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Further Clarifying Part 145 using “Current Data” Proposal

On May 1, ARSA and three other trade associations commented on the FAA’s notice of proposed rulemaking addressing “miscellaneous maintenance-related updates.” The NPRM would remove the requirement from § 145.109 that repair stations maintain “current and accessible” versions of certain documents and data; it would also clarify language in §§ 145.201 and 145.217 regarding the privilege of contracting maintenance functions.

The group praised the FAA’s proposal, noting “[the] agency and industry have struggled with inconsistent language within part 145 for many years. [ARSA and its allies] strongly support making the language in part 145 consistent and clarifying the verbiage and intent.”

The comments showed that support by highlighting several points in part 145 the rulemaking can also amend to improve consistency and clarity. These edits would align the responsibilities of applicants and certificate holders regarding data availability and also match the standard in § 43.9(a)(4) that maintenance providers approve only the work performed on an article for return to service.

The comments provide suggested edits to the following sections: §§ 145.5, 145.51, 145.53, 145.101, 145.109, 145.201, 145.205, 145.211, 145.217, 145.219, and 145.223.

To review the complete comments, click here.

To see the 2010 legal interpretation referenced in the comments, click here.

In addition to ARSA, the submission was supported by the Aircraft Electronics Association, the Aviation Suppliers Association, and the Modification and Replacement Parts Association.

More on the 'Current' Data Effort...

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While ARSA leads the effort to eliminate the requirement, share your experiences regarding “current” maintenance data requirements through the following “quick question”:



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