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

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

[Updated] FAA Exemptions, Deviations and Other Virus Related Information

To keep tabs on all of ARSA’s work related to the current pandemic, visit arsa.org/anti-viral-measures. Note: Guidance, exemptions and other resources will be added to this page as they become…Read More

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

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
ARSA