ARSA RSS Feed ARSA LinkedIn
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The withdrawn FAA memorandum may be found here.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 Survey Invite Sent

February is survey month for maintenance providers. The association encourages its members to respond to two important questionnaires gathering data about the industry: ARSA Annual Member Survey On Feb. 20,…Read More

ARSA Insight at HELI-EXPO 2024

This month, as it prepares for the 2024 ARSA Annual Conference, ARSA’s team will make a special appearance at HAI HELI-EXPO 2024 in Anaheim, California. Sarah MacLeod, Marshall S. Filler,…Read More

2024 Annual Conference – Good as Gold

March 12-15, 2024 Sponsors | Information | Registration Arlington, Virginia and Washington, D.C. with Livestream Options for Conference Ambassadors Thank you to the six Gold Level Sponsors of the 2024 Annual…Read More

Template for Requesting CAAC Special Approval

In December, the Civil Aviation Administration of China (CAAC) issued a notice to U.S. repair stations that it would no longer consider Special Approval applications for certificate extension. Pending new…Read More

FAA Proposes Removing Repair Station “Current” Data Requirement

On Jan. 31, the Federal Register published a notice of proposed rulemaking from the FAA that would amend § 145.109(d) to remove the requirement for repair stations to keep an…Read More
Schaeffler Aerospace
ARSA