FAA DRAFT Designee Policy is Open for Comment

A draft version of the FAA’s designee policy has been published for public comment.

Known by it title, “Designee Management Policy,” this Order is an omnibus of FAA designee policy. It is important to both designees and to the people whose businesses rely on designees. If you use designees to issue 8130-3 tags, then this means you!

One element on which ASA intends to comment is the continuing disconnect between current published 8130-3 tag policy and the function code policy. Despite the FAA eliminating distinctions between 8130-3 tags supporting export vs. domestic transactions, the function codes continue to support the prior practice that drew a distinction between the tags. This creates unnecessary artificial barriers to the documentation of airworthiness, and has been shown by the FAA to undermine both safety and commercial interests.

Resources:

If you have comments or edits for this draft document, then please share them with ASA so ASA’s comments can address industry’s concerns.

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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