Join ARSA Ask ARSA Pay ARSA

Overhaul Reviewed Yet Again

On June 30, the agency issued another legal interpretation on the term “overhaul”—adding to the long list of explanations on the proper use of the term. Again the FAA summarizes the fact that the word can be used in a maintenance record to describe the highest level of work on an article. In other words, there are times that an article need only be cleaned and inspected to be described in a maintenance record as “overhauled.”

ARSA previously addressed the varying uses of the term in the context of component maintenance manuals (CMM), arguing that the regulations—not a manufacturer use of the term in its manual or instructions—dictate when an article is “overhauled.”  With this new legal interpretation ARSA will do further research into the origins and appropriate use of the term – stay tuned.

In the meantime, ARSA’s correspondence with the FAA regarding the use of this term can be found:

To see all the ways that ARSA is working as the voice of the aviation maintenance industry, visit the ARSA Works page.

Online Training: Overhauling Overhaul



More from ARSA

2025 Annual Conference – The “Who’s Who”

March 18-21, 2025 Event Information | Registration | Sponsors | Hotel (Book by Feb. 21) Arlington, Virginia and Washington, D.C. with Livestream Options Thank you to the 17 organizations that have committed…Read More

Industry Input Needed for Restricted Category Listening Sessions

On Jan. 24, the Virginia-based law firm Obadal, Filler, MacLeod, & Klein, P.L.C. launched a survey gathering experience with certification and operation of restricted category aircraft in the United States.…Read More

New Bilateral Oversight Guidance for ASIs

The FAA has announced an amendment to Order 8900.1, Vol. 6, Chap. 9, Sec. 27 clarifying procedures for aviation safety inspectors (ASIs) who oversee domestic repair stations holding foreign certificates…Read More

FAA Opens Workforce Grant Applications for 2025

On Jan 6, the FAA opened applications for its 2025 round of funding available through two aviation workforce grant programs championed by ARSA through multiple congressional reauthorizations of the agency.…Read More

FAA Requires Foreign D&A Testing by 2027

On Dec. 18, the U.S. Federal Register published the FAA’s long-awaited final rule expanding drug and alcohol testing requirements to repair station personnel outside the United States. The new rule…Read More
ARSA