[Note: The following Legal Brief for the October hotline is being published early to ensure ARSA members earliest access to its resources in advance of the new repair station rule’s…Read More
ARSA Seeks Clarification of FAA Designee Privilege
On Dec. 6, 2012, ARSA submitted a letter to the FAA requesting clarification of the privileges afforded to a repair specification designated engineering representative (RS-DER). The issue giving rise to the association’s request centered upon an RS-DER approval, and later “rescission” of that approval by the designee.
ARSA believes that such action is inappropriate under FAA rules. Specifically, the regulation empowering DERs only grants the privilege of approving information; it does not give designees authority to make “unsafe condition” determinations that would form the basis for revocation of an existing FAA approval. That regulatory limitation is reflected in FAA Order 8110.37E, the “Designated Engineering Representative Handbook,” which specifies that only the FAA, not its designees, can make such determinations. ARSA’s clarification request aims to remove potential uncertainty over repair specification approvals.
The FAA response (April 11, 2013) may be found here.
ARSA’s reply (June 5, 2013) to the FAA response may be read here.
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