New Guidance on Completing 8130-3

November 2, 2025 by 1 Comment

The FAA has new instructions on how to complete 8130-3 tags.

FAA Order 8130.21J is the new guidance on how a manufacturer or an FAA designee completes the FAA Form 8130-3. It becomes effective on November 24, 2025. This order includes instructions for a designee who issues the form for parts at a distributor’s facility:

When issued at a distributor, a 14 CFR part 121 or 14 CFR part 135 certificate holder, or a 14 CFR part 145 certificated repair station, enter the following statement: “The product or article shipped under this approval was produced by [insert PAH’s name and CM project number].”

The order also includes instructions for splitting bulk shipments:

8.f.(2) Splitting a bulk shipment. Any person may split a bulk shipment that the person owns or controls. When splitting bulk shipments, PAHs, PAH associate facilities, distributors, PAH-approved suppliers having direct shipment authorizations shall have procedures in place to control products or articles. Previously shipped bulk shipments of new products or articles may be split as many times as the original quantity listed in block 9 permits. Products or articles received without an FAA Form 8130-3 must not be mixed with those received with FAA Form 8130-3. To split a bulk shipment associated with a form, copy the form and either:

(a) Indicate on each copy of the form (front or back side) the number of aircraft engines, propellers, or articles being shipped, tracking number for the portion being shipped, and the name, physical address, date, and contact information of the person splitting the shipment, or;

(b) Make a statement on a separate document accompanying each copy that includes: the tracking number of the original form, tracking number for the portion being shipped (tracking number assigned to the new statement by the person responsible for splitting the bulk shipment), number of aircraft engines, propellers, or articles being shipped (under this new statement), and the name, physical address, date, and contact information of the person splitting the shipment.

Note: Retain a copy of the form or the separate document used to split a bulk shipment
according to paragraph 8.d. This note only applies to paragraph 8.f.(2)

FAA Advisory Circular 43-9D is the new guidance on how a repair station or other maintenance provider completes the FAA Form 8130-3 as an approval for return to service and maintenance release. Rebuilds performed under 14 C.F.R. 43.3(j) and approved under 14 C.F.R. 43.7(d) ARE NOT part of this guidance (they are covered under Order 8120.18A).

Resources

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Unapproved Parts: Landing Gear

February 20, 2025 by Leave a comment

The FAA has issued a new Unapproved Parts Notice (UPN) concerning landing gear manufactured and/or distributed by Seaplanes North, LLC. The landing gear was intended for installation on Aviat Aircraft, Inc., models A-1 through A-1C-200 (type certificated products).

The FAA UPN claims that Seaplanes North, LLC, located in Anchorage, Alaska, produced and sold landing gear (identified as part numbers (P/Ns) 45017-501HD-3X and 45017-502HD-3X). They sold them to various aftermarket users, and the FAA claimed that his was accomplished without an FAA production approval.

Typically, any person who knows that a replacement or modification article is reasonably likely to be installed on a type-certificated product, the person may not produce that article unless it is produced under one of the FAA-published methods found in the regulations. This includes production under FAA production approval (14 C.F.R. § 21.9(a)(2)). There is a path for repair stations to produce parts for consumption during maintenance (14 C.F.R. § 21.9(a)(6)) but unapproved landing gear typically cannot be produced and sold directly to the aftermarket.

More details are available in the FAA UPN.

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New FAA SUPs Reporting Form

September 27, 2024 by Leave a comment

The FAA has published an updated version of the Form 8120-11. This is the form for reporting suspected unapproved parts (SUPs).

One obvious change is the Privacy Act statement, which is bolder and moved to a separate front page (the substance remains similar). The information in the form, though, remains substantially unchanged.

This is not the first update to the form. The 2016 version of the form placed the instructions on the first page so that people could read them before getting to the form (the 2009 version placed the instructions after the form and before the continuation sheet, which caused some confusion).

The FAA estimates that it receives about 150 of these completed forms per year. They also believe that the form takes about 30 minutes to complete. Most importantly, the FAA uses these forms as the first step in assessing whether an unapproved parts investigation is warranted.

If you encounter a Suspected Unapproved Parts, or SUP, then reporting is typically voluntary under the regulations; however many aviation companies have imposed mandatory SUPs reporting requirements on themselves (as a commercial obligation) through their quality manuals or operations manuals.  Be sure to follow your own internal guidance when considering whether to report a SUP!

