Little Wolf Consulting, LLC
Aerospace manufacturing management system and regulatory compliance consulting.
Part 5 Safety Management Systems (NAS9927), Part 21 Production Holder and supplier management, Order 8100.15 ODA Procedures and Part 145 Maintenance and Repair Organizations.
Lead the Pack with Little Wolf Consulting.
My mission is to use my knowledge and experience to improve organizational performance, so my clients become or maintain a commanding market position.
Biography
John Whalen is the principal and owner of Little Wolf Consulting, LLC, which provides clients with mentorship and support regarding global aviation regulations and manufacturing management systems, including safety management systems. He has over 45 years of aerospace manufacturing and maintenance organization experience including Parts 5 (Safety Management Systems), 21 (Certification Procedures), and 145 (Repair Stations). Prior to retiring and starting the consulting practice, John was a Senior Technical Fellow at Collins Aerospace where he was a subject matter expert in process quality and global regulatory compliance. John was also the ODA Administrator for Hamilton Sundstrand, where he led the ODA Unit Members within the unit and provided support to the other ODA organizations within Collins Aerospace.
CONTACT
PROFESSIONAL ASSOCIATIONS
Please call or write to me at: whalenjohn04@gmail.com
Mobile (860) 357-0565 WhatsApp 860 357-0565
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6/3/2026
The FAA has issued revision B to Order 8120.23, Certificate Management of Production Approval Holders. Among other changes the Order now includes Safety Management System (SMS) compliance audits and their applicability to oversight of a PAH with a required or voluntary SMS (VSMS). https://lnkd.in/e9sYWHQE
The FAA has released revision C to FAA Order 8100.15, ODA Procedures. This update contains a significant number of revisions as it incorporates multiple previously issued policy, deviation, and general memos. If you manage or belong to an ODA, this is an important revision to understand.
EASA is reporting a major unapproved parts incident and risk to the aviation component supply chain. Spain’s National Aviation Authority informed EASA that a consignment of formally declared non-airworthy turbofan parts was rerouted in late January 2026 from its destination. The parts were not rendered unairworthy by the contracted mutilation provider.
https://lnkd.in/eU6ZQtVW elq2=1e9211e0a28641faa112/23/2025
In November. the FAA amended the falsification regulations (21.2 for example) previously located throughout title 14 of the Code of Federal Regulations. In chapter I, this rule eliminates inconsistencies among the various falsification regulations and associated sanctions; consolidates all existing falsification regulations into one part under 14 CFR chapter I to standardize the existing falsification regulations; and ensures that falsification-related conduct not addressed by pertinent current regulations is covered. The final rule removes the existing falsification regulations from multiple parts, except part 3, and consolidates them in a new subpart in part 3.1. https://lnkd.in/eQV_tmwx
10/7/2025
Safety Management System compliance is 3 days away for maintenance organizations with EASA approval. The U.S./EU bilateral MAG change 10 becomes effective Oct 10th. Some guidance is available in AC120-92D. Statements of compliance or commitment are due by the 10th. Contact me with questions or concerns. https://lnkd.in/eNYXUmtn
The FAA has updated Order 8100.15 with revision C effective 10/1/2025. This is a rather extensive revision and update. Some new requirements or procedure revisions include requirements for internal audit and corrective action programs, PMA test and computation procedures to be consistent with STC procedures and codified the requirement for ODA OMT approval of new unit members. https://lnkd.in/ded-GusR
9/20/2025:
eVTOL programs and regulatory efforts continue to evolve. This is exciting.
