ASA Member Bulletin - Sep 2017 - DAR 56 Extended until August 2018
The FAA has extended the Limited DAR-F program that allows certain employees of accredited distributors to issue 8130-3 tags for certain inventory known to have been produced by an FAA production approval holder (commonly known as the "DAR 56 program," reflecting the function code number). This is an important victory for distributors who rely on this program as a source of 8130-3 tags.
One Year Extension
The program was extended by a policy memo published on August 25. The new termination date is September 30, 2018 (it was September 30, 2017). In order to take advantage of this extension, limited DARs with function code 56 privileges must request an extension. The new policy memo explains:
A currently appointed Limited DAR-F may request an extension by submitting an email to 9-AIR160email@example.com. Limited DAR-Fs that do not request an extension will be automatically terminated on September 30, 2017, in accordance with the current expiration date on their Certificate of Authority (COA) letter. The Delegation and Organizational Procedures Branch, AIR-6F0, will send an email to each Limited DAR-F who does not request an extension to inform them of the termination of their appointment. AIR-6F0 will issue a new COA letter with the new expiration date to each qualified Limited DAR-F requesting an extension. Each designee will be required to continue to provide quarterly activity reports using the FY18 Quarterly Activity Report in Attachment 1.
The new policy memo is identified by the policy number "AIR-600-17-6F0-PM01." This extension was made in response to ASA's earlier petition, as well as our ongoing dialogue with the FAA about these issues.
The old DAR 56 policy, AIR-100-16-160-PM13, was previously described in this blog. Reviewing that prior publication may be useful, because it provides many important details that are not repeated in the newer policy memo. The new policy extends the old policy, incorporates it by reference, and includes significant changes in the reporting and oversight mechanism.
New Reporting and Oversight Mechanism
Under the original policy, designees were required to track the number of 8130-3 tags that they issued on a Quarterly Activity Report, but that form was not required to be submitted to the FAA (it remained available for review/submission upon request). The new policy now requires information to be submitted to the FAA:
At the end of each quarterly reporting period, the FAA, via e-mail, will be requesting documentation in support of its oversight of each designee. Designees must submit the requested materials via email to firstname.lastname@example.org. In addition, AIR-6F0 will be making site visits to conduct on-site direct observation of selected Limited DAR-Fs. Each site visit will be coordinated with the designee in advance and the distributor management representative will be notified.
So look for the emailed request for documentation, from the FAA! It is possible that the FAA could ask for something different than the Quarterly Activity Report, but it is unlikely because the Report is the only record required to be kept under the program. Also, do not be surprised if the FAA tells you that they will be visiting your facility to oversee your DARs - these sort of site visits will become a normal part of the process.
The FAA recognizes that DAR 56 is merely a temporary solution to a larger issue. The FAA has published a five step plan to move this issue forward toward a long-term solution:
- FAA meeting with EASA - The FAA has scheduled a meeting with EASA management in Cologne in late August to address the specific EASA requirement for an FAA Form 8130-3 and to discuss other options.
- Additional outreach to production approval holders (PAHs) - The FAA is looking into additional outreach to the PAH community to ensure awareness of the current MAG 6 requirement and that they understand the recent Part 21 rule change allowing them to request a quality manual update to issue tags themselves.
- Work with distributor community to ensure they are requesting Form 8130-3s from PAHs - FAA is planning to reach out to the distributors that have Limited DAR-Fs to encourage them to request Form 81 30-3s on their purchase orders for parts that could be destined for EASA repair stations.
- Ensure awareness of Notice 8900.422 - This notice allows repair stations to perform inspections on parts received without the required documentation and to issue FAA Form 8130-3s. This notice is in essence a reissuance of Notice 8900.380.
- Meeting of FAA and industry reps on 8130-3 tag matter - FAA is planning to arrange a meeting in Washington, DC in the next month or so, where we will bring a select group of industry and FAA stakeholders together to discuss how we further address the 8130-3 tag issues and concerns going forward. We will ensure that [ASA is] invited to participate.
Also on the agenda for the September meeting between FAA and the distribution community in a discussion of ASA's request for expansion of the scope of the DAR 56 program to include (1) parts received after the arbitrary 2016 cut-off date (including newly produced parts and newly surplussed parts), and (2) parts bearing industry standard indicia of airworthiness, like documents described in AC 20-62E, and new surplus parts verified by an air carrier to be in new condition.
The observant among you will notice that the originating office (the first part of the policy number) has changed from AIR-100 to AIR-600. This is because of the FAA's Aircraft Certification reorganization.
Interested in the program, but not yet part of it? Qualified employees of AC 00-56 accredited businesses can still apply for DAR 56 privileges until August 1, 2018.