FAA Transitioning Limited DARs to Full-Function DARs

Today, the FAA issued a memo that permits the limited designated airworthiness representatives (DARs) [commonly known as DAR-56s] to transition to normal DARs with function code 19 privileges.  This is a major achievement for ASA’s members!

The Guidance

The new FAA guidance is known as Memo Number AIR-600-17-6F0-DM08.  This memo permits current DAR-56 privilege holders to apply for function code 19 privileges.

The reason for this change is to resolve certain limitation that the FAA now believes are unnecessary.  The first unnecessary limitation involves the date of  receipt of the parts.  DAR-56 privilege holders can only issue 8130-3 where the parts were received by November 1, 2016.  This date was arbitrary, and did not to address the fact that production approval parts are still entering the system from manufactures who do not issue 8130-3 tags.  Transitioning to function code 19 will eliminate this date restriction.

The second issue this resolves is that the DAR-56 program only permits tagging of a very limited slice of parts.  A much broader swath of parts are eligible for 8130-3 tags under current FAA policy.  Function code 19 permits tagging of parts with adequate evidence that they were created by a production approval holder, and have suffered neither damage nor degradation since release from the production approval holder’s quality system.  While this category is subject to FAA guidance, it is still broader than the very narrow limits associated with DAR-56.

The deadline to apply for a smooth transition is 90 days from the date of the memo (Tuesday, 2 January, 2018).

The Process (for 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.

The Process (for others)

We advised all of our members to obtain DAR-56 privileges.  But we recognize that some members did not 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).

What About Export Tags?

The FAA has been transitioning away from a distinction between “domestic tags” and “export tags.” They took a major step toward that goal when they issued the memo guidance that explained that 8130-3 tags were no longer allowed to say the word “export.”  For a full discussion of this change, please see our blog post on the subject.

This transition is consistent with international practice, which typically does not distinguish between an “export tag” and a “domestic tag.”

So the future of the 8130-3 tag is that all tags will look the same – whether they are intended for domestic use or non-US use – and there will be no visible difference in the tag for exports.  The exporter is expected to address the special import conditions of the importing nation.  This has been FAA policy for some time, with export compliance obligations falling on the exporter and not on the DAR.

For newly transitioned DARs who are permitted to issue domestic tags under function code 19, this means that the tags will be useful for exports as well as for domestic transactions.

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ASA Petitions FAA for Extension of DAR-56 Program

Last week ASA submitted a petition to the FAA formally requesting the indefinite extension of the Limited DAR-F Program for Accredited Distributors–commonly known as the DAR-56 program–that is scheduled to expire September 30, 2017.  ASA further requested an expansion of the program to better reflect the needs of the distribution community.  You may also recall that ASA recently led an industry effort that secured the reissuance of FAA Notice 8900.380 for another year. Both of these efforts are in response to the 8130-3 tag requirements arising out of MAG 6, which put billions of dollars of distributor inventory at risk.

ASA explained in its petition to extend DAR-56 indefinitely that the facts that gave rise to the need for the DAR-56 program have not changed and that the need for the program to continue was therefore very important to distributors.  The DAR-56 program permits Limited DAR-F’s to issue 8130-3 tags for parts on the basis of specific indicia of sourcing from the PAH.

As attendees of the ASA conference heard from members, distributors have so much inventory that needs to be tagged under the DAR-56 program that it could literally take years to tag every part.  This includes vast numbers of small, low-dollar-value parts for which hiring an independent designee would be economically infeasible.  ASA therefore proposed an indefinite extension of the program with semi-annual meetings between the FAA, ASA, and interested parties to discuss the ongoing need for the program so that it can be discontinued after a permanent solution is developed.

In addition to proposing an indefinite extension of the DAR-56 program (rather than annual extensions requiring yearly petitions and discussions), ASA also recommended changes that would improve the effectiveness of the program and help distributors.

