On Aug. 9, the Federal Aviation Administration (FAA) responded to a three-year-old ARSA request for legal interpretation. In 2009, ARSA sought clarification that the Airworthiness Limitations Section (ALS) and any Component Maintenance Manuals (CMMs) referenced in ALS are part of the Instructions for Continued Airworthiness (ICA) and that changes to the ALS and/or CMMs therefore triggers the requirements of 14 CFR § 21.50(b) to make ICA available to appropriately rated repair stations.

In their response, the FAA agreed that all CMMs referenced in an ALS are part of the ICA and that modifications to the ALS are changes in type design that trigger § 21.50(b) requirements. The agency further confirmed that design approval holders must make the ALS and referenced CMMs available to a “properly rated repair station with a need to comply with the ALS” (i.e., in possession of a component to be worked on, a contract, work order, etc.). The interpretation fell short of extending CMM availability to all “properly rated repair stations, without restriction.”

~~~ posted 8/17/12 ~~~

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