ARSA RSS Feed ARSA LinkedIn
Contact Us Online Portal

I Think I Need An Aspirin

On April 28, ARSA sent a letter to the Federal Aviation Administration (FAA) seeking clarification on how the agency treats the creation and refilling of Emergency Medical Kits (EMKs) that are required equipment for air carriers (14 CFR § 121.803). The regulation requires carriers to have “an approved” EMK with specific contents that are “inspected” regularly to ensure continued serviceability.

The confusion arises from a lack of guidance on whether an “approved” kit must be created under the part 21 design and production requirements and whether the “inspection” is considered maintenance (as defined in § 1.1) despite the fact they are performed by flight attendants. The FAA furthers the uncertainty by using the Maintenance Time Limitations Section of the carrier’s Operations Specifications (OpsSpecs) to track the EMK’s currency.

ARSA recommended the FAA develop a separate OpsSpecs paragraph for all equipment carried aboard an aircraft that needs periodic validation to ensure that the equipment is not subject to the requirements of part 21 and 43. In the alternative, the agency should clarify in the existing OpsSpecs that EMKs are not validated as part of the maintenance program but are tracked only to ensure the contents do not expire.

Finally, ARSA requested confirmation that any person (including a repair station) may create and restock an EMK without having to comply with part 21 or 43. As the manufacturer, this person may also determine the replacement/validation intervals and issue a certificate of conformity as assurance the kit meets the requirements in the carrier’s OpsSpecs and is usable for a stated period of time.

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



More from ARSA

Good as Gold

Sponsors | Registration | Information March 10-13, 2020 (Add to Outlook Calendar) Washington, D.C. & Arlington, Virginia ARSA is grateful to its 2020 Annual Conference Gold Sponsors. Each company’s support…Read More

ARSA Member Survey Distributed

ARSA’s annual member survey invitation has been sent to the email address of every primary contact. The message is subjected “ARSA Member Survey Invitation” and was sent from arsa@arsa.org with…Read More

ARSA Leads Industry Letter to Repair FAA-TCCA MIP

On Feb. 3, ARSA led an international coalition of 13 U.S. and Canadian aviation associations to deliver a letter to Transport Canada Civil Aviation and the FAA raising two issues…Read More

GAO Workforce Report Can Be Resource for Industry

On Feb. 6, the Government Accountability Office (GAO) released the first in a series of reports mandated by the FAA Reauthorization Act of 2018 to study aviation industry and agency…Read More

ARSA Urges Swift FAA Action on Workforce Priorities at House Hearing

In a statement submitted for the record for a Feb. 11 House Aviation Subcommittee hearing on aviation workforce issues, ARSA called on Congress to apply more pressure to the FAA…Read More
ARSA