At present, the DAR-56 program permits Limited DAR-F’s to issue 8130-3 tags under the following criteria:

  1. The aircraft part was received by the distributor prior to November 1, 2016 and
  2. The aircraft part must bear specific indicia of production under 14 C.F.R. Part 21:
    1. A certificate or statement of conformity that was issued by the production approval holder (any documentation part numbers and serial numbers, if applicable, must match any part markings); or,
    2. A certificate or statement of conformity that was issued by the production approval holder’s supplier, and a verification of direct shipment authorization; or,
    3. Markings regulated under 14 C.F.R. 45.15 and describing the PAH’s name or other identification (for parts, this would typically be limited to PMA, TSOA or critical parts).

ASA recommended that the program be extended as follows:

  1. The program be expanded to include any aircraft part that was received by the distributor at any time when the distributor was accredited under the AC 00-56 program.
  2. Expand the acceptable indicia of production under an FAA production approval to include other documentation the FAA has previously recognized:
    1. For an aircraft part that was accepted into an air carrier’s inventory system as new article, and then subsequently released from that air carrier’s inventory system, a document from the air carrier identifying the part by part number, and by serial number where appropriate, and identifying the part as new (including new surplus); or
    2. A maintenance release document showing (i) that the part was inspected under 14 C.F.R. Part 43 by a person authorized to approve such work for return to service, (ii) that the part was found to be in new condition, and (iii) a part number that matches a number known to be a PAH part number, and that matches the part number on the part, where applicable.

These proposed expansions reflect the fact that the November 1, 2016 receipt date appeared wholly arbitrary and neither supported nor required by any regulatory basis, and that the two additional forms of documentation are commonly accepted in the industry under Part 21 of the regulations.  This would solve the problem of those parts that are currently still being received without tags (as they continue to be released from PAH’s who do not issue tags, or as new surplus from air carriers without tags) and those parts that currently have PAH documentation but are nonetheless excluded under the terms of the current program.

ASA appreciates the FAA’s collaborative efforts to work with us to extend the DAR-56 program as we work toward a permanent solution to the MAG 6 8130-3 tag issue.  We will keep our members updated as we hear more from the FAA.

 

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.

Obtain 8130-3 Tags For Your Inventory – Limited Time Only!

Have you ever wished that there was an easy way to obtain 8130-3 tags for the obviously airworthy articles in your inventory?  Now, you can become a DAR and issue your own 8130-3 tags!  ASA has worked with the FAA to develop a limited program that will allow employees of accredited distributors to obtain DAR privileges to tag certain items in existing inventory.
The program creates a new function code 56 (because of the association with AC 00-56).  This is a limited function code for employees of accredited distributors that permits issue of 8130-3 tags for parts with certain types of clear evidence of production under FAA production approval.  The program can be found in this attached file.
This program is necessary because of the new emphasis on 8130-3 tags created by the FAA-EASA Maintenance Annex Guidance (MAG).  Many FAA inspectors have required repair stations in the US to adopt receiving requirements that only permit receipt of aircraft parts with 8130-3, EASA Form One or TCCA Form One.  Parts with traditional manufacturer’s certificates of conformity (for example) are excluded from the MAG guidance!  This temporary ability to obtain 8130-3 tags permits some existing inventories of good parts to be tagged in order to meet the new standards created by the Maintenance Annex Guidance

What Can be Tagged?

A DAR with Function Code 56 privileges will be able to issue an 8130-3 tags for parts manufactured by an FAA production approval holder (PAH) if the part and its documentation meets one of the criteria below:
1. Certificate of Conformity/Statement of Conformity from the PAH.  The part number and serial number, if applicable, must match any marking on the part.
2. Certificate of Conformity/Statement of Conformity or shipping document from a PAH supplier and verification of that supplier’s direct ship authorization.
3. Part markings made under 14 C.F.R. § 45.15 that include the PAH’s name or identifier (including PMA markings, TSOA markings and critical part markings).  If the PAH name or other identification is not included in the part marking, then you will need a Certificate of Conformity/Statement of Conformity as described in paragraphs (1) or (2) above.