How local and state officials can participate in developing the framework and regulations for implementing eVTOL operations was published in the Federal Register. Comments in response to the publication are due 12/11/2025. A link to the register is provided here: https://www.federalregister.gov/documents/2025/09/16/2025-17844/electric-vertical-takeoff-and-landing-and-advanced-air-mobility-integration-pilot
The FAA has circulated for public comment Draft Advisory Circular (AC) 33-13, “Sample Size Considerations for Comparative Test and Analysis for Turbine Aircraft Engine and APU, PMA, and Third-Party Repair Parts.” This draft describes two approaches to define minimum sample sizes of products and articles for turbine aircraft engines and auxiliary power units that applicants for a parts manufacturer approval may use to show compliance with the test reports and computations requirements of 14 CFR § 21.303(a)(4). It appears to me the requirements of the AC go beyond the necessity especially for directly measurable features. Comments on the draft AC are due on Sept. 12, so please make your voice heard by then. Attached is a link to the draft AC and its comments matrix. https://lnkd.in/e8S2awsr
The FAA is taking regulatory action after discovering some Boeing 787 Dreamliner ram air turbine (RAT) fittings may have been manufactured using unapproved and potentially inferior titanium. In a notice of proposed rulemaking issued on July 28, airlines would inspect specific RAT fittings on nine affected Boeing 787 aircraft including both 787-9 and 787-10 variants. Comments on this pending airworthiness directive will be received until 9.11.2025. Federal Register :: Airworthiness Directives; The Boeing Company Airplanes
The FAA issued a Just-in-Time document related to SMS (Revision 0, dated July 28, 2025). It is meant to assist in communicating additional SMS related information to aviation organizations with an interest in FAA Data Collection Tools. This document is intended to be informational in nature and does not supersede federal aviation regulations nor FAA policies. You can find the document here: https://lnkd.in/eBMkWkPj
The FAA has revised InFO 24007 on 7/8/25. It serves as notice to Part 145 repair stations located in the U.S. seeking initial approval, and existing EASA part 145 certificate holders about the requirement to implement a new Special Condition: SMS. A copy of the Information for Operators is here:
https://lnkd.in/eKdR2QnTThe FAA has issued Change 2 to Order 8120.23A - Certificate Management of Production Approval Holders. The order was effective on June 6, 2025.
A summary is on the Part 21 section of my web site here. The Order can be found here: https://lnkd.in/eyXRFHg86/23/2025
Change 10 to the Maintenance Annex Guidance between the FAA and EASA, has been issued and is effective Oct 10, 2025. As expected, the change includes a requirement for U.S.-based repair stations holding EASA approval to implement a safety management system (SMS).
Contact me for a discussion of the implemented changes.
US-EU Safety Agreement - Maintenance Annex Guidance (MAG) | Federal Aviation Administration
Change 10 to the Maintenance Annex Guidance between the FAA and EASA, has been issued and is effective Oct 10, 2025. As expected, the change includes a requirement for U.S.-based repair stations holding EASA approval to implement a safety management system (SMS). Contact me for a discussion of the implemented changes.
US-EU Safety Agreement - Maintenance Annex Guidance (MAG) | Federal Aviation Administration
The Technical Implementation Procedures (TIPs) for Airworthiness and Environmental Certification – Revision 7 between the US and the EU has been published with an effective date of November 18, 2023. A copy of the TIP and one with highlighted changes can be found here: https://lnkd.in/d9RXnuwi
The FAA has issued notice N 8900.737 which provides interim guidance related to the amendments tov 14 CFR Part 5, Safety Management Systems, effective May 28, 2024. The amendments to part 5 are applicable to existing and new applicants for 14 CFR part 121; part 135; and part 91, § 91.147 commercial air tour operations. The notice is effective for one year https://lnkd.in/eZxQ-qQ9
6/6/2025:
While the FAA is comfortable renewing Boeing’s ODA, that confidence apparently does not extend to production operations. https://lnkd.in/dfGH-Uuw5/21/2025
Important information for an airman receiving a Letter of Investigation (LOI) from the FAA. Responses are now due within 30 days as opposed to the original 10-day requirement. This notice applies only to individual airmen for whom the PBR is relevant. Read the notice in detail to understand its application. https://lnkd.in/e3XiYbpQ
The U.S.-European Union (EU) bilateral aviation safety agreement (BASA) saw an update with Decision No. 13 on Feb 10th. This decision modifies Annex 2, mandating U.S.-based repair stations holding European Union Aviation Safety Agency (EASA) approval to institute, execute, and uphold a Safety Management System (SMS). For further details, the amended BASA document can be accessed at: https://lnkd.in/etMR9BpV.
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Safety Management Systems
In safety management if an incident can happen, it is only a matter of time until it does happen. Taking action to address the potential incident is at the heart of safety management.
