ARSA RSS Feed ARSA LinkedIn
Ask ARSA Online Portal

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In practical terms, ARSA stressed the “over-classification” that results from forcing such carriers to follow the outdated Appendix, which dilutes the intended value of the major repair classification and therefore reduces safety.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

Anti-Viral Measures

For the use of its members and the larger aviation community, ARSA is maintaining this page as a resource for virus-related updates on policy initiatives and business needs. Please bookmark…Read More

Aviation Jobs Protection Program Applications Open

To keep tabs on all of ARSA’s work related to the current pandemic, visit arsa.org/anti-viral-measures. On June 15, the U.S. Department of Transportation opened applications for the Aviation Manufacturing Jobs…Read More

Follow Up on Youth Task Force Meeting

On June 9, the FAA held the third public meeting of the Youth Access to American Jobs in Aviation Task Force. ARSA specifically represents repair stations on the body while…Read More

Hotline Highlight – New Bill Would Create U.S. Aviation Advancement Center

The hotline – ARSA’s premier member newsletter – contains news, editorial content, analysis and resources for the aviation maintenance community. All members should ensure they receive their edition the first week of…Read More

Quick Question – Emerging Tech & Inspector Skills

On May 13, the U.S. Government Accountability Office (GAO) released an assessment of FAA workforce planning (for full coverage, visit arsa.org/gao-workforce). In an appendix to the report, the GAO included a list…Read More
ARSA