ARSA RSS Feed ARSA LinkedIn
Contact Us Payment Portal

Have I Complied Yet?

In a letter to the Federal Aviation Administration (FAA), ARSA requested clarification on what constitutes full compliance with an Airworthiness Directive (AD). The question arose from members that received an Unapproved Parts Notification (UPN) that accused a particular repair station of improperly contracting maintenance to a source that was not “approved” by the manufacturer. The maintenance at issue involved re-coating engine disks after removing and inspecting them for cracks or pits in accordance with AD 2003-12-07.

ARSA contended that the AD only required the removal, inspection and replacement of the disks that were beyond a serviceable limit. If a disk was still serviceable (i.e., no crack or pits existed) the repair station could use methods, techniques and practices that return it to at least the original (or properly altered) condition.

In other words, any maintenance performed on disks after the AD was complied with, including the work that was contracted to the “unapproved” source, could be accomplished in accordance with 14 CFR § 43.13. Therefore, the repair station was not required by the AD to use a source “approved” by the manufacturer to re-coat the disks.

As a result, ARSA requested affirmation of its interpretation of the subject AD, withdrawal of the UPN and confirmation that “approval” by a manufacturer is not required to establish compliance with 14 CFR § 43.13. We will keep our members updated as soon as we get a reply from the FAA.

A copy of ARSA’s letter to the FAA may be found here.



More from ARSA

MRO Europe & Asia – VIP Invitations, ARSA Discounts

On behalf of its partners at Aviation Week, ARSA is helping extend a “VIP” invitation to association contacts employed by airlines or lessors and discounted registration to all other members.…Read More

Starting Strong

Special thanks to MRO Holdings, which includes both Flightstar Aircraft Services and Aeroman, for its Gold Level Sponsorship of ARSA’s 2017 Strategic Leadership Conference in Washington, D.C. on Oct. 18 and 19. MRO Holdings’…Read More

ARSA Training: Part 65 Repairman Certificates

This session reviews the requirements of 14 CFR part 65 subpart E, which concerns aviation repairmen. It presents the language of part 65 in the context of parts 121, 135…Read More

ARSA Training: Live Session on Duty-Free Parts Importation

On Oct. 11, join Executive Vice President Christian A. Klein for an hour-long session on parts importation requirements. Klein will review the issues surrounding duty-free import of civil aviation parts…Read More

Eight ARSA Training Sessions Accepted for IA Renewal Credit

On Sept. 12, ARSA announced that eight of its on-demand training sessions have been accepted by the FAA for Inspection Authorization renewal credit under 14 CFR § 65.93. Each session…Read More
ARSA