ARSA RSS Feed ARSA LinkedIn
Ask ARSA Online Portal

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

How’s Marshall?

On July 8, ARSA Managing Director & General Counsel Marshall S. Filler underwent successful heart surgery. His ongoing recovery has included the usual challenges associated with major surgery. As he…Read More

Anti-Viral Measures

For the use of its members and the larger aviation community, ARSA is maintaining this page as a resource for virus-related updates on policy initiatives and business needs. Please bookmark…Read More

DOT Reopens Jobs Program Applications

To keep tabs on all of ARSA’s work related to the current pandemic, visit arsa.org/anti-viral-measures. On July 26, the U.S. Department of Transportation announced it will re-open applications for the…Read More

FAA to Restart Global Leadership Meeting

On July 20, the FAA announced plans to host its 8th Annual Global Leadership Meeting in Washington, D.C. on Sept. 22-23. The event will have both in-person and online attendance…Read More

Lawmakers Explore Aviation Workforce Diversity

The House Aviation Subcommittee held a hearing July 20 to discuss enhancing diversity in the aviation workforce. The witnesses were (click a name to download their written testimony): Rebecca Lutte,…Read More
ARSA