10/7/2025
Safety Management System compliance is 3 days away for maintenance organizations with EASA approval. The U.S./EU bilateral MAG change 10 becomes effective Oct 10th. Some guidance is available in AC120-92D. Statements of compliance or commitment are due by the 10th. Contact me with questions or concerns. https://lnkd.in/eNYXUmtn
9/22/2025
On Sep 19th, the FAA cancelled Notice 8900.737 - Interim Guidance Based on the Amendments to Title 14 of the Code of Federal Regulations Part 5. Notice 8900.737 - Interim Guidance Based on the Amendments to Title 14 of the Code of Federal Regulations Part 5 (Cancelled)
The FAA issued a Just-in-Time document related to SMS (Revision 0, dated July 28, 2025). It is meant to assist in communicating additional SMS related information to aviation organizations with an interest in FAA Data Collection Tools. This document is intended to be informational in nature and does not supersede federal aviation regulations nor FAA policies. You can find the document here: https://lnkd.in/eBMkWkPj
7/8/2025
The FAA has revised InFO 24007 on 7/8/25. It serves as notice to Part 145 repair stations located in the U.S. seeking initial approval, and existing EASA part 145 certificate holders about the requirement to implement a new Special Condition: SMS. A copy of the Information for Operators is here:
https://lnkd.in/eKdR2QnTMAG Section B: Appendix 1, Paragraph 20.0] Safety Management System (SMS). Repair stations must establish, implement, and maintain an SMS to hold EASA approval. Implementation of the FAA SMS voluntary program, which meets 14 CFR part 5 requirements, is the minimum expectation that repair stations must maintain for compliance with an SMS that is acceptable to EASA. An SMS must be integrated into the repair station’s processes and procedures that support the EASA special conditions and daily operations of the repair station. The SMS must, at a minimum, include the requirements outlined in the SMSVP. The SMS declaration must be submitted with the EASA application. The SMS must be appropriate to the size, scope, and complexity of the repair station’s operations. The following must be integrated into the SMS, Subparts A-F of the SMSVP:
a. Applicability-subpart A
b. Safety Policy-subpart B
c. Safety Risk Management-subpart
d. Safety Assurance-subpart D
e. Safety Promotion-subpart E
f. Maintained in accordance with the recordkeeping requirements-subpart F
g. Ensure compliance with the EASA special conditions and 14 CFR parts 43 and 145June 23, 2025
Change 10 to the Maintenance Annex Guidance between the FAA and EASA, has been issued and is effective Oct 10, 2025. As expected, the change includes a requirement for U.S.-based repair stations holding EASA approval to implement a safety management system (SMS). Please read more in my sites section Part 5 SMS.
Contact me for a discussion of the implemented changes.
US-EU Safety Agreement - Maintenance Annex Guidance (MAG) | Federal Aviation Administration
May 2025: This is a good interview of Acting FAA Administrator Chris Rocheleau. I believe the fact he had a part in helping write the general aviation section of the FAA reauthorization will be a benefit to executing the reauthorization legislation. https://lnkd.in/e_hRthWu
Regulatory Updates:
June 10, 2025:
The FAA has issued notice N 8900.737 which provides interim guidance related to the amendments tov 14 CFR Part 5, Safety Management Systems, effective May 28, 2024. The amendments to part 5 are applicable to existing and new applicants for 14 CFR part 121; part 135; and part 91, § 91.147 commercial air tour operations. The notice is effective for one year. https://lnkd.in/eZxQ-qQ9
NOTE: this guidance was cancelled by the FAA on 9/19/2025.
2/26/2025
The U.S.-European Union (EU) bilateral aviation safety agreement (BASA) saw an update with Decision No. 13 on Feb 10th. This decision modifies Annex 2, mandating U.S.-based repair stations holding European Union Aviation Safety Agency (EASA) approval to institute, execute, and uphold a Safety Management System (SMS). For further details, the amended BASA document can be accessed at: https://lnkd.in/etMR9BpV.
The FAA in its InFO24007 stated the US and the EU have agreed to establish a special condition as part of the Safety Agreement Annex 2. "The FAA Voluntary SMS Program is deemed acceptable as a means to comply with the new requirement." To date, the special conditions have not yet been amended to reflect this agreement.
