ARSA RSS Feed ARSA LinkedIn
Ask ARSA Pay ARSA

ARSA Submits Comments on OMB Good Guidance Practices

ARSA has recently submitted comments on a draft bulletin, issued by the Office of Management and Budget (OMB), concerning the issuing of guidance by Federal agencies. The bulletin includes policies and procedures for agencies to develop, issue and use guidance documents.

OMB has been particularly concerned that agency guidance practices should be more transparent, consistent and accountable. Because guidance documents often do not receive the benefit of careful consideration accorded under the procedures for creating regulations, this bulletin stresses that agencies should follow established and effective procedures in developing guidance. This will help ensure that Federal agencies do not engage in rulemaking through guidance.

In its comments, ARSA thanked the OMB for issuing such an important bulletin, and cited examples where the FAA has used guidance documents as rulemaking. Additionally, ARSA made several suggestions which, if adopted, will increase the OMB’s ability to review guidance documents and make them more easily available to the public. These revisions would force agencies to identify affected parties even if documents are labeled as “internal.”

To download a .pdf copy of ARSA’s comments, Click here.

To download a .pdf copy of the OMB draft bulletin, Click here.



More from ARSA

The Dispatch – Jan. 25 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

See the Agenda

March 14-17, 2023 Arlington, Virginia and Washington, D.C. with Livestream Options for Online Participants Sponsors | Event Information | Registration | Hotel Reservations The 2023 Annual Conference agenda is shaping into…Read More

SMS NPRM Issued Without Part 145

On Jan. 11, the FAA issued a long-awaited notice of proposed rulemaking (NPRM) that would update and expand the requirements for safety management systems. The proposal’s applicability does not include…Read More

MacLeod Selected for ODA Panel

On Jan. 5, the FAA notified ARSA it had selected Executive Director Sarah MacLeod to serve on the Organization Designation Authorization Expert Panel. MacLeod will serve the panel as a…Read More

How to Refocus FAA Guidance on the Rules

On Dec. 8, 2022, the working group tasked by the FAA through the Aviation Rulemaking Advisory Committee (ARAC) to review and reconcile U.S. repair station regulations and guidance delivered its…Read More
Schaeffler Aerospace
ARSA