Join ARSA Ask ARSA Pay ARSA

Have I Complied Yet?

In a letter to the Federal Aviation Administration (FAA), ARSA requested clarification on what constitutes full compliance with an Airworthiness Directive (AD). The question arose from members that received an Unapproved Parts Notification (UPN) that accused a particular repair station of improperly contracting maintenance to a source that was not “approved” by the manufacturer. The maintenance at issue involved re-coating engine disks after removing and inspecting them for cracks or pits in accordance with AD 2003-12-07.

ARSA contended that the AD only required the removal, inspection and replacement of the disks that were beyond a serviceable limit. If a disk was still serviceable (i.e., no crack or pits existed) the repair station could use methods, techniques and practices that return it to at least the original (or properly altered) condition.

In other words, any maintenance performed on disks after the AD was complied with, including the work that was contracted to the “unapproved” source, could be accomplished in accordance with 14 CFR § 43.13. Therefore, the repair station was not required by the AD to use a source “approved” by the manufacturer to re-coat the disks.

As a result, ARSA requested affirmation of its interpretation of the subject AD, withdrawal of the UPN and confirmation that “approval” by a manufacturer is not required to establish compliance with 14 CFR § 43.13. We will keep our members updated as soon as we get a reply from the FAA.

A copy of ARSA’s letter to the FAA may be found here.



More from ARSA

On Demand SMS Training – ERPs

Four Safety Management Systems Training Sessions are now available through ARSA’s training program for registration and immediate on-demand viewing. The trainings were co-administered by ARSA and the Aircraft Electronics Association…Read More

On Demand Training – HazMat Determinations

On Oct. 14, ARSA presented an online training session introducing the key definitions in 49 CFR tied to hazardous materials requirements for maintenance providers in 14 CFR. The level 1…Read More

Online Training – How to Keep the Pilot in the Plane

On Nov. 10, ARSA will present a new addition to its list of human factors training sessions reviewing the June 10, 1990 explosive decompression of British Airways flight 5390.  The…Read More

Don’t Let Your UK CAA Certificate Lapse

ARSA has learned that dozens of United Kingdom Civil Aviation Authority (UK CAA) Part-145 certificates issued to U.S. repair stations are at risk of lapsing because renewal applications have not…Read More

Quick Question – Designee Experience

ARSA calls on persons holding delegated authority from the FAA to respond to this “quick question” survey. Data collected through this effort will support ongoing efforts to assert designee due…Read More
ARSA