FAR 21 Rewrite Leaves More Questions Than Answers
Unintended consequences of a proposed rewrite of FAR 21 certification procedures for products and parts will place an undue burden on repair shops and small businesses, according to Jason Dickstein, president of Washington Aviation Group. “The devil’s in the details,” he told AIN. Dickstein has been part of the Aviation Rulemaking Advisory Committee working on the rewrite since 1992. “The idea was to modernize outdated regulations but the emphasis was on manufacturing, with little thought to the consequences downstream.” Dickstein is concerned about the term “commercial parts,” referring to “standard parts” produced outside the scope of FAR 21.303(a) and manufactured by a party with no specific intent for the part to be used on an aircraft. Such parts are “made for general usage but are appropriate for use in aircraft, such as light bulbs.” Changing the definition might make it difficult and expensive for operators to comply when replacing the part. “There were so many negative comments to the NPRM, it’s difficult to know how the FAA has altered the proposed regulation. We’ll just have to wait and see,” he said.