On April 28, ARSA sent a letter to the Federal Aviation Administration (FAA) seeking clarification on how the agency treats the creation and refilling of Emergency Medical Kits (EMKs) that are required equipment for air carriers (14 CFR § 121.803). The regulation requires carriers to have “an approved” EMK with specific contents that are “inspected” regularly to ensure continued serviceability.

The confusion arises from a lack of guidance on whether an “approved” kit must be created under the part 21 design and production requirements and whether the “inspection” is considered maintenance (as defined in § 1.1) despite the fact they are performed by flight attendants. The FAA furthers the uncertainty by using the Maintenance Time Limitations Section of the carrier’s Operations Specifications (OpsSpecs) to track the EMK’s currency.

ARSA recommended the FAA develop a separate OpsSpecs paragraph for all equipment carried aboard an aircraft that needs periodic validation to ensure that the equipment is not subject to the requirements of part 21 and 43. In the alternative, the agency should clarify in the existing OpsSpecs that EMKs are not validated as part of the maintenance program but are tracked only to ensure the contents do not expire.

Finally, ARSA requested confirmation that any person (including a repair station) may create and restock an EMK without having to comply with part 21 or 43. As the manufacturer, this person may also determine the replacement/validation intervals and issue a certificate of conformity as assurance the kit meets the requirements in the carrier’s OpsSpecs and is usable for a stated period of time.

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

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