FAA presents Revision B to Order 8120.23, strengthens audit planning and supplier oversight

An agency official from the Federal Aviation Administration’s Aircraft Certification Service presented Revision B of FAA Order 8120.23, saying the update restructures certificate management of Production Approval Holders to streamline documentation, clarify responsibilities and align oversight policy with other FAA directives.

The revision, the presenter said, incorporates recommendations from Office of Inspector General report AV2025002 (recommendations 1, 2, 4, 5, 6, 8 and 12) and aligns certificate management with the Safety Management System provisions found in 14 CFR Part 5 and FAA Order 8120.25. The presenter described three principal objectives: enhance clarity by reorganizing and simplifying the order’s language; support compliance by aligning with current regulatory requirements; and foster efficiency by streamlining procedures for audit planning and scheduling oversight.

Key procedural changes include a reorganization of certificate management into four sections—scheduling audits, planning audits, conducting and documenting audits, and post-audit activities (including processing non-compliances). The order now requires a written audit plan for Principal Inspector Audits, Supplier Control Audits and Quality System Audits and specifies criteria inspectors must weigh when developing those plans, such as past findings, process changes, critical processes, known quality issues and areas not previously audited.

The revision adds a fourth pillar to the risk assessment framework that requires inspectors to identify the highest-risk areas within a facility and prepare a facility plan. That assessment is required quarterly for all Level 1 and Level 2 HIGH Production Approval Holders and is optional for other PAHs. The presenter listed data sources for this risk-driven targeting, including production non-conformances, quality escapes, internal audit results, compliance and enforcement history, prior audit non-compliances, interviews with PAH employees, new technology, production increases and organizational instability.

Supplier oversight was notably strengthened. The order expands guidance to account for suppliers and subtier suppliers—requiring FAA inspectors to document what each supplier manufactures, the articles produced, and critical processes performed when selecting facilities for audit. The Supplier Control Audit plan must reflect that supplier scope and use risk indicators to prioritize audits across suppliers and subtier suppliers.

To align with Safety Management System practice, Revision B integrates SMS compliance evaluations into Principal Inspector and Quality System audits when a PAH has a required or voluntary SMS and adds SMS-related noncompliance codes in Appendix E. The order also clarifies how SMS interfaces with an existing quality system.

Changes also clarify how inspectors should categorize findings: the determination of whether a non-compliance is systemic or isolated now occurs at the audit’s conclusion, supported by updated definitions. The order replaces a specific internal tools reference (Aircraft Certification Audit Information System) with the broader term “Oversight Information System,” relocates Quality System Audit auditor appointment and training content to Appendix F, removes Table 3-3 to allow auditor flexibility, and updates figures, tables and FAA Form 8120-14 (Production Approval and Certificate Management Activity Report).

According to the presenter, the directive was coordinated for stakeholder review, including internal legal review by the Office of Chief Counsel and external public stakeholder comments; all comments were reviewed and dispositioned prior to finalization. For assistance the presenter directed listeners to the Policy Servicing Office (Policy and Standards Division, AIR-600) or their Certificate Management Section in the System Oversight Division (AIR-800).

"These revisions reflect a coordinated effort to make FAA directives more intuitive and better suited to today’s operational environment," the agency official said.

The briefing closed with contact and procedural guidance for training requests and further questions; no formal votes or decisions were recorded in the presentation.