ARSA RSS Feed ARSA LinkedIn
Ask ARSA Pay ARSA

ARSA Suggests Changes to FAA Form 8310-3

The FAA recently solicited comments on Form 8310-3, Application for Repair Station Certificate and/or Rating, as it seeks renewed approval from the Office of Management and Budget (OMB) to collect that information. ARSA submitted comments noting that the current form does not accurately reflect regulatory requirements applicable to the sale or transfer of repair station assets.

As provided in Title 14 of the Code of Federal Regulations (14 CFR) § 145.57(b): “if the holder of a repair station certificate sells or transfers its assets, the new owner must apply for an amended certificate in accordance with § 145.51.” However, verbiage in Form 8310-3 suggests that any change in ownershiprequires an amended certificate. This discrepancy between the rule and the Form creates confusion when an incorporated repair station merely transfers stock, not assets. Section 145.57(b) does not apply to such transactions.

ARSA therefore suggested the Form be changed to state “Sale or Transfer of Assets” instead of “Change in Ownership”. The Association also recommended that the FAA clarify differences between a stock and asset transfer, and provide a statement regarding the inapplicability of § 145.57(b) to company stock transactions, in the pertinent section of Order 8900.1.



More from ARSA

Quick Question – Human Factors Findings for Training Development

Approved maintenance organizations with EASA, TCCA, or ANAC approval must include human factors topics in their training programs. In November 2019, change 7 of the FAA-EASA Maintenance Annex Guidance (MAG)…Read More

FAA and EASA Publish MAG Change 9

On June 20, the FAA and EASA released change 9 to the Maintenance Annex Guidance associated with the bilateral agreement between the two civil aviation authorities. The compliance date for…Read More

Wait & See – The Name Game

Thank you to those who helped with the most pressing element of ARSA’s establishing a complementary 501(c)(3) charitable organization to support aerospace maintenance career development. The new organization will provide a means…Read More

ARSA Leads “Can do” Panel, EASA Shares SMS Compliance Date

From June 11-13, ARSA’s leadership team participated in the 2024 FAA-EASA International Aviation Safety Conference in Washington, DC. The annual event alternates between Cologne and the American capital city as…Read More

Repairman History Points ARAC to Certificate’s Future

On June 13, the FAA Aviation Rulemaking Advisory Committee (ARAC) received the final report of its Repairman Certificate Portability Working Group. The report includes thorough regulatory analysis in response to…Read More
ARSA