Overhaul Reviewed Yet Again
July 07, 2015
On June 30, the agency issued another legal interpretation on the term “overhaul”—adding to the long list of explanations on the proper use of the term. Again the FAA summarizes the fact that the word can be used in a maintenance record to describe the highest level of work on an article. In other words, there are times that an article need only be cleaned and inspected to be described in a maintenance record as “overhauled.”
ARSA previously addressed the varying uses of the term in the context of component maintenance manuals (CMM), arguing that the regulations—not a manufacturer use of the term in its manual or instructions—dictate when an article is “overhauled.” With this new legal interpretation ARSA will do further research into the origins and appropriate use of the term – stay tuned.
In the meantime, ARSA’s correspondence with the FAA regarding the use of this term can be found:
To see all the ways that ARSA is working as the voice of the aviation maintenance industry, visit the ARSA Works page.
More from ARSA
ARSA, AEA Seek Legally Supportable OpSpecs
On Sept. 10, ARSA and the Aircraft Electronics Association (AEA) continued their combined effort to limit use of “automatically” assigned operations specifications for repair station certificates. “The regulations are clear;…Read MoreSeeking Time for D&A Implementation
September 15, 2026 | Categories:
Act Now, ARSA News & Updates, ARSA Works, Aviation Policy, Drug and Alcohol, EASA, FAA, Legislative, Operations, Press Releases, Regulatory, Rulemaking
On Sept. 10, ARSA and a coalition of industry allies petitioned the FAA to extend the compliance deadline for certain repair stations located outside the United States to institute drug…Read More
Online Training – HazMat Determinations
September 09, 2026 | Categories:
Act Now, ARSA News & Updates, FAA, Maintenance, Operations, Regulatory, Training
On Oct. 14, ARSA will present an online training session introducing the key definitions in 49 CFR tied to hazardous materials requirements for maintenance providers in 14 CFR. The level…Read More
