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ARSA Repeats Call for Update to Final Inspection Guidance

Thanks to a member question (published as “A Member Asked” in this month’s hotline newsletter), ARSA again reminded the FAA that its guidance should correctly cite (and therefore interpret) the plain language of the regulation.

In this case, the agency continues to “guide” its workforce into believing that a person performing a final inspection for a repair station must be certificated under part 65. The language in section 145.213 makes clear that performing a final inspection and “signing off” on that inspection by issuing a “maintenance release” (under section 43.9) are two separate steps.

It is the person performing the “sign off” that must be certificated under part 65, while the final inspection has to know what s/he is doing. The association has already highlighted the difference between the regulations and the guidance material several times. On Nov. 3, ARSA reiterated its plea to correct the guidance in a letter to Tim Shaver, manager of Aircraft Maintenance Division.

To read the letter, click here.

Previously from ARSA...

6/16/14 - FAA Indicates Plans to Clarify Final Inspection Guidance

June 16, 2014

In response to ARSA’s Nov. 30, 2011 and May 14, 2014 requests, the Federal Aviation Administration (FAA) delivered a letter indicating it will revise Order 8900.1 to reflect that that repair station personnel performing final inspections are not required to be certificated under part 65.

May 15, 2014

On May 14, ARSA submitted a letter to the Federal Aviation Administration (FAA) requesting it correct parts of Order 8900.1 that purportedly requires persons performing final inspections be certificated under part 65. This guidance is incorrect and fails to recognize the regulatory distinction between performing a final inspection and approving the work on an article for return to service. ARSA addressed this issue back in November 2010 but the erroneous guidance remains despite the 2013 and 2014 revisions to Order 8900.1.

The regulations clearly demonstrate that the final inspection and “maintenance release” are two separate and distinct activities. This issue almost never arises because most of the time, persons performing the final inspection are also qualified to issue the approval for return to service; however when a repair station separates these activities, confusion ensues. The regulations certainly make the separation and Order 8900.1 should be revised accordingly.

To see all the ways that ARSA is working as the voice of the aviation maintenance industry, visit our ARSA Works page.



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