Join ARSA Ask ARSA Pay ARSA

ARSA Looks for Proper FAA Interpretation of Rules for Major Repair

ARSA requested that the Federal Aviation Administration (FAA) reconsider its position regarding the applicability of “automatically defined” major repairs listed in Title 14 of the Code of Federal Regulations (14 CFR) part 43, Appendix A. To remedy the issue, ARSA’s Dec. 7 letter asks the agency to issue a new legal interpretation to resolve existing confusion and reverse misunderstandings resulting from the FAA’s previous denials of air carrier petitions on the matter.

Specifically, ARSA points out the relationship between the rules for part 121 and part 135 air carriers with continuous airworthiness maintenance programs (CAMP) to the maintenance requirements in part 43. Namely, that the elevated safety standards for those carriers and the rigid structure provided by a CAMP obviate the need for Appendix A, as reflected in the plain language of part 43. The result is a plain direction to follow the CAMP, without considering the Appendix.

In practical terms, ARSA stressed the “over-classification” that results from forcing such carriers to follow the outdated Appendix, which dilutes the intended value of the major repair classification and therefore reduces safety. (That is, “if everything is important, then nothing is important”.)

ARSA looks forward to the FAA Chief Counsel’s response.

~~~ posted 12/20/11 ~~~



More from ARSA

September SMS Webinar – Emergency Response Plans

On Tuesday, Sept. 29, ARSA and the Aircraft Electronics Association (AEA) will host the next session in their webinar series explaining integration of a safety management system within the operations…Read More

ARSA, AEA Seek Legally Supportable OpSpecs

On Sept. 10, ARSA and the Aircraft Electronics Association (AEA) continued their combined effort to limit use of “automatically” assigned operations specifications for repair station certificates. “The regulations are clear;…Read More

Seeking Time for D&A Implementation

On Sept. 10, ARSA and a coalition of industry allies petitioned the FAA to extend the compliance deadline for certain repair stations located outside the United States to institute drug…Read More

Online Training – HazMat Determinations

On Oct. 14, ARSA will present an online training session introducing the key definitions in 49 CFR tied to hazardous materials requirements for maintenance providers in 14 CFR. The level…Read More

Joint Comments Differentiate Between Authorization and Rating

On Sept. 1, ARSA and the Aircraft Electronics Association (AEA) jointly submitted comments to the FAA’s notice of proposed rulemaking to eliminate the need for a mechanic that holds an…Read More
ARSA