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FAA Proposed to Apply Drug Testing Rules to Foreign Repair Stations

December 8, 2023 by Leave a comment

The FAA has published a proposed rule that would apply FAA drug-and-alcohol testing rules to foreign (non-US) repair stations.

Statutory Authority

49 U.S.C. 45102 directs the FAA to prescribe drug-and-alcohol testing regulations for air carriers and foreign air carriers. Section 308 of the FAA Modernization and Reform Act of 2012 (the Act), 49 U.S.C. 44733(d)(2), requires the FAA to “promulgate a proposed rule requiring that all part 145 repair station employees responsible for safety-sensitive maintenance functions on part 121 air carrier aircraft [be] subject to an alcohol and controlled substances testing program determined acceptable by the [FAA] Administrator and consistent with the applicable laws of the country in which the repair station is located.” Section 2112 of the FAA Extension, Safety, and Security Act of 2016 directed the FAA to finalize the drug-and-alcohol provisions.

Regulatory Actions

The FAA published an advanced notice of proposed rulemaking (ANPRM) on this subject on March 17, 2014.

Opponents of this provision suggested that this could be considered an imposition on the sovereignty of the foreign government. Commenters to the ANPRM suggested that the FAA shouldn’t impose regulations on persons outside the territory of the U.S. where those regulations conflict with the laws of sovereign nations.

The FAA determined that it might be true that extra-territorial application of FAA drug-and-alcohol testing regulations might violate national and international law “and might exceed generally recognized limits to extraterritorial jurisdiction.” Nonetheless, the FAA reasoned that if an FAA testing rule was contrary to the applicable laws of a country in which a repair station was located, then the appropriate remedy would be for the repair station to apply for an exemption from the FAA’s drug-and-alcohol testing regulations.

Comments are due February 5, 2024.



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McPeck Aviation UPN

October 4, 2022 by Leave a comment

This FAA has issued an Unapproved Parts Notice (UPN) advising that “all articles produced and/or sold by
McPeck Aviation and/or Adam McPeck … do not have FAA production approval.”

The UPN advises the industry to look for articles that have the following characteristics:

“• Gaskets and O-rings are manufactured from a blue colored Fluorosilicone material.
• Cowl flap hardware kits contain a white colored acetyl resin washer.
• FAA Form 8130-3, Airworthiness Approval Tag, is not provided with the parts.
• Instrument panels have a supplemental type certificate design approval, but no FAA production approval.”

As usual, the the FAA asks distributors to look in their inventories for these parts, and “the FAA recommends that they be quarantined to prevent installation or use until a determination can be made regarding their eligibility for installation.”

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What Does it Mean if a Component has “a Negligible Safety Effect on the Product”? And Does it Change the Documentation Requirements?

September 6, 2022 by Leave a comment

Has your aircraft or engine manufacturer designated certain parts as having “a negligible safety effect on the product.” What does this mean? And what sort of documentation should you expect on these parts?

A European rule permits manufacturers to designate certain parts that do not need production approval and do not need EASA Form 1. This is not a novel concept – we have the same rule in the United States. Under the FAA regulations, these components are called “Commercial Parts.” 14 C.F.R. §§ 21.1(b)(3), 21.50(c). 

For roughly 15 years, FAA rules have permitted manufacturers to designate parts as “commercial” by demonstrating two facts:

  • The failure of the commercial part, as installed in the product, would not degrade the level of safety of the product; and
  • The part is produced only under the commercial part manufacturer’s specification and marked only with the commercial part manufacturer’s markings

After making an engineering demonstration to show these facts, the design approval holder would then publish the commercial parts in a list that was an element of the Instructions for Continued Airworthiness (ICA).

Very few design approval holders (DAHs) have chosen to take advantage of this opportunity. There are legal liability reasons for being cautious about this, but in addition to increased legal liability, this would also mean that the DAH lose quality control of the transaction. Many production approval holders (PAHs) would prefer to offer direct ship authority to suppliers (or rely on other traditional legal constructs like ‘licensed PMA’) so that the manufacturer (DAH/PAH) can continue to control the quality assurance as well as having contractual provisions limiting the DAH/PAH’s liability in the event of an issue.

I wrote about this EASA proposal in December 2019:

No EASA Form 1 for Certain EU Parts?

ASA raised a number of concerns when this was proposed.  A few of these concerns were addressed by EASA but not all of them.

The new EASA rule requires the design-approval holder to identify the parts as having “a negligible safety effect on the product.”  This is comparable to the United States’ “commercial parts” rule (14 C.F.R. §§ 21.1(b)(3), 21.50(c)).  So the first problem that we can see with this rule is that the same DAHs who did not designate parts in response to the US rule change are probably not going to designate parts now that EASA has added a comparable rule. 

