Pratt & Whitney recently received a response from the FAA to an inquiry related to the D&A rule’s applicability to subcontractors performing parts fabrications under part 43.
In its letter to Pratt & Whitney (.pdf), the FAA explained that fabrication “in the context of Pratt & Whitney’s inquiry” is not considered maintenance. “Subcontractor employees who fabricate a part are not repairing anything,” the agency explained. “Rather, they are producing a part, whether that production is done under a repair station’s quality control system or under a manufacturer’s own fabrication inspection system.” Maintenance is one of the safety-sensitive functions covered by the D&A regulation; manufacturing–including producing parts–is not. The FAA expanded on this view in D&A rule guidance issued Aug. 15.
The FAA also clarified two other issues raised by Pratt & Whitney:
* Non-regulated parts brokers are not covered by the D&A regulation, and
* The D&A regulation does not apply to organizations that perform maintenance outside the U.S., even if the work is for a part 121 or part 135 air carrier.
For more information/background on the drug & alcohol rule, click here.
More from ARSA
December 16, 2024 | Categories:
ARSA News & Updates
The office of ARSA’s management firm will be closed from Dec. 24, 2024 to Jan. 2, 2025. Periodicals will not be distributed on these dates, but the association continues collecting…
Read More
December 17, 2024 | Categories:
Act Now,
ARSA News & Updates,
ARSA Works,
Aviation Policy,
Drug and Alcohol,
EASA,
FAA,
Legislative,
Operations,
Press Releases,
Regulatory,
Rulemaking
On Dec. 18, the U.S. Federal Register published the FAA’s long-awaited final rule expanding drug and alcohol testing requirements to repair station personnel outside the United States.
The new rule…
Read More
Congress’ May 2024 reauthorization of the FAA, requires the Department of Transportation’s Office of Inspector General (OIG) to audit the FAA’s Flight Standards and Aircraft Certification Services (see P.L. 118-63,…
Read More
December 05, 2024 | Categories:
Featured Post
March 18-21, 2025
Event Information | Registration | Hotel
Arlington, Virginia and Washington, D.C. with Livestream Options for Online Participants
Experience the international aerospace maintenance community’s premier event. Join ARSA members…
Read More
On Nov. 19, ARSA submitted a pair of draft advisory circulars for FAA consideration to replace its proposed update to AC 43-9, Maintenance Records.
The documents divide overlapping responsibilities previously…
Read More