Accreditation Alert! DRAFT AC 00-56B is out for comment!

The FAA has released for public comment AC 00-56B, which is the draft revision to the Voluntary Industry Distributor Accreditation Program (current version is AC 00-56A).

This draft FAA advisory circular (AC) describes a system for accrediting aircraft parts distributors based on compliance to a standard and certification of that compliance by FAA-acceptable accreditation organizations.  ASA has been part of this program since the beginning, and is an important FAA partner in the mission to improve aviation safety through effective management systems.

The FAA has strongly endorsed participation in the AC 00-56 program.  FAA is revising this AC to reflect the changes in regulatory requirements and industry practices since the last revision.

ASA met with its Quality Assurance Committee (QAC) on December 5 to review and examine this proposed change.  The QAC was generally supportive of the draft AC, and spent its time examining ways to further improve the document.  ASA is in the process of developing comments based on that QAC meeting.  Those comments will address subjects like these:

  • A transition mechanism for ensuring that industry has time to come into compliance with the new standards
  • Firming up an accurate description of the the relationship between the accreditation organization and the quality system standard holder
  • Firming up an accurate description of the the relationship between the accreditation organization and the FAA
  • Clarifying the definition of distributor
  • Clarifying the definition of Distributor Accreditation
  • Clarifying the definition of Quality System
  • Clarifying the definition of Traceability so it is consistent with current industry connotations
  • Using terminology that is consistent with other FAA guidance
  • Ensuring that FAA audit expectations are adequately described
  • Ensuring that FAA requirements for auditors adequately reflect current industry best practices
  • Clarifying the FAA’s changes in the quality system elements
  • Ensuring that citations to statutes and standards are correct
  • Updating the documentation matrix to reflect current standards and also to reflect the current global nature of the AC 00-56 program

The documentation matrix was subject to significant discussion, and the QAC worked on a proposal to further strengthen the matrix in order to support both current and future industry ‘best practices.’

The draft is open for public comment through January 4, 2015.  Comments should be delivered to

Robert McDonald
1625 K Street NW
Suite 300
Washington, DC 20006

Comments can also be emailed to Robert.CTR.McDonald@faa.gov or faxed to (202) 223-4615, Attn: Robert McDonald.

Please also send a copy of your comments to ASA, so that we can be sure that your views are reflected in the Association’s comments.

About Jason Dickstein
Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. Since 1992, he has represented aviation trade associations and businesses that include aircraft and aircraft parts manufacturers, distributors, and repair stations, as well as both commercial and private operators. Blog content published by Mr. Dickstein is not legal advice; and may not reflect all possible fact patterns. Readers should exercise care when applying information from blog articles to their own fact patterns.

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