Comments Filed at Home and Abroad

ASA continues to work diligently to promote and promote and protect its members’ interests both at home and abroad. In the past month ASA has filed comments on a proposed rule change by NASA, as well as a Notice of Proposed Amendment with EASA.

On June 17, ASA filed comments with NASA regarding the proposed definition of “counterfeit goods” detailed in the proposed “NASA FAR Supplement Regulatory Review No. 1.”  The issue of counterfeit goods in aerospace and received a significant amount of attention in recent years.  As we have explained previously, efforts by Congress and the Administration to curtail the presence of counterfeit parts in the supply chain has the potential to impose significant burdens on distributors.

One way to mitigate that burden is to ensure that everyone has a clear understanding of what is—and more importantly, what is not—a counterfeit good.  ASA is working hard on multiple fronts to ensure that the definition of a counterfeit part remains concise, narrow, and legally accurate, to avoid imposing unnecessary and unhelpful burdens on the industry.

ASA also offered comments on EASA’s recent Part 145 NPA.  The objective of the sweeping NPA is to incorporate SMS principles into Part 145, and the proposed changes have the potential to touch not only repair stations, but also distributors and manufacturers.  ASA made numerous suggestions related to the various proposals in the hopes of assisting EASA in order to assist in a more gradual incorporation of these changes, as well as to address proposals that appeared to fall outside the scope of SMS.

ASA looks forward to working with these agencies to craft regulations that promote safety and benefit the industry.