Join ARSA Ask ARSA Pay ARSA

Ask and You Shall Receive

On March 8, ARSA sent a letter to the FAA requesting that the agency clarify (or, re-clarify) that fabrication of a part is not maintenance.

ARSA’s appeal was driven by several members who recently contacted the association with issues regarding the manufacture of detail parts by maintenance personnel and local inspector interpretations of that practice. With the issue was clearly addressed by a previous legal interpretation from the FAA Office of Chief Counsel and is supported by existing agency guidance, it became apparent that the confusion resulted from individual FAA inspector misunderstandings.

The inspector misinterpretations resulted in claims that a repair station was contracting maintenance functions without FAA approval and not performing maintenance according to regulations. By wrongly categorizing fabrication as maintenance, the FAA was shifting industry focus away from proper execution of the task.

As a result, ARSA asked the FAA to ensure that its front-line inspectors were fully aware of the current policy regarding part fabrication by maintenance providers.

On March 22, the FAA responded, agreeing with the association. “Your understanding on the act of fabrication is correct. It is not considered maintenance,” said Manager Carol E. Giles of the FAA’s Aircraft Maintenance Division.

Giles further advised ARSA that on April 16, 2011, the second compliance date for the revised Title 14 CFR part 21 will become effective and it specifically includes a section addressing part fabrication by an appropriately rated certificate holder.



More from ARSA

2025 Annual Conference – It Happened

March 18-21, 2025 2025 Event Information | 2025 Sponsors Arlington, Virginia and Washington, D.C. with Livestream Options ARSA is grateful to the sponsors, participants, speakers, and support personnel who made the…Read More

Maintenance Industry Surpasses Pre-Pandemic Peaks, Enters “Supercycle”

On March 19, ARSA used its Annual Legislative Day gathering to release its 2025 Global Fleet & MRO Market Report. The analysis provided for the association by Oliver Wyman Vector,…Read More

U.S. Bilateral Update Requires SMS Compliance

On Feb. 10, the Bilateral Oversight Board (BOB) for the U.S.-European Union (EU) bilateral aviation safety agreement (BASA) issued Decision No. 13. It amends BASA Annex 2 to require U.S.-based…Read More

ARSA Survey Invite Sent

On Feb. 21, an invitation to complete ARSA’s member survey was sent to the email address of every primary contact. The message was subjected “Invitation to Complete ARSA’s Annual Member…Read More

ARSA Helps CNBC Illustrate Career Development “Challenge”

On Feb. 14, CNBC published a 12 minute special addressing the workforce and career development challenges facing the maintenance industry. ARSA Executive Director Sarah MacLeod participated, lending a voice to…Read More
ARSA