In a June 19 letter, the FAA addressed ARSA’s request for guidance regarding the identification that should be referenced in maintenance records when more than one production approval holder number is applied to a part.
While the FAA issued a partial response to the association’s request, it did not address the requirements that a maintenance provider understand and know the part it is receiving vis-à-vis the data needed to ensure work is performed properly. It is commendable that the agency’s guidance in Order 8130-21H partially addresses the issue; however, the responsibility of a maintenance provider is contained in part 43 (and for repair stations, part 145). Those regulations require appropriate actions by the maintenance provider in spite and despite “instructions from the customer.” The association will work with the agency to ensure the interrelated regulatory responsibilities and nuances are understood and addressed.
Stay tuned for further coverage.
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Previously from ARSA…
May 22, 2014
On May 21, ARSA submitted a follow-up letter to the Federal Aviation Administration (FAA) requesting guidance regarding the identification that should be referenced in maintenance records when more than one production approval holder number is applied to a part. The association first contacted the FAA about this matter in October 2011. Within a month of that initial submission, the agency expressed shared concern regarding the presence of multiple part numbers. Although the FAA said it planned to review and revise affected policy and guidance as necessary, no such updates were made.
In its new letter, ARSA recommended that the FAA issue the association’s draft joint Information for Operators (InFO), which outlines an acceptable method of (1) recording part numbers in an article’s maintenance record consistent with Order 8130-21, and (2) listing articles by part number on a limited rated part 145 repair station capability list. In all cases, the maintenance provider must be able to recognize the part marking and place correct identification on the § 43.9(a)(4) approval for return to service.
December 9, 2011
In response to an ARSA request, the FAA will review agency policy and guidance regarding part identification when more than one number is applied to a part at production.
In a Dec. 6, 2011 letter, FAA Aircraft Maintenance Division Manager Steven Douglas stated that the FAA, “[shares ARSA’s] concern that the presence of multiple part numbers may cause confusion when maintaining such parts and interfere with recordkeeping.”
The Agency plans to review “affected FAA policy and guidance and revise them as necessary,” including Order 8130.21, Procedures for Completion and Use of Authorized Release Certificate.
November 8, 2011
In an Oct. 19, 2011 letter, ARSA Executive Director Sarah MacLeod raised member concerns about the identification that should be referenced in maintenance records when more than one number is applied to a part at production.
The letter outlined issues multiple part identifications create for repair stations. Most often, inspectors question whether the certificate holder is following its own procedure, holds appropriate ratings and has proper maintenance data when its capability list (CL) contains part numbers rather than manufacturer make and model (i.e., the CL does not include all potential part numbers for a particular article). Problems also arise when customers do not include “dual” part numbers on commercial and regulatory documentation.
ARSA recommended that the FAA issue guidance in the next revision to Order 8130.21, or, alternatively, update Advisory Circular 43-9 to reflect current practices relating to maintenance records issued by persons authorized to approve work for return to service under § 43.3. ARSA will continue to work with FAA officials to resolve the issue.