Right now my biggest concern is that this rule-change will not be useful to most of the industry because of a lack of participation among the DAHs.  The fact that it may not be useful means that any safety-negatives associated with the rule are particularly bitter pills.

The rule change creates new complexity in the system, by permitting parts that previously used the EASA Form 1 to be sold under certificates of conformity, instead. The existing variety of certificates of conformity for standard parts has already created confusion in the industry. Distributors are an important link in the chain of commerce, and they play a vital role in scrutinizing documentation to detect and address problems before those problems can be passed on to an installer.

The rule change creates an opportunity for counterfeit parts to enter the system, because the exempted parts are described only in the ICAs.  Distributors typically do not have access to the ICAs.  This means that distributors will not be able to distinguish a part that is exempt under 21.307(b)(3) from one that is fraudulently claimed to be exempt; and the industry could lose the ability to easily read the new C of Cs for parts that were previously subject to EASA Form 1 but now are being moved to C of Cs.  Fraud is already difficult enough to detect, but the regulatory authorities may no longer have jurisdiction over frauds that do not rely on regulatory authority documentation (like the EASA Form 1), which will diminish some of the front-line response opportunities.

One way to help industry mitigate risks would be for the rule to require publication of the list of “negligible safety parts” (“commercial parts” in the FAA system) to anyone in the industry. This would permit distributors to be able to see who is eligible to produce such parts. When they receive a questionable certificate of conformity for a “negligible safety” part, they would be able to review the list of qualified producers to identify whether that producer was authorized to produce “negligible safety” parts.

The new EASA rule is a manufacturing rule; so how does it intersect with repair station obligations? As we all know, EASA 145.A.42 requires the repair station to obtain an EASA Form 1 or equivalent with each received part. The repair station rules were updated to include an exception for parts that are on one of these “negligible safety” parts lists. Commission Implementing Regulation 2021/700 (EU), Annex II (26 March 2021). Such parts will NOT need an EASA Form 1 or equivalent under the published exception.

Distributors should be especially careful with parts from Europe that are alleged to be subject to the “negligible safety parts” standard. Where possible, reach out to the DAH/PAH and obtain a copy of its “negligible safety parts” list so you can confirm that the European supplier is permitted to produce parts without a Production Organization Approval (POA) and without issuing an EASA Form One.

Also, distributors will want to carefully watch the bilateral agreements to assess when these sorts of parts will be permitted. The current version of the US-EU Technical Implementation Agreement is the April 2019 version, and that version requires EASA form 1 for all parts accepted into the United States. There is an exception for standard parts but there is not yet an exception for “negligible safety parts.” Because these parts woudl not have EASA FOrm 1 (and would appear to be ineligible for such a tag) they would not be eligible for import into the United States under the US-EU agreements. In summary, this means that such parts could be eligible for installation under EASA rules but they would not be eligible for import and installation under FAA rules (e.g. on FAA-registered aircraft) unless the DAH also compiled a commercial parts list under FAA rules.

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UK CAA FAQ: UK CAA Documentation Requirements for Parts

March 1, 2022 by Leave a comment

QUESTION:

UK CAA accepts 8130-3 tags but not EASA Form 1.  Is it possible for an EU based Part 145 organization who has both EASA and FAA approval to provide only a FAA single release certificate and only present this certificate to the UK based organizations as long as the UK based organizations are accepting of a single release certification for a part.  

SHORT ANSWER:

No.  If you ask an EU-based repair station that has both US and EU repair station credentials to maintain an aircraft part and to issue an 8130-3 to document the work it performed, and then subsequently proffer that 8130-3 as the basis for airworthiness determinations prior to installation on a UK-registered aircraft, then the work may be rejected by the UK on the grounds that it does not meet current UK regulatory requirements.

LONGER ANSWER:

Under the new UK CAA standards that go into effect April 1, 2022, the UK CAA will accept maintenance approved on an 8130-3 tag but will no longer accept maintenance released on an EASA Form 1 when issued after April 1.  The questioner offers a clever approach to the impending UK CAA limits.  Unfortunately, this approach puts form over substance.  The root issue is the governmental oversight of the work – not the way that the work is documented.  Therefore, using a clever approach to change the documentation will not be an acceptable way to circumvent UK CAA maintenance controls. 