Qualifications

An applicant for the DAR-56 program must meet all five of the minimum qualifications:
1. AGE: Be at least 23 years of age.
2. EMPLOYMENT: Be employed by an accredited distributor at the location(s) from which the 8130-3 will be issued.  The FAA has not clarified whether this needs to be full-time or part-time nor have they excluded contract employment.  In the absence of clarification, applicants should assume that all categories of employment are acceptable.
3. INDEPENDENCE: Be assigned to a position in the business with sufficient authority to allow the DAR to administer the delegated function effectively without undue pressure or influence from others.
4. EXPERIENCE: Have a minimum of 12 months actual working experience for the accredited distributor under the distributor’s quality system, specifically:
a. Experience in either receiving inspection and/or quality assurance processes; and,
b. Experience reviewing documentation which can be used to verify that the article is traceable to the PAH, such as a FAA Form 8130-3 and Certificate of
Conformity/Statement of Conformity from a PAH.
5. TRAINING: Must have successfully completed FAA course: Issuance of 8130-3 for Domestic and Export Approvals of Engines, Propellers, & Articles Only.

Application Process

Scan and submit the following three documents by email to 9-AIRI60-LimitedDARF@faa.gov:
1. FAA training certificate of completion from the required class [FAA course: Issuance of 8130-3 for Domestic and Export Approvals of Engines, Propellers, & Articles Only]
2. FAA Form 8110-14, Statement of Qualifications (should be signed by the individual employee).
3. A letter of endorsement signed by a management representative from the accredited distributor location where that individual employee is requesting to exercise the authorization.
  • Where the accredited distributor has more than one accredited location, the applicant may apply to exercise privileges at each accreditation location
    under a single management endorsement letter.  The Memo includes a sample letter and explains what must be in the letter.

The applicant is expected to retain the original application materials in his/her records.  FAA Headquarters will review the application.  When an applicant is selected, the FAA will email the applicant a Certificate of Authority.

Limits

There are many categories of airworthy parts without 8130-3 tags that will not be covered by this DAR-56 program.  This is not a solution to all of the problems caused by the implementation of the Maintenance Annex Guidance.  many ASA members will still need to rely on traditional DARs.
The DAR-56 program is limited in time.  All Limited DAR-56 appointments under this program will be terminated on September 30, 2017.  We have discussed with the FAA that there will be a continuing need for the program, because some FAA-PAH manufacturers continue to produce parts without 8130-3 tags.  ASA intends to petition for an extension of the program if it appears that the program remains necessary, but ASA members should not plan on the FAA granting that petition (they have already told us that they will reject such a petition).

Advice

The FAA intends that this DAR-56 program be used to tag existing inventory in order to make it saleable under the new documentation standards of the MAG.  The FAA has stated that they intend to issue privileges to all eligible applicants, in order to facilitate this process (note that this does not give you a legal right to the privileges – the FAA retains the discretion to limit or terminate the program at its discretion).
Many of our members have a substantial existing inventory that is eligible to be tagged under this program.  We have spoken with members who have said that some inventories could take YEARS in order to tag the entire inventory.  We advise accredited members to seek DAR-56 privileges for EACH eligible employee, in order to maximize your potential for issuing 8130-3 tags.  Accredited members should also apply as early as possible.
Once employees have received their certificate of authority, they should start to review existing inventory and issue tags for eligible parts immediately, in order to maximize the documentation of the inventory.
We also advise unaccredited ASA members to seek AC 00-56 accreditation in order to be eligible for the DAR-56 program.  ASA can discuss the process with you and can accommodate members who need AC 00-56 audits in order to participate in the program.

How is FAA’s New Compliance Philosophy Related to Safety?

Many of you know that the FAA published a new compliance philosophy last summer.  The new policy, found in FAA Order 8000.373, focused on cooperative efforts to achieve compliance, rather than blind enforcement.  

Peggy Gilligan is the FAA Associate Administrator for Regulation and Safety.  She is also a lawyer.  She was part of the force behind this new policy and she explained it at the FAA/EASA Internatinal Safety Conference this week.

