ARSA RSS Feed ARSA LinkedIn
Contact Us Online Portal

Exemption Toolkit for “Current” Maintenance Data Requirement

On Nov. 19, ARSA released a members-only toolkit providing a draft petition for exemption – and instructions for its submission – from the requirement under 14 CFR § 145.109(d) that repair stations have “current” manufacturer’s data available even when it is not needed and will not be used.

As many maintenance providers are aware, the FAA does not require design approval holders (i.e., manufacturers) to make maintenance data available as they are required to by 14 CFR § 21.50(b). However, the agency aggressively enforces the requirement for repair stations to possess the most current version of those documents. By submitting petitions, FAA-certificated repair stations will pressure the agency to uniformly apply both design and maintenance requirements in addition to aligning parts 145 and 43.

The association encourages its members to utilize the toolkit to submit a petition; the included draft requires minimal editing/update and is ready to be placed on company letterhead and delivered to the agency. Not only will the effort directly benefit each repair station by helping alleviate an unnecessary regulatory burden, it will also help ARSA develop a broader public policy case for removing the requirement from § 145.109(d).

To access the toolkit:

(1) Log in to the association’s secure online portal (arsa.member365.com). If you have not done so previously or have lost your credentials, enter the email address associated with your membership and follow the instructions for “Forgot Password?”
(2) From your member dashboard, select “Workspaces” from the top menu.
(3) From the workspaces page, select “Publications: Tools for ARSA Members” under the “ARSA Members” category.
(4) On the left side of the workspace screen, select “File Library.”
(5) On the file library page, select “Petition from Exemption from 14 CFR 145.109(d)” from the category drop-down.
(6) Click the filename “ARSA-145-109ExemptionToolkit-20181110.docx” to download the toolkit, which is in a Word Document format.

Keep the association informed by including arsa@arsa.org on any correspondence regarding exemption requests and use the inquiry system to submit any questions.

Related

While you’re requesting exemption from 145.109(d), share your experiences regarding “current” maintenance data requirements with ARSA through the following “quick question”:

Quick Question – Current Maintenance Data



More from ARSA

Conference 2019 – See What Happened

The Live Feed from @ARSAWorks… Click here to see the flurry of social media updates produced by ARSA’s team during the conference. Follow @ARSAWorks 2019 Annual Conference Updates March 19,…Read More

Global Good Sense Recognized by First-Ever Joint Weston Award

On March 15, ARSA gave its 2019 Leo Weston Award to two exceptional individuals from member companies. Werner Luehmann, head of regulatory compliance and authorities’ liaison at Lufthansa Technik and…Read More

Return to Sender – Fraudulent Email Raising Funds for Sick Child

Multiple ARSA members have reported receipt of a suspicious email claiming to be from an @arsa.org email address and raising money for a sick child. There is evidence that similar…Read More

Aviation Maintenance Industry Climbing into Workforce Headwind

The aviation industry is poised for another positive year with global spending on maintenance, repair and overhaul services expected to grow by more than $30 billion over the next decade,…Read More

Maintenance Industry Honors Graves, Lipinski for Aviation Workforce Leadership

On March 13, the aviation maintenance industry honored U.S. Reps. Sam Graves (R-Mo.) and Dan Lipinski (D-Ill.) for addressing the chronic shortage of technicians threating to undermine the growth and…Read More
ARSA