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Aircraft Parts, EASA, FAA, Policy, Uncategorized

MARPA Participates at CMT Meeting of Authorities

Last week MARPA participated at the annual quadrilateral Certification Management Team meeting industry day.  The CMT brings together the certification heads of the FAA, EASA, Transport Canada, and ANAC Brazil and gives the regulators time to work face-to-face on bilateral and multilateral agreements between their respective jurisdictions. Industry day provides an opportunity for representatives of industry to get briefed by the regulators on forthcoming policy initiatives and to offer industry’s insights and requests directly to the regulators.

MARPA regularly attends these meetings to make sure the PMA industry’s interests are represented. Of great importance is to ensure that FAA-PMA parts continue to be accepted without further showing under the implementing procedures of the bilaterals with our various partners. Of specific note, MARPA is working with our partners in pursuit of the goal of removing language specific to so-called “critical” PMAs from the various implementation procedures of the bilaterals. It is our goal that all FAA-PMA parts are accepted under our bilateral agreements without further showing, regardless of where in the product they are installed. Such acceptance would justifiably reflect confidence in the FAA’s oversight of the PMA industry, as well as the PMA industry’s proven track record of safety and compliance.  We hope to see progress on this front in the FAA-EASA TIP revision 7, although the timing for release of that revision is undetermined as the authorities focus on ensuring the benefits of revision 6 are realized, and they have developed a clear idea of what issues need to be addressed.

MARPA also had the opportunity speak about the importance of industry participation throughout the rule-making and policy making process. We were happy to hear that the authorities largely agreed that engagement and transparency throughout the process is important, but they also acknowledged that there may be certain structural or internal impediments that may prevent consultation with industry at every step (or as much as we might like).

For its part, industry came away with two working items to assist regulators in this process: to determine a process by which industry industry can provide input and comment on IPA and other materials to assist in development and evaluate for unintended consequences; and to pursue clarifications from the authorities as to what policies or rules restrain communications with industry.

These are important steps to ensure that forthcoming policies and regulations do adversely affect the PMA industry, or the industry as a whole. It is gratifying to know the authorities share this concern, but there is work to be done to get everyone on the same page.

MARPA will continue to participate in meetings with the authorities like the CMT meeting, the FAA Engine Aftermarket Meeting, the FAA-EASA Safety Conference, and other meetings and working groups established by the authorities.

If you would like to know more about MARPA’s government affairs initiatives, or if you want to participate, we encourage you to attend the MARPA Annual Conference in San Diego, November 5-6 to learn more, or reach out to VP of Government and Industry Affairs Ryan Aggergaard to get involved.

 

 

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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