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Aircraft Parts, aviation, Continued Operational Safety, FAA, Policy

FAA Extends Training, Oversight and Renewal Deadlines for Designees

The FAA has published guidance for Aircraft Certification Service designees (like DAR-F, DMIR, and DER) who experience certain deadlines between December 22, 2018 and April 29, 2019.  Under the new guidance, these otherwise-authorized designees will gain the benefit of an extension to those deadlines. The affected deadlines that fall during this period are extended to April 30, 2019.

We had asked the FAA, during the last government shutdown, we asked the FAA to issue guidance extending the termination dates of all designees who expired during the shutdown, in order to allow them to continue providing critical safety-related services to the aviation industry. This was due to the fact that as they were expiring, there was no FAA staffing to renew their designations during the shutdown.

The FAA was unable to do this (it was outside the scope of the Antideficiency Act and the DOT guidance). But they did the next best thing. When FAA safety personnel returned to work before the end of the shutdown, they made designee oversight a priority. And then, on the first work day that the government was opened after the shutdown, the FAA published AIR-600-19-DM01, which explained that designees in good standing may continue to perform authorized functions in an active status without regard to the status shown on the various designee databases (DIN, DMS or VIS). More importantly, the guidance specifically allowed designees to extend due dates, within the date range, for (1) designee recurrent training, (2) oversight, and (3) renewal. Those training, oversight and renewal dates are extended to April 30, 2019.

The memo also applies to ODA unit members. The may continue to perform authorized functions during this period.

In the event the FAA experiences another lapse in funding, the memo wil continue to apply to that shutdown. Such a subsequent shutdown has already been threatened and could arise after February 15, 2019. If a subsequent shutdown lasts beyond April 30, 2019 then the FAA would have to find another solution (but no government shutdown has ever lasted than long).


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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