There are several inherent problems with this clever approach.  First, it undermines the intent of the regulations.  The current intent of UK CAA is that they will no longer accept maintenance performed by EU repair stations.  Second, because the UK CAA intent is to reject maintenance performed by EU repair stations (except when they obtain UK CAA certification), the UK CAA’s established protocols will not permit the UK to rely on maintenance performed by EU-based repair stations (no matter what documentation they use) [NOTE: EU-based repair stations may apply for UK 145 certification, and then their work becomes acceptable under the UK system].  Third, even if it was not undermining UK CAA intent, it is not currently an available process under the existing bilateral agreements because it does not meet their plain language.

To understand why the clever approach does not work, it is important to understand the basis of aviation maintenance regulation.  Under ICAO standards, the country of registry for an aircraft is responsible for the applicable maintenance standards.  This means that the UK CAA is responsible for the continued airworthiness of aircraft on the UK registry.  The UK CAA issues repair station certificates and provides ongoing oversight to those facilities in order to help manage the continued airworthiness processes.

Under normal bilateral airworthiness relationships, one country may agree to accept maintenance performed by repair stations located in the other.  This can be accomplished through “reciprocal acceptance” or through “dual-certification.”

Under a reciprocal acceptance paradigm, the accepting country (which will be the country of registry with the applicable airworthiness responsibilities) would treat maintenance performed by the maintaining country (which will be the country that issued the repair station certificate) as if it had been performed by a repair station subject to the accepting country’s certificates.  Typically, under a reciprocal acceptance paradigm, the repair station only needs one certificate (from its home government) and that certificate is acceptable for work performed for operators from both jurisdictions.  An example of this can be found in the Canada-US relationship, where each country’s operators are permitted to rely on maintenance performed by the repair stations in the other.  A reciprocal acceptance relationship seems easy, but it requires a tremendous level of trust between the aviation safety authorities.  As a consequence, it is more common to see dual-certification relationships described in bilateral aviation safety agreements.

Under dual-certification relationship, the foreign nation issues foreign repair station certificates in collaboration with the home government.  For example, the EU-US agreements have recognized that the repair station oversight systems of both FAA and EASA are very similar and achieve substantially similar goals.  They have also identified a small number of critical differences between the two repair station certification schemes (these differences are known as “Special Conditions”).  Repair stations in the United States that want to get EASA 145 credentials need to create a manual and a system that addresses those Special Conditions.  An FAA Flight Standards maintenance inspector will inspect the EASA-145 applicant who is locate in the United States to confirm that (1) the repair station meets all of the FAA regulations and (2) the repair station complies with the EASA Special Conditions.  If the repair station meets all of the requirements, then the FAA will recommend to EASA that it issue an EASA 145 certificate and EASA may issue such a certificate.

The FAA and EASA maintain a dual-certification relationship with respect to aviation maintenance.  Repair stations must follow the requirements under that relationship to maintain their repair station credentials.  Under the EU-US bilateral agreement, an EU-based repair station that has both sets of repair station credentials must issue an EASA Form 1 as a release document for maintenance.  It does not have an option to issue an 8130-3 tag.  In the event it must release work that is acceptable in the US but not in the EU, the repair station must release the work on an EASA Form 1 that is annotated with the phrase:

The work identified in Block 11 and described herein has been accomplished in accordance with 14 C.F.R. part 43 and in respect to that work, the items are approved for return to service under certificate no.________.

This product/article meets 145.A.50 requirements, except for the following items, and therefore is “not” eligible to be installed on an EU-registered aircraft:

[** LIST THE DIVERGENCES **]

US-EU Maintenance Annex Guidance, Section C: Appendix 1, para. 7.5 (March 19, 2021).

So the first problem with the clever solution is that an EU-based dual certificated repair station is required to issue an EASA Form 1 under the FAA-EASA Maintenance Annex Guidance.

There is an additional technical impediment.  The US-UK Maintenance Implementation Procedures (MIP) do not blindly rely on the 8130-3 tag.  Under that US-UK MIP agreement, the UK CAA accepts approvals “for return to service by an AMO located in the United States under the FAA’s oversight.”  The US-UK MIP does not accept work performed in the EU.  So there is no legal basis for acceptance in the UK of an 8130-3 that documents work performed in the EU.

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FAA Clears 737 MAX for Service

November 18, 2020 by Leave a comment

Today, the FAA issued Safety Alert for Operators 20015 (SAFO 20015) regarding the return to service of Boeing 737-8 and 737-9 airplanes (referred to collectively as the 737 MAX).

