On December 8, 2023, the FAA published a Notice of Proposed Rulemaking (NPRM) titled “System Safety Assessments” (87 FR 75424). In the NPRM, the FAA proposed to amend certain airworthiness regulations to standardize the criteria for conducting safety assessments for systems installed on transport category airplanes. This would result in additional new analysis requirements under Part 25. It would also create a new category under the airworthiness limitations of an aircraft:
“Each certification maintenance requirement established to comply with any of the applicable provisions of part 25.”
Proposed Addition to H25.4 (Airworthiness Limitations Section)
MARPA is assembling comments on this rule and needs your feedback. The (extended) comment period closes on April 24 (88 FR 13071) so we would love to hear from our members ASAP.
This new rule would impose some new systems safety analyses intro the Part 25 airworthiness standards. This could impose new analysis obligations on PMA applicants.
It would be especially useful to hear from MARPA members about (1) how these new rules would affect your PMA applications and (2) the estimated costs of the proposed additional analyses.
If you identify any unintended consequences of the proposed rules, then please let us know these unintended consequences, as well.
The impact on PMAs appears to have been ignored in the proposal. If the rules are not intended to apply to PMA applicants, then this should be explicitly stated. Our comments will seek to clarify the impact on PMAs and seek either an amended cost-benefit analysis or an explicit limitation on when these analyses must be performed.