Contact Us Payment Portal

ARSA Seeks Drug/Alcohol Rule Applicability Interpretation

ARSA has requested a legal interpretation from the FAA related to the new DOT/FAA drug and alcohol (D&A) testing rule. In a July 18 letter to the agency, ARSA inquired whether persons performing rebuilding and alteration activities are required to be covered by a D&A testing program, and whether persons doing off-aircraft maintenance of in-flight entertainment (IFE) system components must be covered by a program.

While many repair station personnel perform both maintenance and alterations, some do only alterations. Clarifying whether alterations specialists must be covered by a D&A program is critical. The only persons that can be part of an FAA-regulated D&A program are those that perform safety-sensitive functions, including maintenance. “If these [alteration-only] activities are not maintenance, no federal testing would be authorized and the company would be subject to sanctions if it ‘erred on the side of caution’ and tested such employees,” ARSA said in the letter.

ARSA also asked the agency to clarify a conflict on how IFE maintenance is defined. In the D&A rule’s preamble, the agency said that repairing IFE components “usually is not considered maintenance,” while removing and reinstalling the repaired component is maintenance. However, the definition of maintenance in FAR Part 1 includes repair and replacement but excludes removal.

ARSA’s request comes one week after the FAA and industry representatives, including ARSA, met to discuss pending guidance slated to be released by the FAA on complying with the rule.

For more on the new rule, click here.

For a news release on ARSA’s request, click here.

More from ARSA

Symposium 2018 – All That Happened

The 2018 Executive to Executive Briefings, Legislative Day & Annual Repair Symposium kept participants busy from March 13-16. If you were a participant… Access the 2018 Symposium Digital Companion, a…Read More

FAA Provides Follow Up on Written Questions from China IPA Training

Click the image to register for the training session. Update: On March 20, the FAA provided responses and follow up information to all questions submitted in writing during the live…Read More

ARSA Honors Jennifer Weinbrecht with Its Weston Award

Jennifer Weinbrecht. Photo courtesy MRO Network. On March 15, ARSA gave its 2018 Leo Weston Award to Jennifer Weinbrecht, retiring vice president of compliance for Component Repair Technologies (CRT). Weinbrecht…Read More

ARSA Recognizes Inhofe for Legislative Leadership

U.S. Sen. Jim Inhofe (R-Okla.). Photo courtesy Office of Sen. Inhofe. ARSA has recognized Sen. Jim Inhofe (R-Okla.) as its 2018 Legislative Leadership Award recipient. The presentation was made during…Read More

New Aviation Maintenance Industry Report Shows Hopeful Economic Projections, Hard Workforce Truths

According a new report, the global aviation maintenance industry will continue to expand its worldwide economic footprint over the next decade. The projections, released on March 14 during an industry…Read More