ARSA RSS Feed ARSA LinkedIn
Ask ARSA Online Portal

“100-percent Replacement” Makes 1-percent Progress

On Aug. 9, the FAA ended ARSA’s two-year wait for a response to its request to the Regulatory Consistency Communications Board (RCCB) for clarity regarding the right of repair stations to replace 100 percent of an article while performing maintenance. For the most part, this “interim response” merely restated and “acknowledged” the association’s description of the issue.

“FAA regulations do not specify the amount of parts that may be replaced on an article during a single maintenance visit,” the RCCB said in its response, echoing the argument made in ARSA’s initial submission. “Accordingly, the FAA will actively explore developing guidance and whether a legal interpretation is appropriate.”

The status update, which did not claim to be the final word on the issue from the RCCB, did little to enhance consistency in regulatory communications but at least confirmed the FAA’s alignment with industry on the base issue.

To read the complete interim response, click here.

To read the association’s 2017 submission, click here.

7/11/17 - (Updated) RCCB to Clarify Guidance on 100 Percent Replacement

July 11, 2017

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 maintenance. The agency’s Regulatory Consistency Communication Board (RCCB), to which the request was submitted, “has carefully evaluated [the] issue and determined it will be accepted by the RCCB for resolution.”


ARSA Asks RCCB to Clarify Guidance on 100 Percent Replacement

July 6, 2017

On June 29, ARSA submitted a request to the RCCB to help the FAA clarify that repair stations can replace 100 percent of an article while performing maintenance.

Previous agency attempts to determine when a particular action is manufacturing, thus requiring a production approval, are not supported by a plain read of regulations. “The regulations do not directly or indirectly prohibit the replacement of all parts in an article during a single maintenance visit,” the submission said. “There are no limits on the number of parts that can or should be replaced during a maintenance action.”

The request cites the definitions of “maintenance” and “repair” under § 1.1 and their relation to the term “replacement of parts.” It also addresses the prohibition against the reuse of § 45.11 identification plates. Based on a plain reading of these definitions as well as parts 21 and 43 and a review of existing agency guidance, ARSA informed the RCCB that both the Aircraft Certification and Flight Standards services should provide clear direction on how compliance can be shown.

The FAA created the RCCB based on recommendations of the Consistency of Regulatory Interpretation Aviation Rulemaking Committee (CRI ARC). The board’s goal is to provide clarification to FAA personnel, certificate/approval holders and applicants on issues that span the jurisdiction of multiple FAA divisions. In this case, it can provide sensible instruction on the duties and obligations of maintenance providers when performing part replacement.

To read the full submission, click here.

To learn more about the RCCB and ARSA’s recommendations for its development, visit ARSA.org/rccb.

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



More from ARSA

How’s Marshall?

On July 8, ARSA Managing Director & General Counsel Marshall S. Filler underwent successful heart surgery. He is recovering at home and is on track to continue his passion as…Read More

FAA to Restart Global Leadership Meeting

On July 20, the FAA announced plans to host its 8th Annual Global Leadership Meeting in Washington, D.C. on Sept. 22-23. The event will have both in-person and online attendance…Read More

Lawmakers Explore Aviation Workforce Diversity

The House Aviation Subcommittee held a hearing July 20 to discuss enhancing diversity in the aviation workforce. The witnesses were (click a name to download their written testimony): Rebecca Lutte,…Read More

Unpacking AD Authority

On July 2, ARSA requested clarification of the FAA’s authority to issue an Airworthiness Directive, questioning the April 22 posting of an AD against certain Uninsured United Parachute Technologies, LLC…Read More

Training – Parts Documentation Under the U.S.-EU MAG

To see all of ARSA’s work on the MAG, visit arsa.org/mag. For years, ARSA lead an industry wide effort to “smooth” implementation of parts documentation issues in the U.S.-EU Maintenance Annex…Read More
ARSA