The aviation industry has enjoyed an impressive safety record in recent years.   But the regulators are not content to rest on their laurels.  They want to continue working on safety to make aviation ever-safer.  Most of the salient risks have already been addressed so it is harder now to identify risks to address.  In order to identify the risks, the authorities are analyzing trends that could lead to risk.  This allows them to proactively address risk before it can pose a real threat.

The regulatory authorities have been talking about the importance  of data for many years.  They attribute the industry’s recent stellar safety record to safety data collection, and effective use of that data.  Gilligan explained:

“We debuted our new philosophy on compliance. … We want to shift focus so that we and industry are working together on compliance. … We want to look for the trends that lead to systemwide risk …”

She highlighted data sharing as a key element for identifying the next generation of safety risks.  The FAA reasoning is that a cooperative environment is the best environment for encouraging voluntary data sharing.

EASA Executive Dirctor Patrick Ky agreed.  He explained:

Accidents and incidents are frequently a result of many different causal factors, so sharing data is the key to future safety.  

The new compliance program is meant to create an environment in which industry safety data can be shared freely, without fear of repercussion.  As Gilligan said on Tuesday:

“We want everyone in the system to feel free to raise their hand and say that there is something wrong”

While the FAA has decreed that safety is a cooperative effort, this does not mean that enforcement is dead.  Gilligan said “If someone is unwilling or unable to comply with safety standards then that is the highest risk in the system” and such conduct will be met with strong sanctions. 

ASA members should be particularly aware of the new compliance philosophy and what it means for the industy.  Most regulated companies have an opportunity to build a strong relationship with the the FAA, which helps to facilitate cooperation and data sharing in an effort to achieve compliance.  Unregulated distributors, on the other hand, typically do not have the same sort of strong relationships with the FAA.  

Accredited distributors rightfully feel that they are committed to safety, but FAA employees who are not familiar with the the FAA’s AC 00-56 accreditation program may not recognize that commitment.  Thus, when accredited distributors find themselves in possession of shareable safety data, then they should make sure that they take the time to educate the local FAA office about the context of their AC 00-56 quality assurance system.  This may help show that the distributor is a committed part of the aviation system-based safety process.

ASA Fall Workshop Series

The dates and locations for the Fall ASA Workshop have been published:

  • Sep 29, 2015 – Miramar, FL Workshop – Hilton Garden Inn-Ft. Lauderdale/SW Miramar
  • Nov 02, 2015 – Singapore Workshop  – Hilton Singapore
  • Nov 19, 2015 – Chicago, IL Workshop – Hilton Garden Inn-Chicago O’Hare Airport
  • Dec 01, 2015 – Seattle, WA Workshop – Courtyard By Marriott Seattle/SEATAC

This workshop is designed for YOU – we typically develop the program based on the input of members and based on the issues that appear to be important to members.  We expect this Fall’s domestic workshops to address issue that continue to generate calls among our members, like recent changes in US export compliance, changes in the FAA’s SUPs program, and changes to the accreditation advisory circular.  The current agenda for the Fall Workshop looks like this:

Time Topic
9:00 – 10:00 Approved Parts in the US and Europe
10:15 – 11:00 Traceability Documentation: What Documents Does the FAA Recommend? What Documents Does EASA Recommend?
11:15 – 12:00 Building Your C of C: Customizing from a SPEC 106 Template or from a Narrative Format – What Should You Include? What Pitfalls Should You Avoid?
12:00 – 13:00 LUNCH
13:00 – 14:30 Export Compliance – the Rules and Exceptions that Apply to Aircraft Parts
14:45 – 15:30 Hazmat Awareness: Identifying Hazmats in Your Inventory
15:45 – 16:30 Magic Words: Drafting Your Commercial Documents to Promote Your Own Commercial Advantage

The Singapore workshop will be a little different, as it will include issues that are important to non-US companies that are doing business with the US and Europe.

