Join ARSA Ask ARSA Pay ARSA

FAA Heeds ARSA Request, Withdraws Memo On Use of Technical Orders and the Alteration of Data Plates

In response to ARSA’s request, the Federal Aviation Administration (FAA) withdrew a controversial memorandum. The memo indicated that a repair station could not change the identification information of a component to reflect an alteration accomplished using the manufacturer’s component maintenance manual (CMM). It also stated that a repair station could not use Technical Orders (TO) to perform maintenance and approve that work for return to service unless the document was approved by an Aircraft Certification Office (ACO). ARSA argued that the regulations allow both actions.

First, § 43.13 allows minor alterations to articles using acceptable methods, techniques and practices identified in a CMM covering multiple dash numbers. Repair stations must then update the end dash number of the article using the CMM or its own acceptable methods when the CMM is silent (§§ 43.13(a), 45.13(d), and 21.611(c)).

Second, TOs are instructions providing methods, techniques and practices for maintaining military aircraft, many of which are now type certificated by the FAA. Therefore, when a TO describes a minor repair or alteration of a type certificated article it needs no further approval (§§ 43.13(b), 145.201(c)(1)). If it describes a major repair or alteration, the technical data supporting the TO is already approved as part of the type certification process (§ 21.31) and also needs no further approval (§ 145.201(c)(2)) from the ACO.

The FAA considered the arguments and agreed to rescind the memo and conduct a proper regulatory evaluation of both issues. ARSA will keep its members posted on any new developments.

ARSA’s letter and proposed revised memo can be viewed here.

The withdrawn FAA memorandum may be found here.

The FAA’s letter rescinding the memo can be found here.



More from ARSA

ARSA Remembers – Dave Harrington

Colonel David R. “Dave” Harrington , a decorated Air Force pilot, Distinguished Flying Cross recipient, former FAA Flight Standards Service director, husband, father, Pop Pop, and friend, died peacefully on…Read More

On Demand Workshop – It All Starts with the Law

The recording of ARSA’s special workshop providing the regulatory and statutory foundation for compliance is available on demand. The resource was presented to FAA personnel as part of the association’s…Read More

On Demand Training – Employee Reporting & Root Cause Analysis

Two Safety Management Systems Training Sessions are now available through ARSA’s training program for registration and immediate on-demand viewing. The trainings were co-administered by ARSA and the Aircraft Electronics Association…Read More

Training Series – Part 145 in Total

In July and August, ARSA will administer a series of online training sessions combining to walk through every section of 14 CFR part 145, “Repair Stations.” The new series replaces…Read More

Digital Attention Dominates FAA/EASA Conference

The 2026 FAA/EASA International Safety Conference returned to the United States with outsized focus on digitalization and artificial intelligence. ARSA’s Christian Klein and Brett Levanto joined several member company representatives…Read More
ARSA