Join ARSA Ask ARSA Pay ARSA

FAA Responds To Pratt & Whitney D&A Rule-related Interpretation Request

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

IATA PMA Adoption Webinar Recording Available

On Nov. 19, the International Air Transport Association’s (IATA) dedicated advisory group on “alternative aerospace materials” hosted a webinar reviewing the air carrier “practices and perceptions” revealed by the association’s…Read More

FAA Updates Public “Services & Contacts” for Office of Safety Standards

The FAA Office of Safety Standards has updated its “Services and Contacts” directory, which is available as a downloadable PDF. The document includes names, contact emails, and office numbers for…Read More

SMS Integration Webinar Series Continues Dec. 20

On Nov. 18, ARSA and the Aircraft Electronics Association presented the second of six planned webinars – a monthly series stretching into March 2026 – explaining effective integration of a…Read More

Register for FAA’s AMT/Repair Station Safety Stand Down

On Dec. 3 and 4, the FAA will host a series on online safety seminars targeted at technicians (IA renewal credit available) and other repair station personnel. The “Safety Stand…Read More

Product Support Survey for Maintenance Providers

ARSA has partnered with the International Air Transport Association (IATA) to survey the industry delegation under the Airbus or Boeing product support frameworks (Airbus Supplier Support Conditions – (SSC) and…Read More
ARSA