Keeping Fasteners Safe

Standard parts – particularly fasteners – continue to be a topic that is being discussed by regulators on both sides of the Atlantic.  We’ve had private conversations with both FAA and EASA executives on this issue.

The Issue

In 2013, EASA published a Safety Information Bulletin (SIB) entitled “Defective Standard Hardware – MS21042, NAS1291 and LN9338 Self-Locking Nuts, and NAS626 Bolts.”  This European SIB highlighted defects in certain self-locking nuts, and certain bolts.  In each case, the fasteners were standard parts.  EASA recommended that those who use these fasteners should visually inspect them for surface irregularities, such as gouges or cracks, before use.  EASA also recommended testing 1% of each lot received as a means of identifying non-conformities.

In 2014, the FAA published a follow-on document (Standard Hardware, AN, MS and NAS Fasteners, FAA SAIB HQ-14-16 (April 28, 2014)) that expanded on the EASA SIB.  Further investigation had shown that the non-conformities were attributed to hydrogen embrittlement and other other latent manufacturing defects.  Although this information was not published, industry rumor suggested that the hydrogen embrittlement was the product of inadequate heat treating.

The FAA has described the defects in these fasteners as “emblematic of potential flaws in other standard hardware.”  In conversations with both FAA and EASA executives on this issue, the root cause opinions appear to be uniform – when many military specification standards were retired by the U.S military, they were then republished by civil standards organizations for continued use in civil aircraft (e.g. AIA publishes the National Aerospace Standards).  After that time, the Department of Defense no longer provided oversight to these standards.  The civil standards organizations do not certify, monitor compliance or perform surveillance of parts produced to these standards (nor of their manufacturers). The responsibility for compliance with these standards and specifications lies with their respective manufacturers – and nearly all of the time, these manufacturers are doing the right thing – they are ensuring that their standard parts meet the requirements of the applicable standards.  But events have shown that a tiny sliver of bad actors can cause unwanted problems, and some people in the government feel that this lack of oversight has left an opportunity for improper manufacturing.

How can we address this lack of oversight economically?  By considering other forms of oversight and assurance.

There is a solution.

Many fastener distributors are accredited to the ASA-100 standard.  The ASA-100 standard includes a requirement that fastener distributors perform visual inspection on fasteners, and maintain batch/lot segregation of fasteners.  This requirement establishes a second set of eyes to help ensure that fasteners are not subject to obvious flaws.

Thus, buying standard parts from ASA-100 accredited distributors helps to ensure the integrity of the fasteners that you are receiving.

The FAA and EASA are both continuing to look at this issue.

We recently met with EASA and proposed that their regulatory structure already is developing a framework for embracing a solution.  EASA published Opinion 2013-12 which included a recommendation for the updating of EASA 145.A.42.  The new language would include enhanced requirements for acceptance of components:

The organisation shall establish procedures for the acceptance of components, standard parts and materials for installation to ensure that components, standard parts and materials are in satisfactory condition and meet the applicable requirements of point (a).

In the proposed GM3 145.A.42(b)(1) that would accompany this regulatory change, Part 145 organizations would be permitted to rely on “other-party” surveillance of suppliers.  This would include reliance on the surveillance performed under the AC 00-56 program and under the ASA-100 program.  The proposed GM is published in the EASA Comment Response Document (CRD).

In light of the fact that ASA-100 already includes fastener surveillance, EASA could use this upcoming promulgation as a tool to better enhance standard fastener oversight by endorsing fastener surveillance as a required element for inclusion in the GM.  By using the distribution community as a second set of eyes, EASA and the FAA would have an inexpensive mechanism for helping to catch problems in cases where fasteners are not properly produced to the expected standards.

Distributor accreditation has been successful in addressing unapproved parts issues, by creating a knowledgeable group with appropriate quality management systems that are designed to identify those sorts of problems.  This model has already been successfully expanded to fastener issues within the ASA-100 community.  This model can also be further expanded to make use of the entire distributor accreditation community as a second set of eyes, watching for fastener issues.

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