Limited DARs (DAR-56): Apply for Function Code 19 NOW! The Deadline to Apply is January 2, 2018!

We have written previously in this space about the importance of current Limited DARs (L-DAR-F), also known as DAR-56s, to apply to transition to permanent function code 19 status. If you or a person in your company currently holds DAR-56 privileges and an application for function code 19 has not yet been submitted, that must be done as soon as possible! The deadline to apply for this transition is January 2, 2018.

On October 4, 2017, the FAA issued Memo Number AIR-600-17-6F0-DM08.  The memo outlines the process by which holders of the existing DAR-56 privilege can be issued Function code 19 privileges as the Limited DAR program comes to an end. That limited DAR program is scheduled to end on September 30, 2018. This specific Function Code 19 delegation will be limited to the issuance of domestic airworthiness approvals at the holder’s distributor location. The key benefit of the function code 19 privilege is that it is not subject to the DAR-56 program’s limitation to new parts and articles that were in inventory prior to November 1, 2016.

As we’ve previously written in the blog, the application process is as follows:

For Current DAR-56 Holders

If you currently hold DAR 56 privileges, then you should apply to your local (“geographic”) Manufacturing Inspection District Office (MIDO) for appointment as a DAR-F with function code 19.  You can find your geographic MIDO on the FAA’s website.  Using the “select the state” function at the bottom of the page (but above the blue footer), enter your state where you operate and find which MIDO is your geographic MIDO.

Then, apply to your geographic MIDO using the on-line Designee Management System tool.

In order to be appointed as a DAR-F under this program an applicant must meet the minimum qualifications provided in FAA Order 8000.95. Look within 8000.95 for the criteria – specifically in Volume 1, Chapter 2 and in Volume 8, Chapter 2.

There is one significant difference from the standards found in FAA Order 8000.95 and the transitioning DAR 56s.  That is the experience provision.  Under the FAA memo, the applicant who has applied for a timely transition from DAR 56 privileges does not need to meet the normal 36 month experience  requirement.  Instead, the applicant must

“[h]ave a minimum of 12-months actual working experience for the accredited distributor under the quality system at the accredited distributor location(s), specifically:

a. Experience in either receiving inspection and/or quality assurance processes; and,

b. Experience reviewing documentation and/or part markings which can be used to verify that parts and articles are traceable to the PAH.”

Application checklist:

  • Identify your geographic MIDO;
  • Complete the required FAA training (you will need to submit the training certificate as part of your application package);
  • Obtain a letter of reference from the accredited distributor (signed by someone who can represent the business); a sample can be found in attachment 1 to the memo;
  • Ensure that your application details match those already filed for you under the DAR-56 program;
  • Apply through the DMS system, and include:
    1. Evidence of completion of the required FAA training;
    2. The letter of reference from the accredited distributor;
  • Notify FAA Headquarters that you currently hold function code 56 privileges and that you have filed an online application seeking function code 19 privileges.  Perform this notification by ending an email to the AIR-6F0 mailbox at AIR160-limiteddarf@faa.gov.  AIR-6F0 will notify the appropriate MIDO of the application, and let them know that it is subject to the provisions of the policy memo.

Once this process is complete, if the FAA reviews your package and finds that you can be transitioned to function code 19, then they will cancel your DAR 56 privileges and assign function code 19 privileges for issuing 8130-3 tags.  Don’t just rely on this checklist – be sure to study the policy memo!

Once you get the new function code privileges, you should expect that you will be limited to only exercising the privilege at the accredited facilities of the AC 00-56 accredited distributor.  This is not a “portable” credential, because it relies on the distributor’s AC 00-56B system as part of the basis for knowing that the part is in an appropriate condition to receive an 8130-3 tag.

For Those Without DAR-56 Privileges:

We advised all of our members to obtain DAR-56 privileges.  But we recognize that some members did not–or were not able to–follow this advice.  We also recognize that some function code 56 holders may allow the 90 day period to come and go without filing their application to transition.

If you do not hold DAR-56 privileges, or if you waited too long, then there is still a path!

The new guidance permits other persons to apply for function code 19 privileges under the terms of the memo; however such applicants are not entitled to the same presumptions enjoyed by transitioning DAR-56 holders.  If you fall into this category, then you will only be considered if the MIDO can independently establish that the FAA has a need and ability to manage the delegation; this means that you are going to need to convince the MIDO!  You also need to meet conditions that are comparable to those imposed on DAR 56 applicants.  You will still benefit from the alternative experience requirement (12 months experience with the quality system of the accredited distributor).

The Limited DAR program has been a useful tool to work through some of the challenges created by MAG 6. ASA has worked closely with the FAA to develop solutions to help distributors and their repair station customers continue to receive parts that did not enter inventory with an 8130-3 tag. This has included working with the FAA to develop the program initially, and having it extended until September 30, 2018. But the program was never intended to be a permanent solution. It is therefore absolutely critical to apply to transition your DAR-56 privileges to Function Code 19 privileges AS SOON AS POSSIBLE.  Remember, the deadline to apply is January 2, 2018!

Advertisements

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 )

Google+ photo

You are commenting using your Google+ 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 )

Connecting to %s

%d bloggers like this: