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
January 16, 2025 | Categories:
Act Now,
ARSA News & Updates
March 18-21, 2025
Event Information | Registration | Hotel (Book by Feb. 21)
Arlington, Virginia and Washington, D.C. with Livestream Options
The ARSA Annual Confernce is the international aerospace maintenance community’s…
Read More
The FAA has announced an amendment to Order 8900.1, Vol. 6, Chap. 9, Sec. 27 clarifying procedures for aviation safety inspectors (ASIs) who oversee domestic repair stations holding foreign certificates…
Read More
On Jan 6, the FAA opened applications for its 2025 round of funding available through two aviation workforce grant programs championed by ARSA through multiple congressional reauthorizations of the agency.…
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
December 16, 2024 | Categories:
ARSA News & Updates
The association recognizes there are no days off from aviation safety and is grateful to all who keep the world in flight every day – especially those pulling shifts while…
Read More