ARSA RSS Feed ARSA LinkedIn
Contact Us Payment Portal

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.



More from ARSA

MRO Europe & Asia – VIP Invitations, ARSA Discounts

On behalf of its partners at Aviation Week, ARSA is helping extend a “VIP” invitation to association contacts employed by airlines or lessors and discounted registration to all other members.…Read More

Starting Strong

Special thanks to MRO Holdings, which includes both Flightstar Aircraft Services and Aeroman, for its Gold Level Sponsorship of ARSA’s 2017 Strategic Leadership Conference in Washington, D.C. on Oct. 18 and 19. MRO Holdings’…Read More

ARSA Training: Part 65 Repairman Certificates

This session reviews the requirements of 14 CFR part 65 subpart E, which concerns aviation repairmen. It presents the language of part 65 in the context of parts 121, 135…Read More

ARSA Training: Live Session on Duty-Free Parts Importation

On Oct. 11, join Executive Vice President Christian A. Klein for an hour-long session on parts importation requirements. Klein will review the issues surrounding duty-free import of civil aviation parts…Read More

Eight ARSA Training Sessions Accepted for IA Renewal Credit

On Sept. 12, ARSA announced that eight of its on-demand training sessions have been accepted by the FAA for Inspection Authorization renewal credit under 14 CFR § 65.93. Each session…Read More
ARSA