Join ARSA Ask ARSA Pay ARSA

ARSA Submits Comments on OMB Good Guidance Practices

ARSA has recently submitted comments on a draft bulletin, issued by the Office of Management and Budget (OMB), concerning the issuing of guidance by Federal agencies. The bulletin includes policies and procedures for agencies to develop, issue and use guidance documents.

OMB has been particularly concerned that agency guidance practices should be more transparent, consistent and accountable. Because guidance documents often do not receive the benefit of careful consideration accorded under the procedures for creating regulations, this bulletin stresses that agencies should follow established and effective procedures in developing guidance. This will help ensure that Federal agencies do not engage in rulemaking through guidance.

In its comments, ARSA thanked the OMB for issuing such an important bulletin, and cited examples where the FAA has used guidance documents as rulemaking. Additionally, ARSA made several suggestions which, if adopted, will increase the OMB’s ability to review guidance documents and make them more easily available to the public. These revisions would force agencies to identify affected parties even if documents are labeled as “internal.”

To download a .pdf copy of ARSA’s comments, Click here.

To download a .pdf copy of the OMB draft bulletin, Click here.



More from ARSA

Support Simplifying New D&A Rules

On Nov. 26, ARSA submitted a petition for reconsideration of the denied industry effort to help the FAA simplify its new rule requiring drug and alcohol testing programs at repair…Read More

IATA PMA Adoption Webinar Recording Available

On Nov. 19, the International Air Transport Association’s (IATA) dedicated advisory group on “alternative aerospace materials” hosted a webinar reviewing the air carrier “practices and perceptions” revealed by the association’s…Read More

FAA Updates Public “Services & Contacts” for Office of Safety Standards

The FAA Office of Safety Standards has updated its “Services and Contacts” directory, which is available as a downloadable PDF. The document includes names, contact emails, and office numbers for…Read More

SMS Integration Webinar Series Continues Dec. 16

On Nov. 18, ARSA and the Aircraft Electronics Association presented the second of six planned webinars – a monthly series stretching into March 2026 – explaining effective integration of a…Read More

Register for FAA’s AMT/Repair Station Safety Stand Down

On Dec. 3 and 4, the FAA will host a series on online safety seminars targeted at technicians (IA renewal credit available) and other repair station personnel. The “Safety Stand…Read More
ARSA