AS9100 & recent amendments to FAA Title 14 (14 CFR)

I wanted to solicit some thoughts and information in regards to the recent amendments to FAA title 14, with a focus on Parts 1, 21, 43, and 45. I have read the rule and preamble and there is a good amount of information to review.

If you are an FAA-PMA or PAH holder, what changes (if any) did you find you needed to make in your quality system to fully comply?

How are you able to show objective evidence of compliance in the event of an FAA audit?

If you found that no changes in your system was necessary, how did you conduct your assessment?


If anyone has a summary of the changes or another form of the sorts, it might serve a use to someone if you post it.

Re: AS9100 & FAA Title 14 (14 CFR)

We are only just beginning to study the changes to Part 21 but it appears that the changes will have relatively little impact on us as our QMS is pretty comprehensive already. Regardless, we will have 18 months to implement any required changes.

Regarding current audits, those would still be done according to the requirements of 8100.7 and 8100.15 (we are an ODA) and those orders have not changed.

We are a PAH and our PI is working with us to understand the changes and what we will be required implement.

Some other suggested reading would include AC's 21-42, 21-43, 21-44 (if you export), and 45-2D.

Re: AS9100 & FAA Title 14 (14 CFR)

The major changes to the regulations include:

Standardization of quality control system requirements for all aviation manufacturers.

Updated export requirements to facilitate global acceptance and documentation of parts.

Standardization of part marking and identification requirements so they align with other countries’ rules, and consolidation of the requirements into one regulation.

Updated and standardized language in the regulations for production approvals, exporting and identification marking.