ARSA RSS Feed ARSA LinkedIn
Contact Us Online 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

FAA Extends ARSA Training IA Acceptability into 2023

In early 2020, the FAA informed ARSA of a 24-month extension to the expiration dates for each of the association’s online training sessions found acceptable for Inspection Authorization renewal credit…Read More

Presidential Order Directs Agency Focus on Relief

To keep tabs on all of ARSA’s work related to the current pandemic, visit arsa.org/anti-viral-measures. On May 19, President Trump signed Executive Order 13924, “Regulatory Relief to Support Economic Recovery.”…Read More

Anti-Viral Measures

For the use of its members and the larger aviation community, ARSA is maintaining this page as a resource for virus-related updates on policy initiatives and business needs. Please bookmark…Read More

AMT Day 2020 – Still Celebrating Charlie

Charles Taylor, the Wright Brothers’ mechanic and father of aviation maintenance, was born on May 24, 1868. Now – 152 years later – we celebrate him with every safe arrival…Read More

CAAC Updates “Simplified Approval Process for OEM’s MROs”

A member was kind enough to point out temporary guidance issued by the Civil Aviation Administration of China (CAAC) regarding its “Simplified Approval Process for OEM’s MROs.” While, unfortunately, the…Read More
ARSA