ARSA RSS Feed ARSA LinkedIn
Contact Us Payment 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

Report Shows Aviation Maintenance Connects U.S. Workers to Global Economy

Global trade in aviation maintenance creates jobs and business opportunities in every corner of the United States, a new analysis by ARSA shows. Florida, California and Texas top the list…Read More

Member Alert: New Association Management System

ARSA is transitioning to a new membership engagement tool. The “association management system” (AMS) will integrate with www.arsa.org through an online portal providing direct access for members to information, benefits…Read More

ARSA Joins Broad Coalition Urging Skills Education Reform

On June 14, ARSA joined more than 400 other organizations on a letter to Sens. Lamar Alexander (R-Tenn.) and Patty Murray (D-Wash.) urging swift action to reauthorize the Carl D.…Read More

AeroTEC Opens Doors and Congressman’s Eyes

U.S. Rep. Dan Newhouse poses between AeroTEC President Lee Human (Left) and Flight Test Center Site Manager Matt Davis. One of the best ways to educate elected officials about your…Read More

Summer* Briefing on EASA Technical Matters

On June 5, Marshall S. Filler, ARSA managing director & general counsel, represented the association at the bi-annual meeting of EASA’s Engineering and Maintenance Technical Committee (EM.TEC) in Cologne, Germany.…Read More
ARSA