Join ARSA Ask ARSA Pay ARSA

FAA Heeds ARSA Request, Withdraws Memo On Use of Technical Orders and the Alteration of Data Plates

In response to ARSA’s request, the Federal Aviation Administration (FAA) withdrew a controversial memorandum. The memo indicated that a repair station could not change the identification information of a component to reflect an alteration accomplished using the manufacturer’s component maintenance manual (CMM). It also stated that a repair station could not use Technical Orders (TO) to perform maintenance and approve that work for return to service unless the document was approved by an Aircraft Certification Office (ACO). ARSA argued that the regulations allow both actions.

First, § 43.13 allows minor alterations to articles using acceptable methods, techniques and practices identified in a CMM covering multiple dash numbers. Repair stations must then update the end dash number of the article using the CMM or its own acceptable methods when the CMM is silent (§§ 43.13(a), 45.13(d), and 21.611(c)).

Second, TOs are instructions providing methods, techniques and practices for maintaining military aircraft, many of which are now type certificated by the FAA. Therefore, when a TO describes a minor repair or alteration of a type certificated article it needs no further approval (§§ 43.13(b), 145.201(c)(1)). If it describes a major repair or alteration, the technical data supporting the TO is already approved as part of the type certification process (§ 21.31) and also needs no further approval (§ 145.201(c)(2)) from the ACO.

The FAA considered the arguments and agreed to rescind the memo and conduct a proper regulatory evaluation of both issues. ARSA will keep its members posted on any new developments.

ARSA’s letter and proposed revised memo can be viewed here.

The withdrawn FAA memorandum may be found here.

The FAA’s letter rescinding the memo can be found here.



More from ARSA

Quick Question – SMS Lessons

ARSA and the Aircraft Electronics Association continue to explore safety management system integration. Share your repair station’s SMS implementation experiences in this month’s “quick question.” Feedback will be used, without…Read More

Celebrating Charlie with Fortner, AAR

Charles Taylor, the Wright Brothers’ mechanic and father of aviation maintenance, was born on May 24, 1868. Now – 158 years later – we celebrate him through continued commitment to…Read More

ARSA Alerts Congress to Designee Class Action Suit

On May 28, ARSA Executive Vice President Christian Klein informed congressional staff of an ongoing lawsuit against the FAA alleging violations of the Administrative Procedure Act and the Fifth Amendment…Read More

June SMS Webinar – Root Cause

On Tuesday, June 23, ARSA and the Aircraft Electronics Association (AEA) will co-host the next session in their webinar series explaining integration of a safety management system within the operations…Read More

Learning Aerospace Through ARSA

The recording of ARSA’s special workshop for introducing government personnel to the maintenance industry is now available for open registration and viewing. The on-demand resource is a valuable tool for…Read More
ARSA