ARSA RSS Feed ARSA LinkedIn
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In practical terms, ARSA stressed the “over-classification” that results from forcing such carriers to follow the outdated Appendix, which dilutes the intended value of the major repair classification and therefore reduces safety.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

Repairman History Points ARAC to Certificate’s Future

On July 19, the FAA Aviation Rulemaking Advisory Committee (ARAC) delivered the final report of its Repairman Certificate Portability Working Group to FAA Rulemaking Executive Director Brandon Roberts after its…Read More

Poring Over MAG Change 9

In June, the FAA and EASA published change 9 to the Maintenance Annex Guidance issued under the bilateral agreement between the two civil aviation authorities. As described in the summary…Read More

Quick Question – Human Factors Findings for Training Development

Approved maintenance organizations with EASA, TCCA, or ANAC approval must include human factors topics in their training programs. In November 2019, change 7 of the FAA-EASA Maintenance Annex Guidance (MAG)…Read More

Wait & See – The Name Game

Thank you to those who helped with the most pressing element of ARSA’s establishing a complementary 501(c)(3) charitable organization to support aerospace maintenance career development. The new organization will provide a means…Read More

ARSA Leads “Can do” Panel, EASA Shares SMS Compliance Date

From June 11-13, ARSA’s leadership team participated in the 2024 FAA-EASA International Aviation Safety Conference in Washington, DC. The annual event alternates between Cologne and the American capital city as…Read More
ARSA