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In practical terms, ARSA stressed the “over-classification” that results from forcing such carriers to follow the outdated Appendix, which dilutes the intended value of the major repair classification and therefore reduces safety.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

The Dispatch Distro – Nov. 30 Edition

The Dispatch – ARSA’s open-subscription weekly newsletter – provides a central communication for key updates to the global aviation maintenance community. All member contacts, industry allies and subscribers should receive…Read More

Quick Question – 2023 Conference Planning

March 14-17, 2023 Arlington, Virginia and Washington, D.C. with Livestream Options for Online Participants Event Information | Registration The repair station community’s premier substantive event returns; help ARSA’s team plan…Read More

Klein Chronicles Workforce Initiatives for Purdue Symposium

On Nov. 8, ARSA Executive Vice President Christian Klein spoke at Purdue University’s inaugural National Aviation Symposium. Klein headlined a panel on national industry workforce demand, presenting on trends in…Read More

OIRA Building Next Open Government Action Plan

On Nov. 17, ARSA Vice President of Operations Brett Levanto joined an engagement session hosted by the U.S. Office of Information and Regulatory Affairs (OIRA) soliciting input on improving participation…Read More

UK Approval Applications Open in January

On Nov. 15, the FAA hosted a webinar on the Maintenance Implementation Procedures (MIP) and Maintenance Agreement Guidance (MAG) established between the United Kingdom (UK) and United States (US). The…Read More
ARSA