DAR-56 Advice: Apply Under Your Current AC 00-56 Revision Number (even if you are still under “00-56A”)

We have received word that many ASA members are expeditiously pursuing DAR-56 credentials.  This is the temporary program that delegates limited 8130-3 privileges to individuals working in AC 00-56 environments.  It is great to hear that so many individuals in AC 00-56 companies are pursuing these credentials.

In a recent call with the ASA members, they pointed out that a significant portion of the AC 00-56 community is still accredited under AC 00-56A (not “B”).  The cancellation clause of AC 00-56B explains that a distributor can maintain its accreditation under the “A” revision until it runs out and is renewed under the normal renewal schedules:

“Distributors already in the database of accredited distributors under AC 00-56A may maintain their accreditation under the AC 00-56A standard until their accreditation expires, is superseded upon renewal, or is cancelled or removed by the distributor’s accreditation organization.”

So some accredited distributors could retain the “A” accreditation as late as August 2018 (90 days after the publication of the “B” revision + three years, when their accreditation expires).  The community continues to roll from “A” into “B” between now and 2018.

The cancellation clause of the “B” revision incorporates-by-reference and grandfathers the then-existing “A” revision accreditees.  Therefore, it seems logical that we should read the language of the DAR-56 memo to include the remaining accredited distributors who are still under the “A” revision.  There was nothing added by the “B” revision that would be necessary to the structure of the DAR function code 56 program – the “A” revision provided the structure necessary to manage the DAR FC 56 functions.

The problem, of course, is that the sample letter requires confirmation that “The organization listed in the letter is an Accredited Distributor in accordance with FAA Advisory Circular 00-56B.” This appears, on its face, to possibly exclude those companies that are still accredited under the “A” revision.

We asked the FAA how they want applicants who are still under the “A” revision to handle this?  They responded by explaining that it is acceptable for applicants to state “The organization listed in the letter is an Accredited Distributor in accordance with FAA Advisory Circular 00-56A.”  The response came from Scott Geddie, who leads the branch that is processing DAR-56 applications (so he can speak authoritatively on how the FAA will process DAR-56 applications).  Here is the text of the FAA’s response:

Jason

It was certainly not our intent to restrict those that are currently accredited under the “A” revision given the revision “B” guidance that says:  “Distributors already in the database of accredited distributors under AC 00-56A may maintain their accreditation under the AC 00-56A standard until their accreditation expires, is superseded upon renewal, or is cancelled or removed by the distributor’s accreditation organization.”

I believe the best course of action is for the Limited DAR-F applications and their corresponding letters of endorsement to reference the applicable revision of AC 00-56 that they are currently under.  My office will process emailed applications that include the reference to the “A” revision of the AC.

Thanks,
Scott Geddie
Manager, AIR-160, Delegation and Organizational Procedures Branch
Ph: (405)954-6897

Do you have questions about the DAR-56 program? Let us know your questions – we will work with the FAA to try and get answers that can benefit the entire distribution community.

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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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