ARSA RSS Feed ARSA LinkedIn
Contact Us Payment Portal

ARSA Requests FAA Assistance to Address MAG Part Tagging Requirements

On April 3, ARSA joined with several of its industry allies in a letter to the FAA requesting the agency’s assistance in resolving specific “tagging,” requirements in the Maintenance Annex Guidance (MAG).

The MAG contains the detailed guidance that must be developed by the Joint Maintenance Coordination Board (JMCB) of U.S. and EU regulators in implementing the bilateral aviation safety agreement between the U.S. and the European Union that entered into force last spring.

At issue is the MAG “requirement” for an 8130-3 tag, issued by the production certificate holder, on all new parts used by a U.S. based repair station exercising its European Aviation Safety Administration (EASA) privileges. Specifically, the demand conflicts with FAA regulations in several ways. Indeed, the FAA has rejected requiring production approval holders (PAHs) from issuing Form 8130-3 in its own regulations. The letter also notes that EASA regulations allow more flexibility and, therefore, without a change to the MAG provision, U.S. businesses face an unnecessary burden from this significant administrative requirement in the MAG, with no safety benefit.

To resolve this issue, ARSA and its partners suggest changing the MAG language to require U.S. PAHs to use a PAH certificate of conformance stating the production approval under with the component was manufactured. Such a change would ensure consistency with existing FAA rules and improve the international competitiveness of the U.S. aerospace industry in light of the flexibility available to European manufacturers.

As this revision will help the U.S. realize President Obama’s National Export Initiative goal of doubling U.S. exports, the associations suggest that the JMCB adopt the change at its next meeting and incorporate the requested revision into the MAG as soon as possible.

~~~ posted 4/10/12 ~~~



More from ARSA

ARSA Files Brief in Accountable Manager Litigation

On July 17, ARSA filed an amicus brief urging the Ninth Circuit Court of Appeals to reconsider the relationship between the regulatory responsibility of an “accountable manager” and his or…Read More

U.S. Signs Maintenance Agreement with Singapore

On July 12, the FAA signed and released the initial Maintenance Agreement Guidance (MAG) with the Civil Aviation Authority of Singapore (CAAS). The MAG details the agencies’ responsibilities under the…Read More

Online Training – Building a Positive Government Relationship

This session provides a roadmap for building a positive relationship with civil aviation authorities. It begins by describing the rules that should always be considered when engaging with aviation safety regulators,…Read More

2017 NextGen Awards – Celebrate Young Talent

ARSA’s commitment to building the aviation maintenance workforce of the future means celebrating the excellence of the men and women who already keep the world safely in flight. The association…Read More

[Updated] RCCB to Clarify Guidance on 100 Percent Replacement

Update: On July 11, the FAA responded via email to ARSA’s June 29 request for clarity on the ability of repair stations to replace 100 percent of an article while performing…Read More
ARSA