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:

• ARSA, May 29, 2009
• ARSA, July 16, 2009
• FAA Response, August 31, 2009

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

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