FAA issues new SUPs Guidance

The FAA has issued a “change one” to the SUPs Advisory Circular: AC 21-29D, Detecting and Reporting Suspected Unapproved Parts.
The change adds better information on how to subscribe to the FAA’s Unapproved Parts Notices (UPNs) in order to get them when they are issued, and it also updates some office references to make them consistent with the FAA’s reorganization.
Remember, the FAA eliminated the ability to make a SUPs report by phone when they issued the “D” revision last summer.  SUPs reports must be provided to the FAA by e-mail or by US mail.
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ICA Guidance Open for Comment

The FAA has released for comment two guidance documents pertaining to Instructions for Continued Airworthiness (ICA): Draft FAA Order 8110.54B and Draft Advisory Circular 20-ICA. ICA availability is an issue that has a direct effect on repair stations and distributors, and ASA has done a significant amount of work to ensure that ICA are available and accurate in accordance with the Federal Aviation Regulations.

Draft Order 8110.54B is guidance directed at FAA personnel and persons responsible for administering the requirements for ICA.  Among other changes, the draft reorganizes the Order to reflect material moved to AC 20-ICA (below), and importantly incorporates guidance implementing the FAA’s Policy Statement PS-AIR-21.50.01, Type Design Approval Holder Inappropriate Restrictions on the Use and Availability of Instructions for Continued Airworthiness.  ASA has been supportive of the FAA in the adoption that Policy Statement that is intended to protect the industry from anti-competitive ICA restrictions.

Draft AC 20-ICA is a new Advisory Circular that removes industry-specific guidance from the internal FAA Order and places it in a stand-alone AC.  This effort is similar to the FAA’s actions in revising other Orders, which are directed to FAA employees, and removing guidance that is actually intended to be directed outward toward industry and properly placing it in an Advisory Circular.  Like Draft Order 8110.54B, the draft AC implements the FAA policy on ICA established in the Policy Statement.  The proposed AC provides guidance to design approval holders (DAH) and design approval applicants for developing and distributing ICA.

Not only does the availability of ICA directly effect repair stations, the availability of parts lists that are included as a part of the ICA is an important issue for the supplier community.

After a preliminary review these documents appear to offer very positive guidance for the aviation maintenance and distribution industries.  ASA will be reviewing both of these documents closely and offering comments and support for these policies to the FAA.  We encourage repair stations and distributors to review both documents as well.

Comments on both guidance documents must be submitted by October 6, 2015, and may be submitted to the FAA via email to 9-AVS-ICA@faa.gov.  If you have comments or observations that you feel ASA should include in its comments to the FAA, email them to Ryan Aggergaard at ryan@washingtonaviation.com so the we can include them.

FAA issues REVISED AC 00-56B – Voluntary Industry Distributor Accreditation Program

The FAA has issued the long-awaited revision to AC 00-56. This advisory circular describes the Voluntary Industry Distributor Accreditation Program (VIDAP).

This is the “B” revision, and it includes statements about a number of issues that have been part of the FAA’s understanding of the program (so they were part of the ASA implementation based on FAA input) but that had not previously been in print.  It also updates the language to a “plain language” format as well as clarifying some points that had been vague.

The updated version of the AC will be available on the main FAA website; however as of 1:00 pm today it was not yet available.  This is not unusual, and we expect that it should be available on the FAA’s main website by Monday.

However, it *IS CURRENTLY AVAILABLE* in the Regulatory and Guidance Library (RGL).   If the link to the RGL does not work then just go to rgl.faa.gov and use the search engine to find 00-56B.

The ASA Quality Assurance Committee (QAC) will meet on June 7, 2015 in Scottsdale Arizona (click here for more information on the meeting) to discuss the changes in-depth and to consider whether any additional changes to ASA-100 are necessary to reflect the changes to the AC.  The FAA is expected to present the AC at this meeting, and to be available to answer questions.

This ASA QAC meeting is part of the ASA Annual Conference.  We look forward to seeing you there!

Accreditation Alert! DRAFT AC 00-56B is out for comment!

The FAA has released for public comment AC 00-56B, which is the draft revision to the Voluntary Industry Distributor Accreditation Program (current version is AC 00-56A).

This draft FAA advisory circular (AC) describes a system for accrediting aircraft parts distributors based on compliance to a standard and certification of that compliance by FAA-acceptable accreditation organizations.  ASA has been part of this program since the beginning, and is an important FAA partner in the mission to improve aviation safety through effective management systems.

The FAA has strongly endorsed participation in the AC 00-56 program.  FAA is revising this AC to reflect the changes in regulatory requirements and industry practices since the last revision.

ASA met with its Quality Assurance Committee (QAC) on December 5 to review and examine this proposed change.  The QAC was generally supportive of the draft AC, and spent its time examining ways to further improve the document.  ASA is in the process of developing comments based on that QAC meeting.  Those comments will address subjects like these:

  • A transition mechanism for ensuring that industry has time to come into compliance with the new standards
  • Firming up an accurate description of the the relationship between the accreditation organization and the quality system standard holder
  • Firming up an accurate description of the the relationship between the accreditation organization and the FAA
  • Clarifying the definition of distributor
  • Clarifying the definition of Distributor Accreditation
  • Clarifying the definition of Quality System
  • Clarifying the definition of Traceability so it is consistent with current industry connotations
  • Using terminology that is consistent with other FAA guidance
  • Ensuring that FAA audit expectations are adequately described
  • Ensuring that FAA requirements for auditors adequately reflect current industry best practices
  • Clarifying the FAA’s changes in the quality system elements
  • Ensuring that citations to statutes and standards are correct
  • Updating the documentation matrix to reflect current standards and also to reflect the current global nature of the AC 00-56 program

The documentation matrix was subject to significant discussion, and the QAC worked on a proposal to further strengthen the matrix in order to support both current and future industry ‘best practices.’

The draft is open for public comment through January 4, 2015.  Comments should be delivered to

Robert McDonald
1625 K Street NW
Suite 300
Washington, DC 20006

Comments can also be emailed to Robert.CTR.McDonald@faa.gov or faxed to (202) 223-4615, Attn: Robert McDonald.

Please also send a copy of your comments to ASA, so that we can be sure that your views are reflected in the Association’s comments.

FAA Updates SUPs Guidance

The FAA has updated the guidance on detecting and reporting suspected unapproved parts (SUPs), which is known as Detecting and Reporting Suspected Unapproved Parts, FAA AC 21-29C CHG 2 (August 17, 2011).

The advisory circular’s update provides new references to various sections in Part 21 , to coincide with the October 16, 2009 changes in Part 21.  It also makes reference to the new commercial parts definition (part of the 2009 rule change), and clarifies that commercial parts are approved parts.

References to “fabrication inspection systems” are removed from the guidance (the concept of “fabrication inspection systems” was removed from the regulations in favor of unified standard production quality system regulations for all production approval holders).

Finally, the guidance is updated to reflect changed addresses and telephone contact numbers.

The newest guidance can be found online here:

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