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 – Sponsor Salute

Registration is officially open for ARSA’s 2019 Annual Conference. Make sure you’ve got the dates in your calendar (and that they are correct): March 12-15, 2019 in Arlington, Virginia and…Read More

Court Skeptical on Falsification

On Jan. 11, the U.S. Court of Appeals for the District of Columbia Circuit heard oral arguments in Kornitzky Group v. Daniel Elwell. The hearing considered the appeal of a…Read More

Managing a Shut-down Government

Managing Another MAG Mess UPDATE: Having heard on Jan. 14 the FAA was in the process of recalling aviation safety inspectors to work for no-pay while wrangling over the government shutdown…Read More

On-Demand Training – Three Sessions on Human Factors

ARSA is growing its library of human factors-related training sessions. The first three, which introduce key aspects of human factors in aviation maintenance, are now available for immediate on-demand viewing:  Human…Read More

Quick Question – U.S. Government Shutdown

ARSA communicates regularly with officials in the legislative and executive branches of the U.S. government about issues affecting the maintenance and manufacturing sectors.  Help the association manage issues related to the federal government…Read More
ARSA