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 … Continue reading
Back in December, the FAA published the System Safety Assessments NPRM. Along with that publication was issued a raft of draft advisory circulars related to specific provisions of Part 25 (Airworthiness Standards for Transport Category Airplanes). Those draft ACs are: Comments on each of these draft ACs is due April 24, 2023. The MARPA Technical … Continue reading
The deadline for Safety Management Systems (SMS) comments is coming soon. One key question asked in the FAA proposal is whether the SMS rules should be applied to PMA holders. Continue reading
The FAA and other aviation authorities have released a Changed Product Rule (CPR) Report. It outlines proposed agreements among authorities about how to make changes to the CPR. They are accepting comment on it through March 17, 2023. The CPR affects STCs, and as we have seen STC policy can be important to the extent … Continue reading
The FAA will publish its Safety Management Systems (“SMS”) Notice of Proposed Rulemaking (“NPRM”) in tomorrow’s Federal Register. This long-awaited proposed rule has been scaled back from the original scope (manufactures and maintenance organizations) and only appears to apply to: There will be an exception for production certificates that are based purely on a supplemental … Continue reading
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
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
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
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
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
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