On April 20, ARSA received a positive response from the FAA to a May 29, 2014 request for clarification of (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.
It its response, the agency agreed with each of ARSA’s recommendations and specifically confirmed that a repair station may create work instructions for its technical personnel. “An appropriately certificated and rated repair station may develop its own work instructions/shop travelers based on manufacturer’s maintenance data and/or other methods, techniques and practices acceptable to the FAA,” the letter said.
Prior to this clarification, the Miami Flight Standards District Office (FSDO) and the FAA’s Southern Region Office had determined the use of internally developed work instructions, even with only minor differences from manufacturer information, was unacceptable without prior FAA approval.
The FAA also contradicted the determination of the local and regional offices that personnel must have “physical possession” of the manufacturer’s maintenance data even if it was not relevant to the work being performed. The FAA agreed with ARSA that – as stated in 14 CFR part 145.109(d) – appropriate documents must only be “current and accessible when the relevant work is being done.”
The success of ARSA’s request, which had been jointly submitted by Metal Improvement Company LLC, eliminates an unnecessary limitation placed on southern region repair stations without regulatory foundation.
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.
To see all the ways that ARSA is working as the voice of the aviation maintenance industry, visit the ARSA Works page.
