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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.
Jason Dickstein has written 579 posts for MARPA

Safety Management Systems Update (for Manufacturers)

Safety Management Systems (SMS) is being adopted as a standard practice across the manufacturing industry. We will be discussing SMS at the Annual Conference in November. This is a review of the status of SMS regulations for manufacturers in some jurisdictions. United States The FAA is expected to take their existing SMS rule (which applies … Continue reading

MARPA Files Comments to Protect PMA Manufacturers

Last month, MARPA filed comments regarding the FAA’s Airplane Fuel Efficiency Certification Notice of Proposed Rule Making (“NPRM”). The NPRM seeks to implement a 2009 ICAO program that is designed to reduce CO2 emissions from aircraft and engines. The EPA has already implemented aircraft emissions regulations and the FAA rule would similarly establish emissions standards. … Continue reading

Exporting PMA Parts: Make Sure You Perform the Full Analysis

Many PMA parts manufacturers sell their parts to non-US MROs and airlines. When these parts are exported from the United States, they need to be exported in compliance with U.S. export laws. U.S. export laws include a special analysis that must be completed when the export is intended to support a foreign aircraft. When you … Continue reading

MARPA Board Member Krotec Joins U.S. Trade Advisory Committee

MARPA Board member Josh Krotec has been appointed to the Commerce Department’s Industry Trade Advisory Committee (ITAC) on Aerospace Equipment. He is expected to represent the U.S. parts manufacturing and repair station industries on the committee. Krotec was appointed by Secretary of Commerce Gina Raimondo and United States TradeRepresentative (USTR) Katherine Tai. His term will … Continue reading

“Rebuilding” is a Manufacturing Activity for GARA Purposes, and it Does Not Reset the GARA Statute of Repose

A court recently held that a manufacturer who rebuilds a general aviation aircraft part becomes immune from accident-related civil suits 18 years after the original delivery date of the aircraft or the installation date of the part (if the part was not original equipment). This is important because the statute of repose does not get … Continue reading

Fuel Efficiency Metric NPRM – New Rule Could Affect PMAs and STCs

The FAA is proposing a new set of standards applicable to aircraft. While the proposed rule suggests that only the large airframe manufacturers would be affected, the plain language of the rule appears to impose obligations on a wide variety of manufacturers and repair stations. Companies developing PMAs and/or STCs should be concerned about the … Continue reading

Do I Need a UKCA (or a CE) Marking on My Aircraft Parts?

We’ve been getting emails about the UKCA marking. The short answer to most of the questions is that aircraft parts typically do not need a UKCA marking in order to be accepted in the United Kingdom. The UKCA mark will replace the CE mark that is used in the European Union. Currently, the UK accepts … Continue reading

No, Jarkesy Did Not Get Rid of DOT ALJs

We have received several inquiries from MARPA members asking about the effect of last week’s opinion out of the U.S. Court of Appeals for the Fifth Circuit, Jarkesy v. SEC, and what that opinion might mean for Department of Transportation Administrative Law Judges (ALJs) that companies and persons regulated by the FAA interact with from … Continue reading

MARPA COS Rev. 4 Now Available

In late December we posted a request for comments on the MARPA COS Committee’s draft revision to the MARPA COS guidance material. Last updated in 2014, the Continued Operational Safety guidance was due for a review and an update to ensure the guidance reflects current industry best practices. We are now happy to announce that … Continue reading

Summary of U.S. Sanctions on Russia and Belarus (as they apply to Aircraft Parts)

There has been a lot of activity in U.S. export sanctions against Russia and Belarus. Some of those new standards apply to aircraft parts. If you are an FAA-PMA manufacturer or exporter, then here is a summary of the key things you need to know about these new sanctions. Continue reading