On December 20th, ASA met with FAA Aircraft Certification Director Dorenda Baker. In addition to ASA staff and FAA staff, the meeting also included ASA members John Nepola (East Air), Brent Webb (CAVU Aerospace), Mitch Weinberg (International Aircraft Associates) and Paul Wolf (Boeing). The topic of discussion was the documentation (8130-3 tag) requirements of the FAA/EASA Maintenance Annex Guidance (MAG).
During the meeting, the FAA agreed that the new documentation standards appear to reflect an unintended consequence. The members explained that the unintended consequence is adversely affecting domestic aircraft parts transactions and is creating an environment that could diminish safety.
The FAA has expressed that there are some international political pressures that make it difficult to rescind the documentation requirements of the FAA/EASA MAG. So we discussed ways to support the documentation paradigm by making 8130-3 tags reasonably available for existing, airworthy, inventory.
One option would be to add a considerable number of new DARs to the system. The actual number of DARs available to tag aircraft parts inventories is frighteningly small, which has led to monopolistic pricing, which has caused their services to become economically unavailable for many aircraft parts.
The DAR Function Code 56 privilege reflected a good start, but the privilege is too narrow to do much good. Even for distributors whose business models are perfectly aligned with the function code's scope, they found that only about 1/3 of their inventory could be tagged under this function code. And most distributors found that the privilege was considerably less useful than that. Consistent with our June 2016 written proposal, we suggest that:
- the function be expanded to include parts bearing indicia of airworthiness (including documentation from certificated air carriers indicating that the parts are in new surplus condition, as well as documentation described in FAA AC 20-62E);
- the end date of the program be extended (in part because aircraft parts are still being manufactured and released without 8130-3 tags, and in part because it is still common for air carriers to sell new surplus inventories without 8130-3 tags);
- the program element that limits Function Code 56 to only parts received before November 1, 2016 be removed.
The FAA has limited ability to oversee new DARs. For this reason, ASA has volunteered to audit DARs operating within the ASA-100 environment (subject to their own willingness to be audited). ASA is already auditing these facilities on a regular basis under the AC 00-56 program, and is already subject to FAA oversight within this AC 00-56 program. The FAA may use ASA's audits as a risk-mitigating factor in planning its own oversight schedules.
We have discussed other options, like creating an ODA for distribution businesses to obtain 8130-3 tags, or rapidly increasing the community of DAR-F or DAR-T personnel; but the DAR Function Code 56 program seems like a solid foundation upon which to build a scalable program that can be scaled-up to meet FAA safety needs, and then scaled-down as the industry moves into the new documentation paradigm.