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ARSA Submits Comments to FAA Draft Advisory Circular 120-CMP

Last month, in draft Advisory Circular (AC) 120-CMP, the Federal Aviation Administration (FAA) proposed guidance outlining the regulatory interface between air carriers and their maintenance providers. In its comments to the draft, ARSA recommended a number of substantive changes in the form of a largely rewritten AC.

The association sought to clarify the fact that although an air carrier is responsible for ensuring that the work on its aircraft and other articles is performed in accordance with its program and the applicable sections of its manual, a certificated repair station is responsible for the actual performance of the work when it has been contracted by the carrier to provide those services. Other major points ARSA rectified in its rewrite of the draft include the removal of language regarding the proposition that an air carrier needs to “approve” sub-contractors of a certificated repair station, and eliminating the idea that appropriately certificated and authorized repair stations are not able to complete a logbook entry or airworthiness release.

In addition, ARSA added language to better define the framework of a proper regulatory relationship between an air carrier and its maintenance provider. Along those lines, the rewritten draft AC includes a series of questions to help an air carrier evaluate its maintenance program and manual to ensure appropriate information is communicated to its maintenance provider, based on the specific work being performed.

ARSA’s comments are available here. The comments include links to two versions of the draft AC, one with all the tracked changes and another with those changes accepted.



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