6/28/2024
In June the FAA issued InFO24007 outlining the SMS requirements for US repair stations holding EASA certification. As I previously mentioned, this means US repair stations must submit their safety management system to the FAA under their voluntary participation program. A link to the InFO can be found here: https://www.faa.gov/other_visit/aviation_industry/airline_operators/airline_safety/info/all_infos/InFO24007.pdf
4/26/24
The FAA published its final rule on SMS excluding Part 145 organizations. Some of the changes from the NPRM are:
• Part 5 does not apply to either a supplemental type certificate (STC) holder or a PC holder for an STC, or PC holders that only produce parts or articles.
• Foreign holders of a validated TC issued under § 21.29 are now excluded.
• The proposed revision to the definition of “hazard” is partially adopted. The terms “incidents” and “objects” are incorporated as proposed, but the proposal to replace the term “foreseeably” with “potential to” is not adopted. The new definition is: “Hazard means a condition or an object that could foreseeably cause or contribute to an incident or aircraft accident, as defined in 49 CFR 830.2.”
• For existing part 21 certificate holders, the deadline for submission of SMS implementation plans is changed from December 27, 2024, to no later than 6 months after the final rule's effective date.
• The term “interfacing persons” is now clarified to be “those who contribute to the safety” of a covered organization's “aviation-related products and services.”
• The FAA is updating § 5.97(d) in order to reference the new § 5.57, but the amendment is otherwise adopted as proposed. Section 5.97(d) now requires covered aviation organizations to retain records of all communications involving the notification of hazards to interfacing persons, as required by § 5.57, for a minimum of 24 consecutive months.
• The FAA disagrees that the inclusion of the word “incident” in the definition expands the scope of “hazard.” The final rule changes to the definition, notably the addition of “incident,” do not result in a substantial expansion in the scope of hazards that a covered person needs to address.
• The term “incident” is defined in 49 CFR 830.2 (as is “aircraft accident”). As defined, “incident” means “an occurrence other than an accident, associated with the operation of an aircraft, which affects or could affect the safety of operations.”
• The accountable executive responsibilities and roles cannot be delegated to a contractor. An aviation organization may choose to use third-party providers and other industry resources to assist and support SMS integration and development, as appropriate, but that aviation organization remains fully responsible for regulatory compliance.
• The FAA asserts that aviation organizations having an SMS that is certified, approved, or accepted by another entity or through the FAA's voluntary SMS programs does not replace the mandate to meet all applicable part 5 requirements. Companies are nonetheless encouraged to leverage existing processes and procedures to help meet part 5 requirements.
Summary:
In 2018, the International Civil Aviation Organization (ICAO), adopted Safety Management Standards (SMS) and Recommended Practices (Annex 19) an industry consensus standard. The standard is recognized by the FAA (US), EASA (Europe), TCCA (Canada) and ANAC (Brazil) for voluntary adoption pending the addition of the standard in their regulations.
In April 2022 the Aerospace and Defense Industries Association of Europe (ASD), Aerospace Industries Association of America (AIA), Aerospace Industries Association of Brazil (AIAB), Aerospace Industries Association of Canada (AIAC) and the General Aviation Manufacturers Association (GAMA), published an update (issue B) to its previously published international industry standard: SM-0001 - “Implementing a Safety Management System in Design, Manufacturing and Maintenance organizations”.
SMS is the formal, top-down business-like approach to managing safety risk, which includes a systemic approach to managing safety, including the necessary organizational structures, accountabilities, policies and procedures. (Order VS 8000.367)
SMS for Design and Manufacturing Organizations
The Aircraft Certification Service (AIR) launched a Part 21/SMS Rulemaking Project in September 2014. This effort was led by the Policy and Innovation Division's System Performance and Development Branch (AIR-6E0). The Part 21/SMS Rulemaking project incorporates the ICAO Annex 19 requirement, which requires that design and production approval holders, for a product, have an SMS.
In addition to the Part 21/SMS Rulemaking Project, National Aerospace Standard NAS 9927, Safety Management Systems and Practices for Design and Manufacturing, was developed by the Aerospace Industries Association (AIA) and General Aviation Manufacturers Association (GAMA). The FAA has recognized NAS 9927 as meeting the intent of Annex 19 and 14 CFR Part 5.
