ARSA, AIA, GAMA Support Development of AFS Guidance Methodology
On Oct. 9, ARSA joined the Aerospace Industries Association (AIA) and the General Aviation Manufacturers Association (GAMA) on comments to the Flight Standards Service’s (AFS) Draft Order 8000.AFSGDD, “Flight Standards Service Guidance Document Development.”
The draft follows the recommendations of the Consistency of Regulatory Interpretation Aviation Rulemaking Committee (CRI ARC), on which all three associations participated. The comments applaud the FAA for working to broadly apply standardization principles already employed by the Aircraft Certification Service (AIR) in Order 8100.16.
“The proposed FAA Order 8000.AFSGDD represents an important step in promoting consistency of regulatory interpretations and application,” the comments state. “As stated in the CRI ARC, one of the root causes of inconsistency was inadequate and nonstandard regulatory application. The ARC highlighted that the absence of guidance development instructions for FAA personnel allowed for guidance to be published that was not based [on] or consistent with regulations which contribute to inconsistent application of the rule and confusion.”
To assist with the process, the associations provided suggested clarity in 8000.AFSGDD to ensure that rules and statutes take precedence over guidance material. With careful review for consistency, the final order will be an effective tool for regulators while shaping aviation safety and business practices.
Previously from ARSA...
September 15, 2015
On Sept. 10, the FAA released draft Order FS 8000.AFSGDD, “Flight Standards Service Guidance Document Development,” for comment. The draft order supports the agency’s efforts to provide internally and externally consistent guidance by instructing Flight Standards Service (AFS) personnel.
The document follows the CRI-ARC’s recommendation for ensuring clear and consistent methods for creating and changing guidance and includes tips for agency writers as well as details on when, how and why it should be issued. The information is presented in a straightforward and concise manner and will help regulators while shaping aviation safety and business practices:
Order FS 8000.AFSGDD, Flight Standards Service Guidance Document Development: This order establishes the policy and guidelines for AFS personnel who develop, update, or change AFS directives and advisory circulars (AC). For more information and for instructions on how to comment, visit http://www.faa.gov/aircraft/draft_docs/afs_orders.
The draft is open for 30 days, with comments due on Oct. 9.