Summarizing the New FAA Manufacturing and Airworthiness Guidelines

The FAA recently finalized the latest version of its rules for airworthiness and component manufacturing. This situation presents an interesting case study in the cross section of the legal and economic worlds as many of members of industry impacted by the revisions to the existing rules claimed during the commenting period that the costs of the proposed rules would be prohibitive. Though the FAA clearly took a number of industrial complaints under advisement, it still managed to update certain safety standards. Following is a summary of the main changes.

Starting April 14, 2010, the Federal Aviation Administration (FAA) will begin to utilize a new set of certification procedures and identification requirements for aeronautical products and articles. These changes are being promulgated after a nearly four year comment and revision process embarked upon in 2006, and despite the objections of some in the industry who believe some of the changes to be cost prohibitive. The updates will impact production approval holders (PAHs) and manufacturers, with the stated goals being promotion of safety and to better reflect the current global aircraft industry operating environment.


In addition to clarifying certain existing rules and definitions, as well as describing updates to permitting and compliance procedures, the rules contain two changes to the current system that manufacturers in the airline industry should be particularly aware of due to their impact and contentious nature. These include; 1) new requirements for the marking of parts for identification purposes, and 2) new quality control procedures. Notably, two areas of great concern to the industry which the FAA had originally proposed changes to, namely issuance of airworthiness certificates and the addition of certification staff, were left unchanged in the final proposal due to lack of impact on safety and overwhelming potential costs.

Until now, the FAA had only required that parts, and not their individual components, be marked. Although not as sweeping as originally had been planned, the FAA has nonetheless made changes to this rule. Now, PAHs must also mark sub-assemblies and component parts if they leave their facilities as separate articles. These must include the manufacturer’s part number and name, trademark, symbol, or other FAA-approved PAH identification (e.g.,the production approval number, cage code, or Federal supply code for manufacturers (FSCM)). According to the FAA, this is a codification of current industry standards and is less stringent that proposed requirements, which would have included the marking of every component.

Prior to now, PAHs were auditing under various requirements based on the individual parts being produced. Under the new rules, the FAA has attempted to standardize auditing requirements, making them more uniform for all producers. According to the FAA, this is the result of a combination of best practices, ISO standards, and a combination of other sources including other aviation safety authorities. Some of the requirements include procedures for controlling use of design data, tests for design conformity, and rules for scrap parts, among others. For specific guidance on how to construct compliant quality control systems, the FAA will provide additional information on the internet site http://www.faa.gov.