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Aircraft Parts, aviation, Continued Operational Safety, FAA, FAA Design Approval, Legal, Manufacturing, PMA, Policy, Regulatory, Safety Management Systems

MARPA Works on the Future of FAA Certification

The SMS/Part 21 Aviation Rulemaking Committee (ARC) opened a three day meeting this morning in Rosslyn, Virginia.  The meeting expands the scope of the ARC to include four working groups that will develop the new rules for certification and approval of aviation products and articles.  MARPA staff attended the live meeting and MARPA members participated by dial-in teleconference.  This project will definitely affect every MARPA member and could be the most important rulemaking activity affecting the PMA community in over 60 years!

Dorenda Baker is the Director of the FAA Aircraft Certification Service.  Ultimately, the ARC reports to her.  Baker explained that the FAA is committed to taking the ARC’s recommendations and moving forward with those recommendations to craft a rule that meets our ICAO SARP obligations (SMS or Safety Management Systems).  She stressed that we need to take into consideration how this rule will apply to both large and small companies.  It needs to achieve safety goals for everyone.

Some of the points that Baker raised included these:

  • The FAA is committed to this project and has assigned significant staff resources to support the effort.  The FAA recognizes that this is more than a matter of complying with ICAO requirements: it represents the future of aircraft certification.
  • With sequestration and impending sequestration –related furloughs, it is even more important to streamline certification, and to have clear safety accountability for manufacturers.
  • In the area of the 787, the NTSB will be holding hearings and it is clear from the media coverage of the 787 concerns that the general public does not understand what FAA and industry do to ensure safety.  This tells us that outreach will be very important in order to educate people about how the new system (that the ARC recommends) will effectively support safety.
  • FAA is working on its five-year plan, and one of their initiatives is the single surveillance system (working with our partners to ensure global safety).  This project should support that effort by harmonizing to the ICAO SMS obligations.

MARPA has been centrally involved in drafting the working group charters in order to ensure that the ARC recommendations will support the next generation of safety management.  Baker’s commitment to protecting the interest of both small companies and large companies is encouraging; but the details will be important to the PMA community and there is plenty of opportunity to see a rule that does not work well.  With this in mind, this could be one of the most important projects that MARPA has ever worked-on for the future of the PMA community.  MARPA will remain at the heart of this process in order to ensure that the interests of the PMA community are protected.

About Jason Dickstein

Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. Since 1992, he has represented aviation trade associations and businesses that include aircraft and aircraft parts manufacturers, distributors, and repair stations, as well as both commercial and private operators. Blog content published by Mr. Dickstein is not legal advice; and may not reflect all possible fact patterns. Readers should exercise care when applying information from blog articles to their own fact patterns.

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  1. Pingback: Help Shape the Future of Part 21! | MARPA - April 26, 2013

  2. Pingback: MARPA Offers Comments on FAA Sequencing Program | MARPA - July 18, 2013

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