On April 7, the FAA responded to a Nov. 3, 2016 ARSA letter reminding the agency that its guidance should correctly cite the applicable regulation.
The letter from the Aircraft Maintenance Division acknowledged ARSA’s repeated inquiries regarding incorrect final inspection guidance in Order 8900.1. In Volume 6, Chapter 9, Section 11, the agency had erroneously indicated the person performing such inspections must be certificated under part 65. The language in section 145.213 makes clear that performing a final inspection and “signing off” on it by issuing a maintenance release (under section 43.9) are two separate steps.
“Since receipt of your letters, FAA guidance has been revised to include the elements of Safety Assurance System (SAS) and has corrected the errors that you discovered regarding final inspection…and return to service regulation reference[s],” the letter said.
The agency indicated the corrections will be published in the coming weeks along with changes regarding the definition of maintenance functions in Volume 2.
To read the full response, click here.
November 3, 2016
Thanks to a member question (published as “A Member Asked” in this month’s hotline newsletter), ARSA again reminded the FAA that its guidance should correctly cite (and therefore interpret) the plain language of the regulation.
In this case, the agency continues to “guide” its workforce into believing that a person performing a final inspection for a repair station must be certificated under part 65. The language in section 145.213 makes clear that performing a final inspection and “signing off” on that inspection by issuing a “maintenance release” (under section 43.9) are two separate steps.
It is the person performing the “sign off” that must be certificated under part 65, while the final inspection has to know what s/he is doing. The association has already highlighted the difference between the regulations and the guidance material several times. On Nov. 3, ARSA reiterated its plea to correct the guidance in a letter to Tim Shaver, manager of Aircraft Maintenance Division.
To read the letter, click here.
June 16, 2014
In response to ARSA’s Nov. 30, 2010 and May 14, 2014 requests, the FAA delivered a letter indicating it will revise Order 8900.1 to reflect that that repair station personnel performing final inspections are not required to be certificated under part 65.
May 15, 2014
On May 14, ARSA submitted a letter to the Federal Aviation Administration (FAA) requesting it correct parts of Order 8900.1 that purportedly requires persons performing final inspections be certificated under part 65. This guidance is incorrect and fails to recognize the regulatory distinction between performing a final inspection and approving the work on an article for return to service. ARSA addressed this issue back in November 2010 but the erroneous guidance remains despite the 2013 and 2014 revisions to Order 8900.1.
The regulations clearly demonstrate that the final inspection and “maintenance release” are two separate and distinct activities. This issue almost never arises because most of the time, persons performing the final inspection are also qualified to issue the approval for return to service; however when a repair station separates these activities, confusion ensues. The regulations certainly make the separation and Order 8900.1 should be revised accordingly.
November 30, 2010
On November 30, 2010, the association submitted a letter to the Federal Aviation Administration (FAA) requesting that corrections be made to its guidance regarding persons performing final inspections. Specifically, Order 8900.1 has two locations that claim individuals performing final inspections must be certificated under part 65. That guidance is incorrect.
Section 145.213(d) states that only the individual authorized to approve the work for return to service must be certificated under part 65; that person must ensure that a final inspection has been performed before issuing the maintenance release.
The individual performing a final inspection, which must occur before the work is approved for return to service (see § 145.213(a)), needs to be qualified under section 145.155, but not part 65 (see § 145.213(c)).
ARSA noted in its letter that in most cases, the persons performing the final inspection are also qualified to issue the approval for return to service and therefore this issue never arises; the story is different for repair stations that separate the final inspection function from the approval for return to service – but the rule clearly provides for that separation.
To see all the ways that ARSA is working as the voice of the aviation maintenance industry, visit the ARSA Works page.
