ARSA RSS Feed ARSA LinkedIn
Contact Us Payment Portal

Using CMMs for Overhaul

ARSA sent a set of letters to the Federal Aviation Administration (FAA) to dispel the agency’s notion that a repair station could not use a manufacturer’s component maintenance manual to perform an overhaul. The agency opined that a facility must either use a manufacturer’s “overhaul manual” or develop its own FAA-approved manual to accomplish the described work.

The Association disagreed with this opinion and pointed out that whether the manufacturer of an article uses “overhaul” in its manual or instructions does not dictate the use of the term in a maintenance record. The regulations set forth the requirements for the proper use of that term, not the manufacturer.

Maintenance is defined in § 1.1 as “inspection, overhaul, repair, preservation, and the replacement of parts” Further, all maintenance must be done in accordance with the performance standards set forth in § 43.13. Section 43.13(a) indicates that the manufacturer’s maintenance manual or instructions for continued airworthiness contain acceptable methods, techniques and practices for accomplishing work.

In order to use the term “overhaul”, a maintenance provider must perform an extensive scope of work. That is, the repair station must disassemble, clean, inspect, repair as necessary, reassemble and test the article in accordance with procedures developed by the manufacturer. The regulations do not limit the use of that term to manufacturer instructions that contain the word “overhaul”; rather they dictate the scope of work necessary to ensure that all tasks are accomplished (or determined unnecessary).

Therefore, a repair station may use the term “overhaul” provided the necessary work scope has been accomplished in accordance with the § 43.13(a) methods, techniques and practices. In other words, an “overhaul” manual is not required to perform the work scope necessary to use that term in a maintenance record.

ARSA’s letters to the FAA may be found here, and here.

UPDATE: On August 31, 2009, the FAA responded to ARSA’s letters.



More from ARSA

ARSA Files Brief in Accountable Manager Litigation

On July 17, ARSA filed an amicus brief urging the Ninth Circuit Court of Appeals to reconsider the relationship between the regulatory responsibility of an “accountable manager” and his or…Read More

U.S. Signs Maintenance Agreement with Singapore

On July 12, the FAA signed and released the initial Maintenance Agreement Guidance (MAG) with the Civil Aviation Authority of Singapore (CAAS). The MAG details the agencies’ responsibilities under the…Read More

Online Training – Building a Positive Government Relationship

This session provides a roadmap for building a positive relationship with civil aviation authorities. It begins by describing the rules that should always be considered when engaging with aviation safety regulators,…Read More

2017 NextGen Awards – Celebrate Young Talent

ARSA’s commitment to building the aviation maintenance workforce of the future means celebrating the excellence of the men and women who already keep the world safely in flight. The association…Read More

[Updated] RCCB to Clarify Guidance on 100 Percent Replacement

Update: On July 11, the FAA responded via email to ARSA’s June 29 request for clarity on the ability of repair stations to replace 100 percent of an article while performing…Read More
ARSA