(File 5 of 5)
Presenter: Barbara Capron, Production and Airworthiness Division, AIR-200
Narration text: This segment reviews the effective date of the rule, as well as compliance dates, and discusses related Advisory Circulars and Orders.
Effective date of final rule:
Compliance Dates - In the NPRM, the FAA proposed an effective date of 18 months after the date of publication of the final rule in the Federal Register. Upon further review, and in response to comments, we have revised the effective date and compliance dates as follows:
The rule is effective 180 days after publication in the Federal Register;
Compliance date for part 1; part 21, subparts H, I, L, and N; and part 45,
subpart B, §§ 45.11 and 45.13 is 180 days after publication in the Federal Register; and
Compliance date for all other portions of the rule is 18 months after
publication in the Federal Register.
180 Day Compliance Date - In reviewing part 1; part 21, subparts H, I, L, and N; and part 45, subpart B, §§ 45.11 and 45.13, we found the rule changes to be either relieving or cost neutral to industry. We further determined that they are stand-alone changes, and do not affect and are not affected by other changes to the rule. Therefore, we have chosen a compliance date of 180 days after publication of the rule in the Federal Register. During that 180 day period, we will provide necessary guidance and policy to industry on how compliance may be achieved with regard to these portions of the rule.
18 Month Compliance Date - All other portions of the final rule either create a new requirement or are tied to a new requirement and will therefore have a compliance date of 18 months after publication of the rule in the Federal Register. During that 18 month period, we will provide any necessary guidance and policy to the industry on how compliance may be achieved with regard to these portions of the rule.
In order not to run dual rule requirements with two sets of guidance and policy, operating to the rule ahead of the compliance dates will not be allowed. We strongly feel that the 18 month compliance date is necessary for both industry and the FAA in order to prepare for all of the changes put forth in the rule.
We recognize that approximately 1,700 PAHs will need to have their quality systems and manuals reviewed and approved prior to the 18 month compliance date. We have established a process to undertake this task and will provide guidance concerning how the FAA and industry will coordinate the effort within 180 days of publication of the rule.
We further acknowledge that this final rule represents a shift in many of our policies and procedures, and will require training for both industry and the FAA. The process of reviewing and modifying training, orders, and advisory circulars has begun.
Nathan Leonard, Part 21 Course Manager, FAA Academy and Barbara Capron, Production and Airworthiness Division, AIR-200
Presenter: Nathan Leonard, Part 21 Course Manager, FAA Academy