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FAA, Policy, Regulatory

FAA Examines the Changed Product Rule

Yesterday, the FAA announced the availability of a Report from the from the Changed Product Rule International Working Group (CPR IAWG). The report provides recommendations related to changes to the way that the Changed Product Rule would be used and managed in FAA certification and approval processes. These changes are likely to affect MARPA members who use Supplemental Type Certificates (STC) to approve major changes.

The CPR IAWG Report recommendations include a suggestion that:

“A comprehensive integrated system-level analysis recognizing that in this complex interactive system, every change could interact with other parts of the system The assessment of the proposed design changes on existing systems at the aircraft level includes using development assurance principles, system safety principles, and validation & verification techniques. The level of assessment should be proportional to the impact of the change at the aircraft level”

Changed Product Rule Recommendations, Aircraft Certification, Safety, and Accountability Act (ACSAA), Section 117, Changed Product Rule, Page 6 (2022 International Authorities Working Group). Found online at https://www.faa.gov/sites/faa.gov/files/IAWG_CPR_recommendations.pdf

While there are many ways to implement this recommendatoin, an in-artful implementation could needlessly inhibit certain PMAs, without adding any related safety value to the PMA process.

The CPR IAWG has recommended engagement with the public in order to further develop the CPR concepts. The FAA plans to solicit public input at a public meeting which will be announced in the future.

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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