In a recent letter to the Federal Aviation Administration (FAA), ARSA suggested the agency adopt guidance on the use of a “current inspection program recommended by the manufacturer” under Title 14 CFR § 91.409(f)(3). In response the FAA issued an Information for Operators (InFO) Which clarifies that an operator must properly adopt a program under 14 CFR section 91.409(e) that is “current” at that time (the time of the adoption). While some may claim that the INFO carries no “weight”, the fact that it clearly defines the regulatory requirement that was not addressed in the interpretation of section 91.409(f) makes it valid and applicable.
When a proper selection or identification is not made the maintenance provider is required to use the program recommended by the manufacturer at the time of the inspection. Further the InFO states that owner/operators cannot retroactively select an inspection program and must provide maintenance facilities with properly selected programs that are different from the program recommended by the manufacturer at the time of the inspection.
A copy of the InFO guidance may be found here.