The FAA has established a Voluntary SMS Program that allows the FAA to assess applicant voluntary SMS programs in accordance with the Standard or 14 CFR Part 5. NAS9927 is intended to enable United States (US) aviation design and manufacturing (D&M) organizations to voluntarily implement a SMS that is consistent with 14 CFR part 5, Safety Management Systems. For a voluntary SMS to be accepted by the FAA, the respective organization must demonstrate that the SMS satisfies the intent of part 5 in all important respects. Upon acceptance of an SMS program, AIR awards a letter stating the participating company has a SMS Program accepted by the FAA.
The FAA accepts NAS9927 as a basis for SMS recognition and will develop policy that will allow for an assessment of the processes and procedures of a Design and/or Manufacturers voluntary implementation of an SMS per Section 1 of the NAS9927.
SMS for maintenance organizations
Maintenance organizations certificated by the FAA do not yet have a mandatory requirement to implement a safety management system. However, a future (not yet drafted) revision to the Maintenance Annex Guidance (MAG) for the FAA-EASA bilateral will extend the requirement to U.S. repair stations with EASA approval. Organizations are encouraged to voluntarily participate and implement a program with FAA acceptance.
Effective Dec. 2, 2024, all EASA Part-145 approved maintenance organizations (i.e., those with certificates directly from EASA, not via a bilateral) must have implemented an SMS program.
A SMS program includes:
(1) Safety policy and objectives
• Management commitment and responsibility.
• Safety accountabilities.
• Appointment of key safety personnel.
• Coordination of emergency response planning.
• SMS documentation.
(2) Safety risk management
• Hazard identification.
• Safety risk assessment and mitigation.
(3) Safety assurance
• Safety performance monitoring and measurement.
• The management of change.
• Continuous improvement of the SMS.
(4) Safety promotion
• Training and education.
• Safety communication.
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Summary of regulatory activity and news.
6/3/2026
The FAA has issued revision B to Order 8120.23, Certificate Management of Production Approval Holders. Among other changes the Order now includes Safety Management System (SMS) compliance audits and their applicability to oversight of a PAH with a required or voluntary SMS (VSMS). https://lnkd.in/e9sYWHQE
4/6/2026
The FAA has released revision C to FAA Order 8100.15, ODA Procedures. This update contains a significant number of revisions as it incorporates multiple previously issued policy, deviation, and general memos. If you manage or belong to an ODA, this is an important revision to understand.
2/23/2025
In November. the FAA amended the falsification regulations (21.2 for example) previously located throughout title 14 of the Code of Federal Regulations. In chapter I, this rule eliminates inconsistencies among the various falsification regulations and associated sanctions; consolidates all existing falsification regulations into one part under 14 CFR chapter I to standardize the existing falsification regulations; and ensures that falsification-related conduct not addressed by pertinent current regulations is covered. The final rule removes the existing falsification regulations from multiple parts, except part 3, and consolidates them in a new subpart in part 3.1. https://lnkd.in/eQV_tmwx
10/4/2025
The FAA has updated Order 8100.15 with revision C effective 10/1/2025. This is a rather extensive revision and update. Some new requirements or procedure revisions include requirements for internal audit and corrective action programs, PMA test and computation procedures to be consistent with STC procedures and codified the requirement for ODA OMT approval of new unit members. https://lnkd.in/ded-GusR
8/11/25
The FAA has circulated for public comment Draft Advisory Circular (AC) 33-13, “Sample Size Considerations for Comparative Test and Analysis for Turbine Aircraft Engine and APU, PMA, and Third-Party Repair Parts.” This draft describes two approaches to define minimum sample sizes of products and articles for turbine aircraft engines and auxiliary power units that applicants for a parts manufacturer approval may use to show compliance with the test reports and computations requirements of 14 CFR § 21.303(a)(4). It appears to me the requirements of the AC go beyond the necessity especially for directly measurable features. Comments on the draft AC are due on Sept. 12, so please make your voice heard by then. Attached is a link to the draft AC and its comments matrix. https://lnkd.in/e8S2awsr
6/24/2025
The FAA has issued Change 2 to Order 8120.23A - Certificate Management of Production Approval Holders. The order was effective on June 6, 2025.
