On Oct. 4, ARSA asked the FAA for clarification regarding the use of maintenance instructions modified according to EASA part 145.A.45(d). ARSA submitted its request on behalf of European ARSA members working under the Agreement between the United States of America and the European Community on Cooperation in the Regulation of Civil Aviation Safety; those members have faced questions over FAA acceptance of such modified maintenance instructions (MMI).

Under EASA’s rules, MMI are equivalent or improved instructions that retain the intent of the original type-certificate holder’s information. Since MMIs do not affect the “engineering design,” they should not be considered a deviation from the manufacturer’s maintenance manuals or ICA. As such, ARSA asked the FAA to officially recognize the acceptability of MMI.

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