ARSA RSS Feed ARSA LinkedIn
Contact Us Online Portal

ARSA Submits Comments on OMB Good Guidance Practices

ARSA has recently submitted comments on a draft bulletin, issued by the Office of Management and Budget (OMB), concerning the issuing of guidance by Federal agencies. The bulletin includes policies and procedures for agencies to develop, issue and use guidance documents.

OMB has been particularly concerned that agency guidance practices should be more transparent, consistent and accountable. Because guidance documents often do not receive the benefit of careful consideration accorded under the procedures for creating regulations, this bulletin stresses that agencies should follow established and effective procedures in developing guidance. This will help ensure that Federal agencies do not engage in rulemaking through guidance.

In its comments, ARSA thanked the OMB for issuing such an important bulletin, and cited examples where the FAA has used guidance documents as rulemaking. Additionally, ARSA made several suggestions which, if adopted, will increase the OMB’s ability to review guidance documents and make them more easily available to the public. These revisions would force agencies to identify affected parties even if documents are labeled as “internal.”

To download a .pdf copy of ARSA’s comments, Click here.

To download a .pdf copy of the OMB draft bulletin, Click here.



More from ARSA

Simple Math – Counting Bilaterals in a Quadrilateral Group

On Nov. 6-9, the Maintenance Management Team (MMT) met in Brasilia, Brazil to discuss a variety of international issues affecting their respective bilateral maintenance agreements. Sometimes referred to as the…Read More

Return to Sender – Fraudulent Email Warning

Multiple ARSA members have reported receipt of a suspicious email from arsa@arsa.org subjected: “Shared ‘New Maintenance Data’ with you.” The message appears to come via Microsoft OneDrive. The association did…Read More

What Election 2018 Means for Maintenance

The dust from the 2018 midterm elections is still settling, but here are some initial thoughts on what the results mean for ARSA members: House Freshman Class Creates Risks and…Read More

Hotline Highlight: Take it with You

The hotline – ARSA’s premier member newsletter – contains news, editorial content, analysis and resources for the aviation maintenance community. All members should ensure they receive their edition the first week of…Read More

Quick Question – Current Maintenance Data

Repair stations can help ARSA with its ongoing effort to make sense out of the rules governing maintenance data availability and currency. Take a minute to complete this month’s “quick…Read More
ARSA