On Demand: Contract Maintenance – Functions and Vendors
This session provides information on obtaining approval of maintenance functions and selecting and categorizing maintenance function vendors properly under 14 CFR part 145.
Instructor: Sarah MacLeod
On Demand – Available Anytime
Registration for an ARSA-provided training session includes:
- Access to the on-demand, recorded version of the webinar to be made available after the live session is complete (or at time of purchase, for on-demand classes).
- A copy of the presentation and all reference material with links to relevant resources and citations.
- Upon completion of the class as well as any test material, a completion certificate.
The association’s training program is provided through Obadal, Filler, MacLeod & Klein, P.L.C., the firm that manages ARSA. To go directly to OFM&K’s online training portal, visit PotomacLaw.inreachce.com. To learn more about the association’s training program and see course availability, visit arsa.org/training.
Previously from ARSA
September 29, 2015
On Sept. 22, the Federal Aviation Administration (FAA) released two draft revised advisory circulars (AC’s) updated to reflect the agency’s air carrier contract maintenance requirements regulation. The rule takes effect on March 4, 2016.
Proposed revisions to “Certificate Holder Maintenance Programs” (AC 120-16G) and “Scope and Recommended Content for a Contractual Agreement Between a Certificate Holder and a Maintenance Provider”(AC 120-106A) reiterate the regulations’ requirements for air carriers and maintenance providers performing “covered work.”
The draft ACs also outline the means for submitting maintenance provider list (MPL) as required by the rule. Air carriers must provide to FAA certificate-holding district offices (CHDO) a list of maintenance providers, including the name and physical (street) address or addresses where each maintenance provider performs work for the certificate holder and a description of the type of maintenance, preventive maintenance or alteration the provider will perform at each location.
The FAA details the manner that the MPL must be provided to the agency. There are two acceptable templates available to air carriers: MPL Template-Excel and MPL Template-XML. Both can be downloaded from the Flight Standards Service Aircraft Maintenance Division (AFS-300) web site under the AFS-300 Job Aids section.
Comments on the drafts are due by Oct. 21. ARSA is working with its air carrier partners to ensure the rule’s implementation has minimal burden on the industry.
For an ARSA document detailing the mandates and restrictions of the new regulation and other information, review the material below.
June 2, 2015
On June 2, ARSA released a document detailing the mandates and restrictions imposed by the new air carrier contract maintenance rule, which takes effect on March 4, 2016.
ARSA worked diligently, both on the regulatory and the legislative fronts, to ensure the relationship between repair stations and air carriers would remain unchanged by the new rule. Consequently, most of the new mandates already exist and the impact on the aviation maintenance community should be minimal.
On May 28, ARSA hosted a webinar to overview the implications of the new rule and discuss compliance issues. An on-demand recording of that webinar is available for purchase. To access the recording, click here.
May 4, 2015
For a full account of ARSA’s regulatory and legislative activities surrounding this congressionally-mandated regulation, see:
March 23, 2015
On March 4, the FAA unveiled a congressionally-mandated rule on air carrier contract maintenance requirements. The association has been engaged for years on Capitol Hill and with regulators to mitigate the rule’s impact on repair stations and their airline customers.
The following resources have been produced to assist industry members in interpreting the new rule and understanding its development:
- Comparison between the proposed and final rule.
- Comparison of Sec. 310, FAA Reauthorization Act (H.R. 915) and Sec. 319, FAA Modernization & Reform Act (as enacted).
- Contract Maintenance Requirements Timeline (from Dec. 1997 to Mar. 2015).
To see all of the ways ARSA is working on behalf of the aviation maintenance industry, please visit the ARSA Works page. For more reference material and compliance information, visit the association’s resource page.
March 5, 2015
On March 4, the FAA unveiled a congressionally-mandated rule on air carrier contract maintenance requirements.
The action was commanded by the FAA Modernization & Reform Act of 2012 (Public Law 112–95 (February 14, 2012)). While unnecessary, Congress was compelled to “do something” about Department of Transportation Office of Inspector General reports (2003, 2005, 2008) criticizing the FAA’s oversight of air carriers’ contract maintenance programs.
ARSA’s actions on the legislative and regulatory fronts have ensured minimal disruption to airlines and repair stations. Beginning with recommending legislative language (and successfully lobbying to enact it), the association then worked with its airline colleagues and the FAA on parallel changes to OpSpec D091. Finally, when the mandated rule was proposed, ARSA comments helped the FAA adhere to congressional intent and the statute’s plain-language.
The work ARSA did on your behalf ensured this government regulation will have a minimal impact.
March 4, 2015
ARSA will be working with its airline colleagues to ensure a smooth transition is achieved. The association’s 2013 comments to the notice of proposed rulemaking can be found here.
November 14, 2012
On Nov. 13, the FAA issued a notice of proposed rulemaking regarding the relationship between contract maintenance providers and air carriers that operate aircraft with 10 or more seats.
The proposal is a direct result of congressional action. Sec. 319 of the FAA Reauthorization and Reform Act of 2012 (enacted on February 14, 2012) mandated the FAA to issue regulations regarding who may perform “covered work” on aircraft used to provide air transportation. ARSA aggressively lobbied Congress on the provision to ensure effective oversight of maintenance providers without undermining the efficiency of the industry.
The NPRM would require operators to develop policies, procedures, methods, and instructions for performing contract maintenance, and to include them in their maintenance manuals. This would ensure that operators are able to maintain consistent control and oversight over the maintenance of their aircraft. While the reauthorization law only referenced part 121 air carriers, the rulemaking would expand the same requirements to include part 135 operators of aircraft with 10 or more seats.
Recognizing that repair stations have faced difficulty gaining consistent access to the relevant portions of a carrier’s manual, the proposed regulation requires air carriers or commercial operators to provide the repair station performing work with the applicable portions of its maintenance manual. This remains consistent with the air carriers’ retaining primary responsibility for aircraft and supports the concept that the provider is an extension of the air carriers’ maintenance program when a repair station performs work.
The proposed rule would define “maintenance provider” to avoid the confusion between certificated and non-certificated personnel, and would define a maintenance provider as “any person who performs maintenance, preventive maintenance, or an alteration for a certificate holder other than a person who is trained by and employed directly by that certificate holder.”
Finally, the proposed rulemaking mandates that part 121 and 135 operators maintain a complete and comprehensive list of each party with which it contracts maintenance and a description of the work performed. Such a catalog is intended to help the FAA allocate oversight resources as appropriate, ensuring a risk based inspection regime that does not hinder repair station efficiency.
The Association will be closely reviewing the rule over the coming weeks to ensure that the proposal is free of any unintended consequences. These new regulations would take effect one year after the publication of the final rule in the Federal Register.
For a document comparing Sec. 319 of the FAA Modernization & Reform Act to the NPRM, please click here.
ARSA strongly encourages all repair stations to closely review the proposed regulations and submit comments before the
February 11, 2013 deadline March 13, 2013.
~~ Updated 2/12/2013: New comment deadline ~~