Join ARSA Ask ARSA Pay ARSA

HazMat Compliance Baseline

On August 20, 2009, the Federal Aviation Administration (FAA) released N 8900.88 entitled “Letter Certifying HAZMAT Training for Employees of Part 145 Repair Stations” directing Aviation Safety Inspectors to obtain a letter from all repair stations certifying that the hazardous material (hazmat) employees have been properly trained. While there is no regulation requiring repair stations existing before 2005 to provide this information, ARSA has created a letter that will inform the agency of a repair station’s status as an hazmat employer and if it is, the training status of its employees. The letter may be found here.

The FAA’s notice is a bit confusing since it seems to indicate that even if the repair station is not a hazmat employer, it must obtain verification that its contractors have provided appropriate hazmat training. In 2005, the association petitioned the government to ensure that this misunderstanding would not take place; it requested a clarification to ensure that if the original repair station was not a hazmat employer, then it did not have to verify the compliance of its vendors. In its denial of the petition for rulemaking, the agency assured the association that if the original repair station was not a hazmat employer, it did not have to comply with any of the hazmat requirements, including verification of its contractor’s compliance. We are hopeful that the FAA will clarify that fact to its inspectors before too many “demands” are made on repair stations.



More from ARSA

2025 Annual Conference – The Who’s Who

March 18-21, 2025 Event Information | Registration | Sponsors | Hotel (Book by Feb. 21) Arlington, Virginia and Washington, D.C. with Livestream Options Thank you to the 17 organizations that have committed…Read More

New Bilateral Oversight Guidance for ASIs

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

FAA Opens Workforce Grant Applications for 2025

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

FAA Requires Foreign D&A Testing by 2027

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

Good Maintenance Cheer this Holiday Season

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
ARSA