A subsurface flaw located near a component surface is transformed to a surface flaw in accordance with a flaw-to-surface proximity rule. The recharacterization process from subsurface to surface flaw is adopted in all fitness-for-service (FFS) codes. However, the criteria of the recharacterizations are different among the FFS codes. In addition, the proximity factors in the rules are generally defined by constant values, irrespective of flaw aspect ratios. This paper describes the stress intensity factor interaction between the subsurface flaw and component free surface and proposes a proximity factor from the point of view of fatigue crack growth rates.