Join ARSA Ask ARSA Pay ARSA

Ask and You Shall Receive

On March 8, ARSA sent a letter to the FAA requesting that the agency clarify (or, re-clarify) that fabrication of a part is not maintenance.

ARSA’s appeal was driven by several members who recently contacted the association with issues regarding the manufacture of detail parts by maintenance personnel and local inspector interpretations of that practice. With the issue was clearly addressed by a previous legal interpretation from the FAA Office of Chief Counsel and is supported by existing agency guidance, it became apparent that the confusion resulted from individual FAA inspector misunderstandings.

The inspector misinterpretations resulted in claims that a repair station was contracting maintenance functions without FAA approval and not performing maintenance according to regulations. By wrongly categorizing fabrication as maintenance, the FAA was shifting industry focus away from proper execution of the task.

As a result, ARSA asked the FAA to ensure that its front-line inspectors were fully aware of the current policy regarding part fabrication by maintenance providers.

On March 22, the FAA responded, agreeing with the association. “Your understanding on the act of fabrication is correct. It is not considered maintenance,” said Manager Carol E. Giles of the FAA’s Aircraft Maintenance Division.

Giles further advised ARSA that on April 16, 2011, the second compliance date for the revised Title 14 CFR part 21 will become effective and it specifically includes a section addressing part fabrication by an appropriately rated certificate holder.



More from ARSA

Good Maintenance Cheer this Holiday Season

The office of ARSA’s management firm will be closed from Dec. 24, 2024 to Jan. 2, 2025. Periodicals will not be distributed on these dates, but the association continues collecting…Read More

FAA Requires Foreign D&A Testing by 2027

On Dec. 18, the U.S. Federal Register published the FAA’s long-awaited final rule expanding drug and alcohol testing requirements to repair station personnel outside the United States. The new rule…Read More

Don’t Be Ignored – STC Audit Survey

Congress’ May 2024 reauthorization of the FAA, requires the Department of Transportation’s Office of Inspector General (OIG) to audit the FAA’s Flight Standards and Aircraft Certification Services (see P.L. 118-63,…Read More

2025 ARSA Annual Conference

March 18-21, 2025 Event Information | Registration | Hotel  Arlington, Virginia and Washington, D.C. with Livestream Options for Online Participants Experience the international aerospace maintenance community’s premier event. Join ARSA members…Read More

Clarifying (by Dividing) Recordkeeping Guidance

On Nov. 19, ARSA submitted a pair of draft advisory circulars for FAA consideration to replace its proposed update to AC 43-9, Maintenance Records. The documents divide overlapping responsibilities previously…Read More
ARSA