ARSA RSS Feed ARSA LinkedIn
Contact Us Online Portal

FAA Responds To Pratt & Whitney D&A Rule-related Interpretation Request

Pratt & Whitney recently received a response from the FAA to an inquiry related to the D&A rule’s applicability to subcontractors performing parts fabrications under part 43.

In its letter to Pratt & Whitney (.pdf), the FAA explained that fabrication “in the context of Pratt & Whitney’s inquiry” is not considered maintenance. “Subcontractor employees who fabricate a part are not repairing anything,” the agency explained. “Rather, they are producing a part, whether that production is done under a repair station’s quality control system or under a manufacturer’s own fabrication inspection system.” Maintenance is one of the safety-sensitive functions covered by the D&A regulation; manufacturing–including producing parts–is not. The FAA expanded on this view in D&A rule guidance issued Aug. 15.

The FAA also clarified two other issues raised by Pratt & Whitney:

* Non-regulated parts brokers are not covered by the D&A regulation, and
* The D&A regulation does not apply to organizations that perform maintenance outside the U.S., even if the work is for a part 121 or part 135 air carrier.

For more information/background on the drug & alcohol rule, 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