92.

Marc Bouthillier of the Engine and Propeller Directorate has said that this revision features some updated references, and clarifications of guidance.  He has said that the FAA’s compliance guidance IS NOT intended to be changed in this revision.

We’d appreciate your insights about whether you think there are any substantive changes.  We’d also appreciate hearing from PMA manufacturers that produce rotating parts, whether you find that the requirements of Advisory Circular 33.74/92-1A (the current version) have been applied to PMA applicants.

In addition, the AC has always included in this AC some requirements that appear to go beyond the strict requirements of the regulations.  Many of these are requirements that seem to have been endorsed as sound practices by engine OEMs.  We would be interested in hearing whether the PMA community finds that any of the extra-regulatory requirements of the AC are imposing a burden on PMA manufacturers.

Comments on this proposal are due to the FAA by September 12, 2014 so we would appreciate it if you could provide your comments to us at MARPA no later than the end of August.  You can also file comments directly with the FAA by emailing them to carlos.fernandes@faa.gov

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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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