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Aircraft Parts, aviation, FAA, Manufacturing, PMA, Policy

Minor Changes to FAA PMA Policy

This morning, the FAA circulated Change 2 to the FAA Order 8110.42D.

FAA Order 8110.42 is the internal FAA order that tells FAA employees how to process PMA applications. It has been very important for PMA applicants to read it in order to now how to assemble a PMA application so that it is acceptable to the FAA. The “D” in 8110.42D tells us that it is the fourth major revision to the order (after “A,” “B,” and “C”). The “change 2” tells us that it is the second minor revision to the fourth major revision.

The minor changes to the document are mostly updates to office names that reflect the changes related to the aircraft certification services’ reorganization; for example the previous references to a MIDO (such as a MIDO being responsible for issuing production approvals) have been updated to call each such office a “certificate management branch.” In addition to name changes, the “change 2” revision also replaces the references to the Regulatory and Guidance Library (RGL) with references to the Dynamic Regulatory System (DRS) that replaced it.

This was considered a minor change that did not need to be open to public comment. We are still expecting a more substantive change to this guidance in 2024 that will be open to public comment. When it is made available for comment, MARPA and its Technical Committee will be carefully scrutinizing the proposed changes. If you want to be part of this process, then please make sure that you contact Katt Brigham and have her add your name to the MARPA Technical Committee contact list.

The new guidance document was circulated this morning. It was electronically signed on November 1, but it is effective as of October 27, 2023.

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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