DAR 56? Apply to Extend Your Credentials by September 30!

Do you have function code 56 privileges?  If you do, then you need to renew your credentials ASAP – the deadline for renewal is September 30.  Instructions and other guidance for renewal can be found in our earlier post about submitting your request for renewal.

Background on FC 56

FAA created a program (AIR-100-16-160-PM13) that allowed qualified distributor employees to issue 8130-3 tags as DARs exercising function code (FC) 56.

Many of the eligible new parts had been accepted under their previously acceptable documentation schemes, which were both known and recognized within the industry. ASA argued that under FAA policies (like FAA AC 20-62E), these documents were sufficient to identify a new part and to permit installation, so issuing an 8130-3 tag based on that evidence should be a mere ministerial task. The FAA agreed and created a Limited DAR program (“DAR 56”) in which individuals could obtain the DAR privilege of issuing 8130-3 for parts when the following conditions were met (this is only a partial list):

  1. Individual must work for an accredited distributor, and can only tag parts that were received by the distributor’s accredited system before a certain date (currently November 1, 2016)
  2. Individual must complete FAA training
  3. Part must either bear (1) part markings regulated under 14 C.F.R. § 45.14 [PMA, TSOA and critical parts], (2) a certificate from the manufacturer, confirming that the part was produced under a FAA production approval, or (3) a certificate from the manufacturer’s direct-ship authorized supplier, confirming that the part was produced under a FAA production approval.

The program was scheduled to end on September 30, 2017 but was extended by an additional policy memo (AIR-600-17-6F0-PM01) until 2018.

Discussion with the FAA About the Future of DAR 56

The FAA is considering converting all FC 56 DARs into FC 19 DARs (they will need to apply through normal channels, but the FAA would treat their distribution experience as relevant experience for obtaining Function Code 19 privileges).

If this program goes through, then many of the FC 56 limitations would ‘go away’ and the DARs would be able to use function code 19 to tags other sorts of new parts that have clear indicia of having been produced by US Production Approval Holders.  This could make it easier to handle expendables that have been difficult to get tagged because of their volume and low-cost (relative to the normal cost of obtaining an 8130-3).  It is likely that the converted DARs woud lneed to rely on their AC 00-56 systems as a condition of the exercise of their functions.

This is not yet subject to final approval by FAA management, so it could change!

Advice

If you currently hold Limited DAR credentials under the “DAR 56” program, then

  1. You need to apply to extend your credentials by September 30 – that deadline is coming up fast!! You can find more details here;
  2. Be sure to use your credentials to issue 8130-3 – activity is an important metric when seeking to renew or upgrade your credentials;
  3. We are working with the FAA to permit transfer of your credentials to a permanent DAR with function code 19 (able to issue 8130-3 tags for a wider class of demonstrably airworthy, new parts). We hope to have more news on this, soon!
Advertisements

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.

Leave a Reply

Please log in using one of these methods to post your comment:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out / Change )

Twitter picture

You are commenting using your Twitter account. Log Out / Change )

Facebook photo

You are commenting using your Facebook account. Log Out / Change )

Google+ photo

You are commenting using your Google+ account. Log Out / Change )

Connecting to %s

%d bloggers like this: