The FAA has published for manufacturers of aircraft and aviation products new regulations that will update and standardize FAA requirements. The agency says the change “will better align [regulations] with the current global manufacturing environment.”
“We want to make sure that all aircraft and parts designed for them meet the highest standards no matter where they are manufactured or who makes them,” said FAA Administrator Randy Babbitt. “These changes to our certification rules will help us do that.”
Babbitt said that the aircraft manufacturing industry has evolved significantly since many of the regulations were issued in 1964, prompting the agency to update manufacturing regulations.
“Back then a typical business model involved many aircraft manufacturers with relatively few suppliers. Today, there are fewer manufacturers but the number of suppliers has increased. Many of those suppliers are located outside the United States and build much larger portions of the aircraft than in earlier years,” he said.
The major changes reflected in the updated regs include standardization of quality control system requirements for all aviation manufacturers; updated export requirements to facilitate global acceptance and documentation of parts; standardization of part marking and identification requirements so they align with other countries’ rules; and consolidation of the requirements into one regulation.
The member companies of the Aviation Suppliers Association (ASA) give the FAA mixed reviews. Jason Dickstein, ASA’s general counsel, told AIN the aircraft manufacturing industry has evolved significantly over the past several decades. “The industry is constantly adopting new technologies that improve safety by increasing manufacturing efficiency and quality. The new regulations recognize this by permitting a wide variety of solutions to their performance standards.”
Dickstein said the number of FAA-approved manufacturers has vastly increased in recent decades with significant numbers of PMA and TSO manufacturers that didn’t exist 30 years ago. “This has increased the work load on the aircraft certification service. In order to help alleviate the workload, the FAA is requiring more accountability from FAA-approved manufacturers.
“This should not be a problem for most companies because organizations such as MARPA (Modification and Replacement Parts Association) have established continued operational safety (COS) paradigms that provide a framework for exceeding the regulatory standards.”
The new regulation requires that all PMA manufacturers, regardless of size, need to establish quality systems that meet the same quality-assurance standards as the largest production certificate holders such as Boeing, GE and Pratt & Whitney. “Where COS principles have been adopted this shouldn’t be a problem for PMA companies, but the greatest challenges come from those rules affecting non-manufacturers,” Dickstein said.
“The new standards that forbid the continued production of commercial parts, such as light bulbs that are made for a wide variety of industries, could ground aircraft if they are enforced as written. These parts have historically been regulated at the installation phase rather than the production phase because they are made for a wide variety of industries and were not intended only for aircraft.”
The FAA maintains that there is a “safety valve” in the new commercial parts regulations in the form of the ability for design approval holders to create FAA-approved commercial parts lists, but Dickstein sees a problem.
“It doesn’t help the pilot who’s flying an out-of-production aircraft and it assumes that companies with current-production aircraft will create commercial parts lists gratuitously, instead of taking commercial advantage of the instant monopolies that this rule gives them,” he said. “I hope that design approval holders will support safety and the good of the industry by producing these commercial parts lists, but I suspect that the very short implementation time of the rule will be insufficient to permit publication of complete commercial parts lists.”
Dickstein cautions non-aviation companies that might not be aware of the new FAA standards. “Under the new regulations a company could find itself caught unaware in an enforcement action. Equally bad for the industry is a company that is aware of the new regulations and because of them might take positive steps to prevent its parts from being sold into the aviation market. This will particularly be a problem for older model aircraft. It has the potential to lead to aircraft being grounded because of unavailability of parts that have the least potential safety affect; something as non-flight safety critical as reading lights or the curtain rings that separate coach from first class.”