ARSA RSS Feed ARSA LinkedIn
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

Coming Soon On Demand – An Overview of Part 91

On May 31, ARSA Executive Vice President Christian Klein presented an online training session overviewing 14 CFR part 91. Description: This session overviews the general operating rules of 14 CFR…Read More

AMT Day 2023 – Celebrating Charlie

Charles Taylor, the Wright Brothers’ mechanic and father of aviation maintenance, was born on May 24, 1868. Now – 155 years later – we celebrate him with every safe arrival…Read More

GAO Workforce Report Makes Limited Use of Misleading Data

On May 17, the U.S. Government Accountability Office (GAO) released a report on the “Current and Future Availability of Airline Pilots and Aircraft Mechanics.” The GAO’s analysis reads like a…Read More

Live Training Sessions

Stay smart. Stay current. Stay out of trouble with ARSA training.…Read More

Training – Part 43 for Repair Stations

On June 14 at 11:00 a.m. EDT, ARSA Vice President of Operations Brett Levanto will lead an online training session covering 14 CFR part 43 that highlights the interplay between…Read More
Master Air Parts
ARSA