ARSA RSS Feed ARSA LinkedIn
Contact Us Payment 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

Tell Congress to Support Maintenance Workforce Bill

Members of the aviation maintenance community need to join ARSA’s aggressive effort to include the association’s workforce development legislation in the FAA reauthorization process. The bill would create a new…Read More

Travel Well with “Going Global” Regulatory Training

International markets mean expanded business opportunities that require an expansive regulatory understanding. Working on your global knowledge with two on-demand training sessions from ARSA Managing Director & General Counsel Marshall…Read More

AMT Day 2018 – How Will You Celebrate Charlie?

Charles Taylor Charles Taylor, the Wright Brothers’ mechanic and father of aviation maintenance, was born on May 24, 1868. Now – 150 years later – we celebrate him with every…Read More

Industry Sets Remote Connectivity Baseline for FAA

On May 7, ARSA and 15 of its aviation industry allies jointly submitted a draft advisory circular to the FAA providing “guidance for using remote connectivity technology and tools.” The…Read More

On Demand Training – Recordkeeping Sessions

Proper maintenance demands proper documentation. Review the association’s recordkeeping sessions – led by Sarah MacLeod and Marshall S. Filler – and learn how to “finish the job with proper paperwork.” Recordkeeping…Read More
ARSA