ARSA Requests ICA Legal Interpretation
May 18, 2009
On May 18, 2009, ARSA submitted a request for interpretation to the Federal Aviation Administration’s (FAA) Office of Chief Counsel regarding maintenance manuals or instructions referenced in the Airworthiness Limitations Section (ALS) of Instructions for Continued Airworthiness (ICA). The Association asked the FAA to recognize that:
1. All component maintenance manuals (CMM) referenced in the ALS are a required part of the ICA;
2. Modifications to the ALS made after January 28, 1981 are changes in the type design that trigger the ICA requirements in 14 CFR § 21.50(b); and therefore,
3. Design approval holders must make the ALS and referenced CMMs available to properly rated repair stations.
The request was spurred in part by the Special Federal Aviation Regulation (SFAR)-88 requirements mandating design approval holders develop design changes along with maintenance and inspection instructions to maintain ignition source prevention features in fuel tanks. In many cases the instructions are contained in an amended ALS that directly references CMMs as the source of the information.
ARSA looks forward to the FAA’s response and will keep its members updated on any developments.
Click here to read the Association’s request.
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