Boeing has made changes to the 737 MAX:

  • Aircraft design,
  • Aircraft Maintenance Manuals (AMM),
  • Fault Isolation Manual (FIM),
  • Component Maintenance Manual (CMM),
  • Maintenance Review Board Report (MRBR), and
  • Master Minimum Equipment List (MMEL).

The FAA also issued Notice 8900.570 today, to provide guidance concerning this return to service of 737 Max aircraft that received their certificates of airworthiness before November 18th (today) . The FAA is also issuing airworthiness directive 2020-24-02 (as of this time, this AD is not yet available on the FAA’s websites nor on the Federal Register website but it ought to be available quite soon).

Contacts at U.S. air carriers told me this morning that they are actively working to return these aircraft to service, now that they’ve been cleared by the FAA. This aircraft design has probably received more government scrutiny than any design in the history of aviation, so many industry insiders have a great deal of confidence in the current 737 MAX design.

More details also continue to be available on Boeing’s website, which has a dedicated page on the 737 MAX.

UPDATE: Airworthiness directive 2020-24-02 was published two days later, in the November 20 Federal Register.

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FAA Efforts to Re-Tool Itself in Response to Covid-19 Closures

April 22, 2020 by 1 Comment

We had a phone call today with FAA Associate Administrator Ali Bahrami and his team.  This is part of a series of calls in which we’ve been engaged to share information and keep everyone working together during the Covid-19 crisis.  Bahrami is working from home but he nonetheless has been very transparent with the industry about the FAA’s efforts.

Here are some bullet points on new developments in aviation regulation:

  • FAA has issued a SAFO 20009 for air carrier crews.  This replaces SAFO 20003 (an earlier document with guidance for air carrier crews).  It includes guidance for health monitoring and health protection.
  • FAA is working on a new Special Federal Aviation Regulation (SFAR) to address a wide variety of issues that are caused by the current Covid-19 crisis.  This mostly addresses timing issues where certificates or approvals are expiring but cannot safely be renewed at the present time.  It is in FAA coordination and is moving toward finalization.  The next step will be DOT review.  DOT knows that this is a priority.  The FAA confirmed today that there is presently no authoritative list of items in the SFAR because the draft is still subject to change; nonetheless, the SFAR is expected to provide extensions for a number of recurring regulatory requirements, including:
    • Extensions of pilot currency requirements;
    • Extensions for certified flight instructor certificate requirements;
    • Extension of knowledge examination expiration periods;
    • Extension for filing certain documents under the FAA’s enforcement provisions;
    • Extensions for certain aircraft maintenance / continuing airworthiness requirements.
  • FAA issued an aircraft certification service policy for the use of remote technology.  Flight Standards has been working on their own corollary document.  FAA Maintenance Division Manager Jackie Black explained that the maintenance and operations industry sectors have different business needs from those of the manufacturing sector.  Thus, the Flight Standards guidance is different from the Aircraft Certification guidance.  This guidance was signed by Ricardo Domingo today so it will be issued very soon.  It has already been briefed to the Flight Standards managers.  Mr. Domingo asked Mr. Black to make it available to industry.
  • The FAA has the power to reinspect or reexamine an FAA-issued certificate at any time.  This is known as a 709 reexamination because the authority is found in 49 U.S.C. 44709.  For 709 reexaminations, the FAA has said that if you make a request then they can delay the re-examination or conduct it remotely.
  • The FAA is looking into how to handle IA recurrent training.  They have already extended the expiration date of existing approved courses.  There are some existing remote-delivery courses in the FAA’s IA-training database but many courses were approved only as “conventional” courses (e.g. live-and-in-person).  Forthcoming guidance will allow the current providers of already-approved courses to change the format of delivery (to permit remote delivery), without having to go through a burdensome re-approval process for the new method of delivery.
  • FAA has received an OMB memo about planning for the return of FAA employees to the office (using the White House’s three-phase approach).  FAA is currently defining a process that meets the OMB requirements, so they can be prepared for a return to in-office operations.

 

 

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FAA Authorizes ASA to Perform Remote Auditing under AC 00-56B

April 2, 2020 by Leave a comment

This morning, the FAA sent a letter to ASA authorizing ASA to conduct remote audits during the Covid-19 National Emergency.

This will allow ASA-100 accredited companies to obtain audits during the coronavirus crisis, and to maintain their ASA-100 and AC 00-56B accreditation. ASA will continue to play its part in supporting safety through the aviation supply chain.

