May 29, 2014

ARSA joined its member, Metal Improvement Company LLC,  in submitting a letter under the Federal Aviation Administration’s (FAA) Consistency and Standardization Initiative (CSI) regarding (1) a repair station’s ability to develop and use work instructions and (2) the exact requirements for accessibility of relevant maintenance data during the performance of maintenance functions.

The Miami Flight Standards District Office (FSDO) and the FAA’s Southern Region Office previously determined that the use of internally developed work instructions, even with only minor differences from manufacturer information, was unacceptable without prior FAA approval. The local and regional offices also determined personnel must have “physical possession” of the manufacturer’s maintenance data even if it was not relevant to the work being performed.

The Code of Federal Regulations (CFR) states repair stations must ensure maintenance functions are performed in accordance with part 43. The agency has repeatedly clarified (e.g., Order 8900.1 and AC 120-77) that work instructions are acceptable as long as they return the article to its original or properly altered condition. Pre-approval is unnecessary unless the instruction results in a major repair or alteration.

A 2010 legal interpretation from the FAA acknowledged that part 145.109(d) only requires manufacturer’s technical data to be “accessible” and that there will be instances when it will not be used. Additionally, “physical possession” is certainly not required when the repair station’s work instructions contain all of the elements for performing the work in compliance with part 43.

The CSI requests that the FAA confirm that repair stations may create work instructions for its technical personnel and that the manufacturer’s maintenance data need only be “accessible” when relevant work is being performed. The CSI letter recommends that the FAA issue an advisory circular that elaborates on the development and use of work instructions based on parts 21, 43 and 145.