ARSA Works: FAA Affirms Part Recovery Rights
On Aug. 25, the FAA affirmed ARSA’s contention that a repair station’s rating allows it to make “continue-in-service” determinations on internal or attached articles.
The acknowledgement came in response to a July 9 letter sent by the association to the Aircraft Maintenance Division regarding the removal and reinstallation of components – a practice also affectionately referred to as “salvaged part,” “cannibalized part,” “serviceable part” or “part recovery.”
The original letter was initiated after a member received a letter of investigation questioning the repair station’s utilization of a recovered parts procedure. In it, ARSA asserted the right of certificated entities to review, visually inspect, check or test sub articles to determine if they are “serviceable as removed” from a top assembly. Once this assessment is made, ARSA contended, the part can be used in any assembly under maintenance or placed into stock.
In its response, the FAA agreed: “The privileges and limitations of repair stations, under Title 14 Code of Federal Regulations (14 CFR) sections 43.3(e), 43.7(c) and 145.201, allow for the performance of maintenance on all articles for which they are rated.” Holding ratings for “top assembly” articles, the agency continued, signifies qualification to maintain all “sub-articles.” Based on this foundation, the response concluded that repair stations can implement procedures to perform inspections, tests and other maintenance in compliance with part 43 on sub-articles and place them in stock for future use.
To read the complete response, click here.
Previously from ARSA...
July 14, 2015
On July 9, ARSA delivered a letter to the FAA aircraft maintenance division regarding the removal and reinstallation of components – a practice affectionately referred to as “salvaged part”, “cannibalized part”, “part recovery” or “continue-in-service” processes.
ARSA asserted that a repair station’s rating allows it to make continue in service determinations on internal or attached articles. These determinations are accomplished by reviews, visual inspections, checks or tests of sub-articles to determine if they are “serviceable as removed.” If no further maintenance actions or steps are required, the part can be used in the assembly under maintenance, another assembly or be placed into stock for future use.
The letter was initiated after an ARSA member received a letter of investigation questioning the repair station’s utilization of a recovered parts procedure. Contrary to the local office’s position, a rating for each type of article being reviewed, inspected or tested is unnecessary.
When a continue in service review performed during incoming inspection or during the course of maintenance on the “rated” article reveals that repairs or alterations must be performed, then the repair station must have the proper rating to perform the necessary work on the sub-article.
To see all the ways ARSA is working as the voice of the aviation maintenance industry, visit the ARSA Works page.