On June 30, the agency issued another legal interpretation on the term “overhaul”—adding to the long list of explanations on the proper use of the term. Again the FAA summarizes the fact that the word can be used in a maintenance record to describe the highest level of work on an article. In other words, there are times that an article need only be cleaned and inspected to be described in a maintenance record as “overhauled.”
ARSA previously addressed the varying uses of the term in the context of component maintenance manuals (CMM), arguing that the regulations—not a manufacturer use of the term in its manual or instructions—dictate when an article is “overhauled.” With this new legal interpretation ARSA will do further research into the origins and appropriate use of the term – stay tuned.
In the meantime, ARSA’s correspondence with the FAA regarding the use of this term can be found:
To see all the ways that ARSA is working as the voice of the aviation maintenance industry, visit the ARSA Works page.
Online Training: Overhauling Overhaul
More from ARSA
February 01, 2023 | Categories:
, ARSA News & Updates
The Dispatch – ARSA’s open-subscription weekly newsletter – provides a central communication for key updates to the global aviation maintenance community. All member contacts, industry allies and subscribers should receive…Read More
In January, the FAA issued its long awaited notice of proposed rulemaking (NPRM) that would update and expand the requirements for safety management systems. Despite the proposal’s (thankful) omission of…Read More
On Jan. 31, ARSA coordinated submission of a letter to FAA and EASA executives seeking to correct misinterpretation of aircraft parts documentation requirements under the U.S./EU bilateral aviation safety agreement…Read More
March 14-17, 2023
Arlington, Virginia and Washington, D.C. with Livestream Options for Online Participants
Sponsors | Event Information | Registration | Hotel Reservations
Thank you to the 19 organizations that have…Read More
On Jan. 11, the FAA issued a long-awaited notice of proposed rulemaking (NPRM) that would update and expand the requirements for safety management systems. The proposal’s applicability does not include…Read More