Join ARSA Ask ARSA Pay ARSA

ARSA Comments on FAA’s Interpretation of Duty & Rest Provisions

On June 14, ARSA submitted comments to the FAA’s “proposed” interpretation of duty and rest provisions for maintenance personnel. The agency’s new position effectively eliminates the language in 14 CFR § 121.377 that requires one day off during any seven consecutive days “or the equivalent thereof within any one calendar month”.

Although characterized as a proposal, the FAA had previously issued the interpretation on May 18, 2010. In fact, the FAA’s stated basis for requesting comments was ARSA’s December 13, 2010 letter calling for withdrawal of the new interpretation.

ARSA’s letter noted that the interpretation conflicted with earlier FAA interpretations, long-standing policy and the plain language of the existing rule. The association noted that the new interpretation was, in effect, rulemaking without public notice and comment required by the Administrative Procedure Act. The FAA responded that it would not withdraw the interpretation, but would instead seek comments before deciding to modify or rescind the May 18 interpretation.

ARSA’s latest comments point out that the FAA’s interpretation impermissibly creates a de facto new duty time regulation under the cover of interpreting an existing rule, and therefore circumvents the rulemaking process. As a result, the association again asks for withdrawal of the May 18 interpretation.

~~~ posted 06/17/11 ~~~



More from ARSA

2025 Annual Conference – Going Platinum

March 18-21, 2025 Event Information | Registration | Sponsors Arlington, Virginia and Washington, D.C. with Livestream Options ARSA thanks each of these eight companies for the strength of spirit they continue…Read More

U.S. Bilateral Update Requires SMS Compliance

On Feb. 10, the Bilateral Oversight Board (BOB) for the U.S.-European Union (EU) bilateral aviation safety agreement (BASA) issued Decision No. 13. It amends BASA Annex 2 to require U.S.-based…Read More

ARSA Survey Invite Sent

On Feb. 21, an invitation to complete ARSA’s member survey was sent to the email address of every primary contact. The message was subjected “Invitation to Complete ARSA’s Annual Member…Read More

ARSA Helps CNBC Illustrate Career Development “Challenge”

On Feb. 14, CNBC published a 12 minute special addressing the workforce and career development challenges facing the maintenance industry. ARSA Executive Director Sarah MacLeod participated, lending a voice to…Read More

ARSA Joins Workforce Grant Application

On Feb. 5, the aviation non-profit Choose Aerospace, which administers ARSA’s annual scholarship in addition to providing a maintenance-focused curriculum for student and employee development programs, included the association on…Read More
ARSA