ARSA RSS Feed ARSA LinkedIn
Ask ARSA Online Portal

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

How’s Marshall?

On July 8, ARSA Managing Director & General Counsel Marshall S. Filler underwent successful heart surgery. He is recovering at home and is on track to continue his passion as…Read More

FAA to Restart Global Leadership Meeting

On July 20, the FAA announced plans to host its 8th Annual Global Leadership Meeting in Washington, D.C. on Sept. 22-23. The event will have both in-person and online attendance…Read More

Lawmakers Explore Aviation Workforce Diversity

The House Aviation Subcommittee held a hearing July 20 to discuss enhancing diversity in the aviation workforce. The witnesses were (click a name to download their written testimony): Rebecca Lutte,…Read More

Unpacking AD Authority

On July 2, ARSA requested clarification of the FAA’s authority to issue an Airworthiness Directive, questioning the April 22 posting of an AD against certain Uninsured United Parachute Technologies, LLC…Read More

Training – Parts Documentation Under the U.S.-EU MAG

To see all of ARSA’s work on the MAG, visit arsa.org/mag. For years, ARSA lead an industry wide effort to “smooth” implementation of parts documentation issues in the U.S.-EU Maintenance Annex…Read More
ARSA