What if you are accredited to AC 00-56B through an ASACB audit under one of the ISO standards: ISO9001, AS9100, AS9110 or AS9120?  No problem.  ASACB also secured permission from the FAA to perform remote audits for AC 00-56B accreditees under one of the FAA-recognized ISO9001, AS9100, AS9110 and AS9120.  ANAB, the ANSI National Accreditation Board, has already issued permission for ASACB to perform remote audits.  Both sets of permission are necessary, because both FAA and ANAB have oversight authority over ASACB.

Background

Why did ASA need to go through this formal approval process?

FAA AC 00-56 Accreditation Supports Safety

In the 1980s and 1990s, there were industry concerns that aircraft parts distribution could be a source of inadequate parts that failed to meet safety standards. The FAA investigated a number of options, such as regulating distibutors, and decided to try setting voluntary standards and permitting third party oversight as a tool for establishing safety assurance standards to be used in distribution.

The FAA published AC 00-56 (the Voluntary Industry Distributor Accreditation Program) in 1996. The program recognized Accreditation Organizations with standards that were considered acceptable to the FAA.  One of those Accreditation Organizations was ASA, which used ASA-100 (and later was also permitted to use ISO9001, AS9100, AS9110 and AS9120).  The recognized Accreditation Organizations were permitted to audit Distributors’ compliance to the published voluntary standard. This meant that the distributor had to meet the quality standard (ASA-100, ISO9001, AS9100, AS9110 or AS9120) and also all of the elements of AC )0-56.

Since the inspection of the program, the FAA has audited ASA to gauge the success of the program.  FAA program audits have confirmed that this AC 00-56B program reflects a sound safety program that makes a positive contribution to aviation safety. The AC 00-56 Program has become an important tool to assist the FAA in ensuring aviation safety.

AC 00-56 has become a globally recognized program. There are AC 00-56 accredited distributors on every continent except Antarctica. The European Union has promulgated laws requiring Part 145 certificate holders to have procedures for accepting components. EASA 145.A.42(b)(i). EASA has interpreted this to mean that 145 organizations must evaluate their suppliers (EASA AMC1 145.A.42(b)(i) Components, ¶ (b)). AC 00-56 (and ASA-100) has been recognized as an acceptable program for supplier evaluation under European supplier control laws (EASA GM3 145.A.42(b)(i) Components, ¶ (b)(4)).  ASA has been in talks with other civil aviation authorities around the world to encourage them to adopt similar provisions recognizing the value of distributor accreditation.

AC 00-56B Requires Onsite Auditing

One of the features of the AC 00-56B program is onsite auditing of the Distributors. AC 00-56B requires onsite audits in section eight, paragraphs (b) and (f). The onsite audits are performed by qualified auditors who meet the requirements of AC 00-56B, under the coordination of Accreditation Organizations recognized in AC 00-56B.

On March 13, 2020, President Trump issued a Proclamation on Declaring a National Emergency Concerning the Novel Coronavirus Outbreak. The Proclamation recognized that “[t]he spread of COVID-19 within our Nation’s communities threatens to strain our Nation’s healthcare systems.” Since that date, many United States governors and mayors have issued correlative orders: restricting travel and requiring people to remain in their residences. Covid-19 has affected the availability and advisability of travel.

Health concerns related to Covid-19 are making onsite auditing under AC 00-56B an unnecessary risk.  Travel restrictions and state “stay-at-home” orders are making it impractical to perform onsite auditing under AC 00-56B.  Remote auditing mitigates the risks posed by onsite auditing, while providing a practical response to the need to “stay-at-home” to reduce disease transmission.

While remote auditing seems like the right response, it is still not permitted under AC 00-56B.  Thus, the industry needed a formal FAA deviation or exemption that permitted remote auditing.  ASA discussed with the FAA issuing a Notice to permit industry-wide remote auditing under AC 00-56B, but the FAA was uncomfortable with this because of the need for procedures that would ensure remote auditing was successful.  ASA petitioned the FAA to permit ASA to perform remote audits, based upon ASA’s remote auditing process and remote auditing auditor training program.

Remote Auditing the Right Way

The FAA authority is subject to ASA’s internal procedures for remote auditing, which have been developed by the audit team to help ensure an equivalent level of safety assurance. These procedures include new techniques for investigation by the audit team, and identification of objective evidence of adequate compliance.

ASA has already performed auditor training to teach the audit team how to perform remote auditing successfully.  Additional staff training is now planned for the approved procedures.

The current ASA authorization from the FAA for remote auditing is valid from April 1, 2020 through December 31, 2020.  The scope is global, so that ASA can continue to provide services to clients everywhere in the world.

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