A summary will be posted shortly. The Order can be found here: https://lnkd.in/eyXRFHg86/18/2025
The Technical Implementation Procedures (TIPs) for Airworthiness and Environmental Certification – Revision 7 between the US and the EU has been published with an effective date of November 18, 2023. A copy of the TIP and one with highlighted changes can be found here: https://lnkd.in/d9RXnuwi
While the FAA is comfortable renewing Boeing’s ODA, that confidence apparently does not extend to production operations. https://lnkd.in/dfGH-Uuw
May 29, 2025
The FAA announced it will renew Boeing’s Organization Designation Authorization (ODA) for three years effective June 1. This is good news for Boeing and the FAA. Boeing can use its ODA Unit Members to conduct inspections, and the FAA can begin to redirect it staff to other oversight tasks. https://lnkd.in/e5ghyDXp
March 19, 2025
The FAA issued draft Order 8130.21J, “Completion of FAA Form 8130-3 under Part 21.” If you or your organization has not yet read and commented on this draft, this is of the essence. The comment period is only open for 33 days. https://lnkd.in/d9m2UQsf
Summary
Many people within the aerospace community do not realize the FAA, and other national airworthiness authorities, govern how organizations involved in the production of products and articles for use in commercial aircraft. This is a overview of the FAA regulations. Keep in mind other aviation authorities have similar regulations.
The Code of Federal Regulations Title 14, Aeronautics and Space are acts of Congress and are therefore legally binding and subject to enforcement under CFR § 21.2.
14 CFR Part 21, Certification Procedures for Products and Articles, prescribes the procedural requirements for issuing and changing design approvals; production approvals; airworthiness certificates; and airworthiness approvals. Part 21 also specifies the rules governing applicants for, and holders of, any approval or certificate specified in paragraph (a)(1) of this section, and the procedural requirements for the approval of articles.
The design of Products, which are defined as aircraft, engines and propellers, and articles defined as a material, part, component, process, or appliance must meet the FAA airworthiness standards. Finished products and articles must conform to the approved design and be in a condition for safe operation. The FAA approves the quality management system for organizations holding design approvals (Type Certificate, Supplemental Type Certificate, Technical Standard Order, and Part Manufacturing Approval) and those holding production approvals (Production Certificate, Technical Standard Order, and Part Manufacturing Approval). When an organization discovers malfunctions or defects in their product or article, they must report it to the FAA. The FAA can mandate design changes to correct unsafe conditions.
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10/7/2025
Safety Management System compliance is 3 days away for maintenance organizations with EASA approval. The U.S./EU bilateral MAG change 10 becomes effective Oct 10th. Some guidance is available in AC120-92D. Statements of compliance or commitment are due by the 10th. Contact me with questions or concerns. https://lnkd.in/eNYXUmtn
7/8/2025
The FAA has revised InFO 24007 on 7/8/25. It serves as notice to Part 145 repair stations located in the U.S. seeking initial approval, and existing EASA part 145 certificate holders about the requirement to implement a new Special Condition: SMS. A copy of the Information for Operators is here:
https://lnkd.in/eKdR2QnTChange 10 to the Maintenance Annex Guidance between the FAA and EASA, has been issued and is effective Oct 10, 2025. As expected, the change includes a requirement for U.S.-based repair stations holding EASA approval to implement a safety management system (SMS).
Contact me for a discussion of all the implemented changes.
Section B: Appendix 1, Paragraph 20.0] Safety Management System (SMS). Repair stations must establish, implement, and maintain an SMS to hold EASA approval. Implementation of the FAA SMS voluntary program, which meets 14 CFR part 5 requirements, is the minimum expectation that repair stations must maintain for compliance with an SMS that is acceptable to EASA. An SMS must be integrated into the repair station’s processes and procedures that support the EASA special conditions and daily operations of the repair station. The SMS must, at a minimum, include the requirements outlined in the SMSVP. The SMS declaration must be submitted with the EASA application. The SMS must be appropriate to the size, scope, and complexity of the repair station’s operations. The following must be integrated into the SMS, Subparts A-F of the SMSVP:
a. Applicability-subpart A
b. Safety Policy-subpart B
c. Safety Risk Management-subpart C
d. Safety Assurance-subpart D
e. Safety Promotion-subpart E
f. Maintained in accordance with the recordkeeping requirements-subpart F
g. Ensure compliance with the EASA special conditions and 14 CFR parts 43 and 145US-EU Safety Agreement - Maintenance Annex Guidance (MAG) | Federal Aviation Administration
The U.S.-European Union (EU) bilateral aviation safety agreement (BASA) saw an update with Decision No. 13 on Feb 10th. This decision modifies Annex 2, mandating U.S.-based repair stations holding European Union Aviation Safety Agency (EASA) approval to institute, execute, and uphold a Safety Management System (SMS). For further details, the amended BASA document can be accessed at: https://lnkd.in/etMR9BpV.
