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MARPA and Other Trade Associations Fight to Prevent FAA From Being Assigned Needless Tasks

Some of you may have heard that there is legislative language that would force the FAA to promulgate unnecessary regulations related to marking of “influencing parts.”  These would be defined as parts that can affect an engine LLP; there is no further refinement that would limit the scope of the term “affect.”

The proposed legislation would require the FAA  to issue regulations for marking these “influencing parts.” Ordinarily, you mark a part because the part marking is perceived to be useful; but it appears that the proposed markings would not be used for anything.  No guidance for what should be marked on new parts is indicated, so one cannot even guess at the purpose that such markings might achieve.

Under the proposal, the FAA would also be required to issue regulations for “post repair marking or identification on an influencing part [to reflect] the drawings and specifications used to gain the repair design approval issued by the Federal Aviation Administration.” What is wrong with this picture:

  • Remember that the description of the work performed is required to be on the approval for return to service and is typically included in the work order as well, so this marking requirement is generally redundant.
  • The FAA has no uniform identification system for drawings and specifications, and drawings and specifications are typically proprietary, so the reference would also be meaningless to third parties in many cases, thus the specific requirment provides no value.
  • Given the fact that hot section parts generally will lose markings due to the conditions inside the engine it appears that this requirement is not calculated to achieve anything useful for such parts.
  • Finally, marking engine parts in a way that will not be rapidly eradicated may require physical marking (like vibra-peening); such marking practices need to be researched for individual parts because of the possibility that they may undermine the strength or integrity of the part (thus wasting resources better spent on protecting safety).  So such marking requirements may actually undermine the safety of aircraft engines!

Perhaps the most important issue here is that anything that seemed good about this proposal already exists in FAA regulations and/or guidance.  The FAA has been diligent on the issues surrounding this proposal, and legislation is not needed.  Legislation of this sort would only serve to divert important FAA resources away from issues that really do affect safety.

Several trade associations have banded together to write Congress about the impracticality of this proposal.  The letter is being transmitted to Congress today.

Special thanks go out to Daniel Fisher, the Vice President of Legislative Affairs for ARSA, who alerted us to this legislative issue and who led the effort to send a letter to Capitol Hill on this issue.

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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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