ARSA RSS Feed ARSA LinkedIn
Contact Us Online Portal

ARSA, Industry Partners Help FAA Reconstruct Recordkeeping Guidance

On June 12, an ARSA-led coalition of ten industry partners submitted a complete rewrite of the agency’s proposed Advisory Circular 43-ARTS, “Use of FAA Form 8130-3 for Approval to Return to Service Under Part 43.”

The signatories, most of whom also joined a February request for extension to the comment period, made good use of the additional time provided. They compared the draft AC as written to existing maintenance recordkeeping rules and agency guidance and determined that the draft should not be issued.

“Release of the draft AC without a complete rewrite will, among other things, cause both industry and the FAA to expend considerable resources to ensure continued compliance with section 43.9 and international commitments,” the letter said.

The coalition instead submitted a replacement for the existing AC 43-9C, which is not current and fails to address 43.9 requirements. The new draft walks through the rule and described what it requires for mechanics, repairmen and repair stations performing work on aircraft with U.S. airworthiness certificates. The submission also describes the steps for handling, correcting or reissuing maintenance records as well as completion of FAA Form 8130-3 for the FAA, EASA and other civil aviation agencies.

“[Maintenance records] associated with a civil aviation aircraft, its installed products, appliance and articles are essential to making determinations of the aircraft’s airworthiness,” the group’s draft AC describes, underscoring the importance of correctly aligning agency guidance with recordkeeping regulations. “Maintenance records provide tangible evidence that the work on the aircraft and its installed products and articles was performed appropriately and correctly.”

In addition to providing the replacement for AC 43-9C, the signatories also urged the agency to issue separate advisory circulars on 43.11 inspection records and part 91 owner/operator records.

To read the full submission (cover letter and rewritten AC), click here.

The following organizations joined ARSA in the submission:

Aircraft Electronics Association
Airlines for America
Aviation Suppliers Association
General Aviation Manufacturers Association
Gulfstream Aerospace Corporation
Modification and Replacement Parts Association
MOOG Aircraft Group
National Air Transportation Association
Professional Aviation Maintenance Association

Previous Work on Recordkeeping Guidance...

3/8/17 - ARSA, Industry Partners Get 90 Additional Days to Comment on Form 8130 AC

March 8, 2017

On Feb. 27, an ARSA-led coalition of industry partners asked the FAA to extend the comment period on Draft Advisory Circular 43-ARTS, “Use of FAA Form 8130-3 for Approval to Return to Service Under Part 43.” The agency summarily accepted the request, providing an additional 90 days; comments are now due on June 12.

The group’s 15 signatories from both trade associations and private aviation companies sought the additional time to carefully reconsider the AC as proposed by the agency:

“Draft [AC] 43-ARTS significantly revises the agency’s interpretation of the requirements for using FAA Form 8130-3 for approving articles for return to service,” the request said. “Because the draft AC does not mirror the maintenance recordkeeping regulations and conflicts with existing agency policy, additional time is required for industry to develop comprehensive substantive comments.”

To read the complete request, click here.

To see all of the ways ARSA serves as voice of the aviation maintenance industry, visit the ARSA Works page.



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