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

Championing the Industry at MRO Americas

On stage and behind the scenes at the Georgia World Congress Center, ARSA leaned into the 2025 MRO Americas convention theme: Shaping the future of aviation maintenance. Brett Levanto, association…Read More

Weston Award Recognizes Crowley’s Commitment to Learning

On March 20, ARSA recognized Jerry Crowley with its Leo Weston Award for Excellence in Government Service. Crowley is a long time FAA aviation safety inspector who was a professional…Read More

Industry Requests More Time to Comment on FAA Order 8130.21J

Update: On April 17, the FAA notified the industry signatories that it had extended the comment deadline to June 6, 2025. On March 28, ARSA joined 11 ally trade associations…Read More

Small Biz Recruitment by Repair Stations

The National Skills Coalition and its partner organization Business Leaders United invite the repair station community to support a study of small and mid-sized business recruiting practices. The study seeks…Read More

Maintenance Industry Surpasses Pre-Pandemic Peaks, Enters “Supercycle”

On March 19, ARSA used its Annual Legislative Day gathering to release its 2025 Global Fleet & MRO Market Report. The analysis provided for the association by Oliver Wyman Vector,…Read More
ARSA