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When Current Is Past

***Update: On May 22, 2009, the Federal Aviation Administration (FAA) released this InFO, which clarifies that an operator must properly adopt a program under 14 CFR section 91.409(e) that is “current” at that time (the time of the adoption). While some may claim that the InFO carries no “weight”, the fact that it clearly defines the regulatory requirement that was not addressed in the interpretation of section 91.409(f) makes it valid and applicable.

In December 2008, the FAA’s Office of Chief Counsel, Regulatory Compliance Division issued an interpretation of 14 CFR section 91.409(f)(3) that “a current inspection program recommended by the manufacturer” means the one that the registered owner chose at a point in time, not current as of “today”. This has created confusion among maintenance providers as to which program they should be using on “current” inspections (those being done today). With the help of a member’s law firm, Hogan & Hartson, L.L.P., ARSA requested guidance on exactly what program the maintenance provider should be using when the operator did not clearly “choose” one as required by 14 CFR section 91.409(f).

The December 2008 interpretation may be found here.

ARSA’s request for guidance can be found here.

If members have questions regarding this issue, please contact Sarah MacLeod at sarahsays@arsa.org.



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