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

Learning Aerospace Through ARSA

The recording of ARSA’s special workshop for introducing government personnel to the maintenance industry is now available for open registration and viewing. The on-demand resource is a valuable tool for…Read More

SMS Webinar Series – Employee Reporting (Recording in Production)

On Tuesday, May 26, ARSA and the Aircraft Electronics Association (AEA) continued their webinar series explaining integration of a safety management system within the operations of an FAA-certificated repair station.…Read More

Foreign D&A Compliance Toolkit

ARSA calls for its foreign members (except those located in Canada) to utilize the association’s new Foreign Repair Station Drug & Alcohol (D&A) Compliance Toolkit by following these steps: (1)…Read More

Industry Can Help Itself with New D&A Tools

ARSA challenges its members to utilize the association’s new Foreign Repair Station Drug & Alcohol (D&A) Compliance Toolkit. The Compliance Toolkit provides basic information regarding the FAA’s expansion of D&A…Read More

Review ACS Recommendations

Assess the recommended update to the Airman Certification Standards for maintenance technicians. The ACS has been incorporated by reference into the rules associated with training and mechanic certification and is…Read More
ARSA