ARSA RSS Feed ARSA LinkedIn
Contact Us Payment Portal

FAA’s Word on Bonded Repair Size Limits – Final Policy

On Nov. 24, the FAA issued a final policy (PS-AIR-100-14-130-001) regarding bonded repair size limits. ARSA’s regulatory team is currently reviewing…Stay tuned.

 

Previously from ARSA…

ARSA’s Word on Bonded Repair Size Limits Draft Policy

October 16, 2014

On Thursday, Oct. 16, 2014, the Aeronautical Repair Station Association (ARSA) submitted comments to the Federal Aviation Administration (FAA) requesting the withdrawal of Draft Policy PS-AIR-20(xxx)xx-xx: Bonded Repair Size Limits.

Your Word is Your Bond – Bonded Repair Size Limits Draft Policy

October 2, 2014

A member has alerted ARSA to a draft policy from the FAA regarding Bonded Repair Size Limits that would require design approval holder (DAH) substantiation on any repairs developed by owners, operators, repair stations, Designated Engineering Representatives (DER), or engineering firms.

ARSA urges anyone affected by such a change to submit comments to the FAA before the October 10, 2014 deadline.

The FAA cites unexpected failures of bonded repairs to non-critical structures as the impetus for the draft policy. The agency, without providing regulatory, engineering, technical or statistical references, “concludes that bonded repair of critical structure is a potential safety threat.” The draft includes further presumptions that there are no available non-destructive inspection (NDI) techniques that assure that viability of a bonded repair. The FAA has deemed that such uncertainty necessitates a limit to the size of bonded repairs for critical structures. Through comments, ARSA members have the opportunity to ensure the agency ensures its policy is grounded in the regulations and to produce documented proof and objective data to corroborate its assumptions.

Under the draft policy, the size limitations of the bonded repairs are based on the inherent constraints of the specific designs and those associated with the substantiating data used to meet relevant regulations under 14 Code of Federal Regulations (CFR) parts 2123252743. The policy will impact the capabilities of owners, operators and repair stations to develop repairs on critical structures by creating reliance on substantiation data only from the DAH for specifying tolerances and size limitations.

The resulting uncertainty imposes unknown cost on industry members without additional benefit to safety. There are additional concerns that dependence only on the DAHfor repair substantiation—many of whom may not have sufficient maintenance experience—will drive the use of new, more costly parts in lieu of properly established repairs.

Examine whether this issue may affect your business. Stay informed, ask questions, and submit your comments to the docket. Repair station involvement on these issues – which seem small but can have broad impact on the maintenance community – is essential to ensuring the government appropriately balances its responsibilities with the industry’s.



More from ARSA

Report Shows Aviation Maintenance Connects U.S. Workers to Global Economy

Global trade in aviation maintenance creates jobs and business opportunities in every corner of the United States, a new analysis by ARSA shows. Florida, California and Texas top the list…Read More

Member Alert: New Association Management System

ARSA is transitioning to a new membership engagement tool. The “association management system” (AMS) will integrate with www.arsa.org through an online portal providing direct access for members to information, benefits…Read More

ARSA Joins Broad Coalition Urging Skills Education Reform

On June 14, ARSA joined more than 400 other organizations on a letter to Sens. Lamar Alexander (R-Tenn.) and Patty Murray (D-Wash.) urging swift action to reauthorize the Carl D.…Read More

AeroTEC Opens Doors and Congressman’s Eyes

U.S. Rep. Dan Newhouse poses between AeroTEC President Lee Human (Left) and Flight Test Center Site Manager Matt Davis. One of the best ways to educate elected officials about your…Read More

Summer* Briefing on EASA Technical Matters

On June 5, Marshall S. Filler, ARSA managing director & general counsel, represented the association at the bi-annual meeting of EASA’s Engineering and Maintenance Technical Committee (EM.TEC) in Cologne, Germany.…Read More
ARSA