ARSA RSS Feed ARSA LinkedIn
Ask ARSA Pay ARSA

FAA Agrees with ARSA on Work Instructions

On April 20, ARSA received a positive response from the FAA to a May 29, 2014 request for clarification of (1) a repair station’s ability to develop and use work instructions and (2) the exact requirements for accessibility of relevant maintenance data during the performance of maintenance functions.

It its response, the agency agreed with each of ARSA’s recommendations and specifically confirmed that a repair station may create work instructions for its technical personnel. “An appropriately certificated and rated repair station may develop its own work instructions/shop travelers based on manufacturer’s maintenance data and/or other methods, techniques and practices acceptable to the FAA,” the letter said.

Prior to this clarification, the Miami Flight Standards District Office (FSDO) and the FAA’s Southern Region Office had determined the use of internally developed work instructions, even with only minor differences from manufacturer information, was unacceptable without prior FAA approval.

The FAA also contradicted the determination of the local and regional offices that personnel must have “physical possession” of the manufacturer’s maintenance data even if it was not relevant to the work being performed. The FAA agreed with ARSA that – as stated in 14 CFR part 145.109(d) – appropriate documents must only be “current and accessible when the relevant work is being done.”

The success of ARSA’s request, which had been jointly submitted by Metal Improvement Company LLC, eliminates an unnecessary limitation placed on southern region repair stations without regulatory foundation.

Previously from ARSA...

Part 43 and Repair Station Work Instructions

 

May 29, 2014

ARSA joined its member, Metal Improvement Company LLC,  in submitting a letter under the Federal Aviation Administration’s (FAA) Consistency and Standardization Initiative (CSI) regarding (1) a repair station’s ability to develop and use work instructions and (2) the exact requirements for accessibility of relevant maintenance data during the performance of maintenance functions.

The Miami Flight Standards District Office (FSDO) and the FAA’s Southern Region Office previously determined that the use of internally developed work instructions, even with only minor differences from manufacturer information, was unacceptable without prior FAA approval. The local and regional offices also determined personnel must have “physical possession” of the manufacturer’s maintenance data even if it was not relevant to the work being performed.

The Code of Federal Regulations (CFR) states repair stations must ensure maintenance functions are performed in accordance with part 43. The agency has repeatedly clarified (e.g., Order 8900.1 and AC 120-77) that work instructions are acceptable as long as they return the article to its original or properly altered condition. Pre-approval is unnecessary unless the instruction results in a major repair or alteration.

A 2010 legal interpretation from the FAA acknowledged that part 145.109(d) only requires manufacturer’s technical data to be “accessible” and that there will be instances when it will not be used. Additionally, “physical possession” is certainly not required when the repair station’s work instructions contain all of the elements for performing the work in compliance with part 43.

The CSI requests that the FAA confirm that repair stations may create work instructions for its technical personnel and that the manufacturer’s maintenance data need only be “accessible” when relevant work is being performed. The CSI letter recommends that the FAA issue an advisory circular that elaborates on the development and use of work instructions based on parts 21, 43 and 145.

To see all the ways that ARSA is working as the voice of the aviation maintenance industry, visit the ARSA Works page.



More from ARSA

FAA-EASA Conference – New Tech, Digitization, Workforce

Aviation safety professionals from around the world gathered in Washington, D.C. June 14-16 for the 2022 FAA-EASA International Aviation Safety Conference. ARSA was represented by Executive Director Sarah MacLeod and…Read More

Aviation Bills Move on the Hill

Aviation took center stage on Capitol Hill in recent weeks as the House of Representatives passed legislation to improve government coordination on advanced air mobility and the Transportation & Infrastructure…Read More

ARSA Continues Press on Parts Documentation

On June 10, ARSA responded to the FAA’s reversal of its 2016 acceptance of the association’s E100 Form as a means of compliance with parts documentation requirements under the privileges…Read More

Hotline Highlight – Campaign Contributions

The hotline – ARSA’s premier member newsletter – contains news, editorial content, analysis and resources for the aviation maintenance community. All members should ensure they receive their edition the first week of…Read More

Showing Your Workforce

In partnership with Airlines for America and the Regional Airline Association, the association invites members to support new analysis of the aviation maintenance workforce. Oliver Wyman CAVOK, the aviation consulting…Read More
ARSA