12/18/2024
As I previously shared, the FAA issued its final rule requiring foreign repair stations to comply with the requirements of the FAA's Drug and Alcohol Testing Program. A review of the rule does allow foreign governments and individual foreign repair stations subject to the rule to obtain FAA recognition of a compatible alternative. See the attached Aviation Week article for their reporting on this. This unilateral approach, required by Congress, is detrimental to existing bilateral agreements.https://aviationweek.com/mro/safety-ops-regulation/faa-expands-drug-alcohol-testing-non-us-shops
12/16/2024
Today, the FAA issued its final rule requiring certificated repair stations located outside the U.S. to conduct alcohol and controlled substance testing on employees performing safety-sensitive maintenance functions on certain air carrier aircraft. The document is scheduled to be published on 12/18/2024 but you can find an unpublished copy here: www.federalregister.gov/public-inspection/2024-29837/drug-and-alcohol-testing-of-certificated-repair-station-employees-located-outside-of-the-united
11/27/2024
If your repair station needs to hold a UK Civil Aviation Authority approval to perform maintenance you need to act immediately. On Dec. 31, 2024, the UK CAA will no longer recognize EASA approvals held by U.S. repair stations. To begin the application process for approval under the U.S./UK bilateral use this link:
Apply for a Part 145 Approval based on a FAR 145 Repair Station Certificatecaa.co.uk
11/21/2024
Maintenance organizations outside the US need to engage with the White House Office of Information and Regulatory Affairs (OIRA) as it reviews the FAA’s final rule regarding expanding drug & alcohol testing requirements to repair stations located outside the United States. Don't wait for the final rule to be published. See the notice in the Federal Register here: www.federalregister.gov/documents/2023/12/07/2023-26394/drug-and-alcohol-testing-of-certificated-repair-station-employees-located-outside-of-the-united
11/4/24:
The FAA has rescinded its legal interpretation that would have required directly supervising aircraft maintenances activities to observe the work performed by apprentices.
10/15/24
The FAA issued a stay of its interpretation of 14 CFR § 43.3(d) dated September 3, 2024, that concluded remote supervision of maintenance activities is not allowed. GAMA, ARSA and Savvy Aviation, Inc. had petitioned the FAA to reconsider their decision which resulted in this stay.
7/16/24:
The FAA in its InFO24007 stated the US and the EU have agreed to establish a special condition as part of the Safety Agreement Annex 2. "The FAA Voluntary SMS Program is deemed acceptable as a means to comply with the new requirement." To date, the special conditions have not yet been amended to reflect this agreement.
6/28/2024
In June the FAA issued InFO24007 outlining the SMS requirements for US repair stations holding EASA certification. As I previously mentioned, this means US repair stations must submit their safety management system to the FAA under their voluntary participation program. A link to the InFO can be found here: https://www.faa.gov/other_visit/aviation_industry/airline_operators/airline_safety/info/all_infos/InFO24007.pdf
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3/28/2026
EASA is reporting a major unapproved parts incident and risk to the aviation component supply chain. Spain’s National Aviation Authority informed EASA that a consignment of formally declared non-airworthy turbofan parts was rerouted in late January 2026 from its destination. The parts were not rendered unairworthy by the contracted mutilation provider.
https://lnkd.in/eU6ZQtVW elq2=1e9211e0a28641faa18/4/25
The FAA is taking regulatory action after discovering some Boeing 787 Dreamliner ram air turbine (RAT) fittings may have been manufactured using unapproved and potentially inferior titanium. In a notice of proposed rulemaking issued on July 28, airlines would inspect specific RAT fittings on nine affected Boeing 787 aircraft including both 787-9 and 787-10 variants. Comments on this pending airworthiness directive will be received until 9.11.2025. Federal Register :: Airworthiness Directives; The Boeing Company Airplanes
6/5/2025
Two new unapproved part notifications have been issued by the FAA.
