The FAA’s State of Transition
The FAA is in a state of transition in a number of aspects. The aviation safety discipline is becoming more and more global daily. The interconnection of the various aviation regimes necessitates more and more coordination. The FAA’s internal regulatory systems are being stretched by new initiatives—SMS, SIAS, and the new compliance policy.
Below are two updates on each transition point:
1. EASA-FAA Maintenance Guide, Annex 6
FAA has extended a key provision that allows U.S. repair stations with European Aviation Safety Agency (EASA) certification to inspect and approve parts that don’t have recently required EASA documentation.
The authority, detailed in FAA Notice 8900.429 is targeting its repair-station inspectors and is intended to bridge a gap created by Maintenance Annex Guidance (MAG) Change 6, the latest update to the U.S.-E.U Bilateral Aviation Safety Agreement (BASA).
Change 6, which when into effect in June 2016, mandated that all new parts entering a repair station have an airworthiness approval tag—an 8130-3 under FAA regulations. While EASA’s rules for production-approval holders (PAHs) require issuance of a tag, FAA’s PAH rules assume a part made under them is airworthy. Many U.S. parts-makers don’t take the extra step of issuing tags, as the requirement only affects parts going into the 1,400 U.S. based repair shops with dual FAA/EASA approvals.
The requirement is expected to be addressed–and either heavily modified or eliminated altogether—in MAG Change 7, but that update’s release has been delayed. The FAA work-around issued last year and set to expire this month was supposed to be superseded by an updated MAG. The new provision extends repair station inspection and tagging authority through August 8, 2018.
The Aviation Suppliers Association and the Aeronautical Repair Station Association (ARSA) led a multi-organization effort to ensure the inspection authority was issued last year and then extended in light of the MAG 7 delays. Issuing the tags provides a “critical alternative path to compliance” until the situation can be addressed in the MAG, ARSA noted.
While the new authority helps repair stations navigate the regulatory challenge, U.S. parts distributors remain without a solution. Many of them have parts in their inventory that don’t have 8130-3s, and a temporary FAA fix—a program granting distributors a slimmed-down designee authority to tag some parts—is set to run out next month. FAA has no plans to extend the program. The Aviation Suppliers Association is leading a coalition urging FAA to find a solution.
2. FAA Flight Standards Service—disbanded its regional organization
The FAA officially disbanded the regionally structured Flight Standards Service (FSS) on Monday Aug 21. As of Aug. 21, the FSS will be based around four functional areas—
- Air Carrier Safety Assurance,
- General Aviation Safety Assurance,
- Safety Standard, and
- Foundational Business.
According to the Information for Operators briefing the FAA released on the reorganization earlier this month, the initiative “is a service-wide effort to transform the culture of Flight Standards into an organization that facilitates critical thinking, interdependence and consistency to better serve aviation safety.”
The FAA promises “the reorganized Flight Standards will be a streamlined structure that will allow for faster response times, single points of accountability in each functional organization, greater agility and consistency.” Under the old regional system, FAA regulations were sometimes interpreted somewhat differently from district to district. Members of the public trying to find their new point of contact should reference the Flight Standard Information Management System (FSIMS), which now hosts the FSS Organizational Chart, FAQs and an FSS Responsibilities Quick Reference Sheet. Although the regional Flight Standards offices will no longer be providing regulatory guidance, local FAA offices will remain in place to perform non-policy-making functions previously handled by the FSDO.
The FAA wants to stress that the realignment should be transparent to Certificate Holders and cotinue to interact with the FAA employees who currently manage your certificate. These employees should be able to resolve any issues that may arise. If, however, you have not been able to resolve an issue through this channel, the FAA established a Rapid Response Team to help. Should you need RRT support, the contact information is:
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