Wednesday, October 1, 2008
The R is Silent
Being a New Yorker by birth, I am intrigued by the way others speak. Just within a few miles of my old neighborhood one can encounter a cornucopia of dialects. I also defer to my adopted city of Boston, where there are only 25 letters in the alphabet, because the R is silent (except when saying Red Sox).
I mention this bit of trivia to assist in answering the upcoming question. Next year the Organizational Designated Airworthiness Representative (ODAR) is being replaced by the Organization Designation Authorization (ODA). So, what is the difference between an ODAR and an ODA? Answer: The letter R. Well, yes and no; but mostly no.
Since 1927, the federal government has implemented representatives from the private sector to inspect and examine aircraft as part of an aviation safety management organization. The forerunner of the FAA, the Civil Aeronautics Administration, authorized designees for airworthiness, airman or certification ratification as part of a program; this was expanded in the 1950s with the Delegation Option Authorization (DOA). In the 1980s, the FAA brought about the ODAR program, as well as the Designated Airworthiness Representative (DAR) program.
According to FAA Order 8100.15, November 14, 2009, the ODAR, along with the DOA, the Delegated Authorization Station (DAS), and any authorization for an operator or repair station under Special Federal Aviation Regulation 36 (SFAR 36) will cease to exist, replaced by the ODA. On August 6, 2006, FAA Order 8100.15 was published to prepare the industry for the requirements and changes that are to occur when the ODA start-up date arrives; the order advises Aircraft Certification and Flight Standards Services personnel managing these delegated associations. The ODA rules have been spelled out in 14 CFR Part 183, subpart D; these rules, however, do not have an influence upon individual designees referenced in subparts A through C, e.g., the DAR.
Now it is obvious that more than the letter R is different; there are the four aforementioned groups that are to become ODA. Each type of ODA is made up of ODA holders and ODA units. The ODA holder, quite simply, is the organization which the FAA grants the ODA to. Examples of organization types are repair stations, aircraft operators and/or consultant groups. The administrator for the ODA holder is the manager of the group.
The ODA unit is a group of at least two qualified individuals within the ODA holder that execute the authorized tasks; these persons are referred to as "unit members." These individuals must meet the competency to perform their jobs per FAA Order 8100.8.
One minor evolution involves the wording of the title each ODA organization member receives: "unit member," which replaces "authorized representative." Reason: each ODA organization’s individual is not the representative and shouldn’t be mistakenly identified with the organization, which is the actual representative.
Not every ODA organization can be eligible for each ODA type; they must be sorted according to their granted function. The types of ODA programs created by Order 8100.15 are:
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Type Certification (TC ODA)
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Production Certification (PC ODA)
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Supplemental Type Certification (STC ODA)
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Technical Standard Order Authorization (TSOA ODA)
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Major Repair, Alteration, and Airworthiness (MRA ODA)
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Parts Manufacturer Approval (PMA ODA)
An organization may apply for more than one ODA type for which it is certified.
The folks in headquarters have been coordinating efforts to meet the deadline of 11/14/2009. Our guidance, the 8900.1, was updated last March to incorporate policies for inspectors to conduct surveillance and assure that procedures for the issuance, renewal, and amending of an ODA are in place. Training has been stepped up to cycle through FAA inspectors who are or will be advisors for the ODA organizations so there are no "skips-in-the-record" when 11/14/2009 rolls around.
Now I think I have made it clear that 11/14/2009 is the start date. There is no grandfather clause; the transitions from ODAR, DAS, DOA, and SFAR 36 to ODA are not automatic. Each existing delegation transitioning to an ODA before 11/14/2009, to prevent a lapse in your authorization you should have applied for your ODA before May 2008 — that’s right, May 2008. To facilitate the transition, the FAA had begun accepting applications for ODA on November 14, 2006. For those I pointed to in my last article when I spoke of they who procrastinate when renewing their designation, if you have not already applied for the ODA, it would be in your best interest to pursue it real soon, before the rush.
For everyone looking to acquire your ODA, when you’se guys (oops, wrong accent) when you get to w-ahk, and p-ahk the c-ah, then get busy on that application. Because there is only one thing more silent than a letter R when speaking Boston-ese... that’s the phone on your desk without your ODA.

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