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The withdrawn FAA memorandum may be found here.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

Final Rule Alleviates “Current Data” Burden

On Nov. 10, the Federal Register published the FAA’s final rule “Inspection Programs for Single-Engine Turbine-Powered Airplanes and Unmanned Aircraft; and Miscellaneous Maintenance-Related Updates.” Included in those “miscellaneous updates” are: (1) Removal…Read More

Repair Station Radio Podcast – “Swimming the Current”

The association’s team returns for a full 20 minutes (and a few seconds) to talk about the “miscellaneous maintenance updates” in a recently issued FAA Final Rule removing the “current”…Read More

President McHugh Finds Fresh Faces and Familiarity on ARSA Board

On Oct. 30, ARSA’s Board of Directors gathered for its annual meeting in Arlington, Virginia. The body pivoted from the previous day’s collaborative roundtable discussions into reviewing the association’s work…Read More

“Doing Big Things with Big Rocks”

On Oct. 29, ARSA and its Board of Directors hosted representatives from its enterprise member companies, allied organizations, and key government officials for its Annual Leadership Roundtables. The series of…Read More

This is Us

Based on an overview provided by ARSA Director Art Smith, the association produced this 50 second commercial for its work and its industry. Members are encouraged to go to the…Read More
ARSA