FAA Changes the Criteria for Maintaining Night Vision Goggles

Night Vision Goggles were once thought of as exclusively military technology, but now they are used in daily civilian use. This migration has caused the FAA to spend more time thinking about repair of Night Vision Goggles used by civilian aviators.

When Night Vision Goggle technology first became available for civil-use, aeronautical repair stations used military maintenance specifications or they used developed their own repair methods  in order to service the goggles.  The FAA issued limited specialized service ratings to these repair stations to reflect the appropriate rating for the work.

In 2004, the FAA published a Technical Standard Order for Night Vision Goggles – TSO-C164. In the wake of this TSO, repair station maintenance of Night Vision Goggles has increased.

The FAA feels that maintaining Night Vision Goggles is no longer novel, unique, or unusual.  They have concluded that it is no longer appropriate to issue a limited specialized services rating for Night Vision Goggle maintenance, and have published Notice 8900.202 concerning Night Vision Goggle maintenance.

The FAA now feels that Night Vision Goggles should be maintained under a Class 3 Accessory or Limited Accessory rating.  This decision does not invalidate existing limited specialized services ratings, but it does mean that new repair stations wishing to do this work should apply for a Class 3 Accessory or Limited Accessory rating, and it also means that existing repair stations should be able to drop the limited specialized services rating in favor of a Class 3 Accessory or Limited Accessory rating (as appropriate) if that is their desire.

Repair stations maintaining Night Vision Goggles should investigate to make sure that they have the right rating for the work that they are performing.  Distributors seeking maintenance of Night Vision Goggles should make sure that the repair stations that they use are properly rated.

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About Jason Dickstein
Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.

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