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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.



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