Teaching (your) grandmother to suck eggs is an English saying that refers to a person giving advice to another person in a subject with which the other person should already be familiar.

A July 30 ARSA letter provided regulatory confirmation to the FAA that nothing in the aviation safety rules prohibits independent repairs on articles designed and produced under technical standard order authorizations (TSOA).

The letter catalogued statements made by agency personnel to association member representatives inaccurately claiming limitations on or prohibitions of repairs on such items. For each statement, the letter signed by Executive Director Sarah MacLeod cited parts 1 or 43 to demonstrate definitions and authorization’s confirming the privileges of maintenance providers.

“Many of these roadblocks are based on lack of knowledge and misconceptions,” the letter said about the referenced statements. To remove those “roadblocks,” ARSA repeatedly requested the government read the rules:

(1) § 1.1 defines “maintenance.”

(2) §§ 43.1 and 43.3 grant repair stations the authority to perform maintenance.

(3) § 43.13 allows maintenance actions returning the article to at least its original or properly altered condition.

(4) Determinations on eligibility for installation (based on the definition of “airworthiness” in part 3) are made by persons authorized by part 43.

Reviewing the plain language of these citations confirms the authority of maintenance providers repairing TSOA articles. Focusing on this language prevents confusion caused by misreading the implications of the design and production rules in part 21.

“For future reference, the regulations for maintaining items that have been released from a production approval holder’s quality system are contained in part 43,” the letter said. “The FAA has other rules associated with operating aircraft that individuals in Aircraft Certification may read for personal understanding.”

As ARSA says in its training sessions, reading is required for survival in aerospace.

To read the complete letter, click here.

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