2025_AAE_EHL_20240711_558 concerns wired conduit assemblies manufactured and sold by Joslyn Sunbank, LLC and 2025_AAE_EHL_20240823_471 concerns Lavatory refresh modification kits manufactured and sold by Safran Cabin, Inc. Here is a link to the FAA SUPs listing: https://lnkd.in/d9URZ_wh6/4/2025:
This article discusses the continuing fall out of the SUPs investigation of AOG Technics. It is good to see the follow through and serious legal ramifications of persons taking such unethical action in our industry. https://lnkd.in/e3Z8KwNQ
5/21/2025
The FAA has proposed mandating Boeing-recommended inspections of about 100 787-9s and -10s for fuselage fittings that may be constructed from the wrong grade of titanium. https://lnkd.in/evUcSxH8
Almost anything can be counterfeited these days. The accidental or intentional acquisition or manufacture of counterfeit parts directly opposes the industry’s safety objectives. Counterfeit parts compromise entire systems and can impact flight safety which threatens lives. The globalization of the aerospace industry complicates the objective of mitigating counterfeit parts.
There is a difference between having a suspected part and an actual counterfeit part. Just because a part is deemed suspect doesn’t mean it is counterfeit. An approved part is a material, part, component, that has been produced in accordance with regulatory requirements. A suspect part may be unintentionally nonconforming to the certified design requirements. Think of a product quality escape where manufacturing created a nonconforming characteristic that was not captured by the quality system. All counterfeit parts are intended to represent compliance with approved part design but are sold with the knowledge they are not approved. Think of parts bought as scrap and refurbished to appear airworthy.
FAA Order 8120.16 describes the FAA’s Suspect Unapproved Parts program.
There are many other industry standards and publication which address this issue.
SAE AS 5553D-2022: Counterfeit Electrical, Electronic, And Electromechanical (EEE) Parts; Avoidance, Detection, Mitigation, And Disposition was created to help avoid, detect, mitigate, and dispose of counterfeit parts. The standard outlines a counterfeit EEE parts control plan, and it also details personnel training, EEE parts availability, the purchasing process, purchasing information, and the verification of purchased EEE parts.
AS9100 is an internationally recognized Quality Management System (QMS) standard for the aerospace industry. It was developed to ensure that companies adhere to stringent, consistent requirements, thus ensuring safety and reliability in the aerospace industry. One of the critical requirements is the prevention of counterfeit parts, as detailed in clause 8.1.4. This clause is particularly relevant for quality assurance managers who are tasked with ensuring the authenticity and quality of parts used in aerospace manufacturing.
AS6081: Fraudulent/Counterfeit Electronic Parts: Avoidance, Detection, Mitigation, and Disposition - Distributors. This standard is designed specifically for organizations (typically AS9120 but can be applied to AS9100) who are not buying direct from the OEMs/OEMs 100% of the time.
Terms and Definitions
The FAA’s general definitions are available in their Dynamic Regulatory System 14 CFR Part 1: Dynamic Regulatory System (faa.gov)
Approved Part. The term “part” is contained in the definition of articles, (“a material, part, component, process, or appliance”) as defined in 14 CFR part 21.1. An approved part may be produced pursuant to § 21.8 or § 21.9 and is not restricted to FAA production approvals (e.g., PMA, TSO). (FAA Order 8120.16).
An Unapproved article is an article not meeting the requirements of an approved or acceptable article. (Order 8110.118).
Counterfeit Part. A type of “unapproved part” made or altered to imitate or resemble an “approved part” without authority or right, and with the intent to mislead or defraud by passing the imitation as original or genuine. Note: Counterfeit parts may be new parts that are deliberately misrepresented as being designed and produced under an approved system or other acceptable method even though they were not so designed and produced. (FAA Order 8120.16).
Commercial Part. Commercial part is defined in 14 CFR 21.1(b)(3). Commercial part is an article (part, component or possibly an appliance depending on the appliance, but not a material or process) that was originally approved through an FAA design approval and is listed on an FAA- approved commercial parts list included in the DAH’s ICA.
Standard Parts conform to established industry-wide or government specifications. These specifications stipulate the design, manufacturing and uniform identification requirements. The specifications are readily available to any persons or organizations who want to produce these articles. (FAA Order 8100.42)