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

The Dispatch – Feb. 1 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

Quick Question Explored – SMS Proposed Rule

In January, the FAA issued its long awaited notice of proposed rulemaking (NPRM) that would update and expand the requirements for safety management systems. Despite the proposal’s (thankful) omission of…Read More

Industry Seeks Relief from Bilateral Parts Documentation Squeeze

On Jan. 31, ARSA coordinated submission of a letter to FAA and EASA executives seeking to correct misinterpretation of aircraft parts documentation requirements under the U.S./EU bilateral aviation safety agreement…Read More

Sponsor Salute

March 14-17, 2023 Arlington, Virginia and Washington, D.C. with Livestream Options for Online Participants Sponsors | Event Information | Registration | Hotel Reservations Thank you to the 19 organizations that have…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
Master Air Parts
ARSA