On July 9, 2010, ARSA submitted a request to the Federal Aviation Administration (FAA) asking for the agency to correct and reissue Notice 8900.88 (“Letter Certifying HAZMAT Training for Employees of Part 145 Repair Stations” published August 20, 2009).

Regulations require repair stations to certify, in writing, that all “hazmat employees” are properly trained. However, such documentation is only required during a repair station’s initial certification, and when a repair station amends its certificate or changes a rating. ARSA submitted the request because, in contrast to current regulations, Notice 8900.88 required repair stations to retroactively provide written certification of compliance with hazmat training requirements.

Not only was the retroactive requirement beyond the scope of existing rules, it also served no regulatory or practical purpose. Even without written certification, repair stations are required to comply with hazmat rules; Notice 8900.88 simply added an unnecessary burden on repair stations. To remedy the situation, ARSA included a proposed substitute Notice with its letter that accurately reflects written certification requirements under the relevant rules.

Notice 8900.88 can be found on the FAA’s website here.

ARSA’s Letter and proposed replacement Notice are available here.

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