ARSA sent a set of letters to the Federal Aviation Administration (FAA) to dispel the agency’s notion that a repair station could not use a manufacturer’s component maintenance manual to perform an overhaul. The agency opined that a facility must either use a manufacturer’s “overhaul manual” or develop its own FAA-approved manual to accomplish the described work.

The Association disagreed with this opinion and pointed out that whether the manufacturer of an article uses “overhaul” in its manual or instructions does not dictate the use of the term in a maintenance record. The regulations set forth the requirements for the proper use of that term, not the manufacturer.

Maintenance is defined in § 1.1 as “inspection, overhaul, repair, preservation, and the replacement of parts” Further, all maintenance must be done in accordance with the performance standards set forth in § 43.13. Section 43.13(a) indicates that the manufacturer’s maintenance manual or instructions for continued airworthiness contain acceptable methods, techniques and practices for accomplishing work.

In order to use the term “overhaul”, a maintenance provider must perform an extensive scope of work. That is, the repair station must disassemble, clean, inspect, repair as necessary, reassemble and test the article in accordance with procedures developed by the manufacturer. The regulations do not limit the use of that term to manufacturer instructions that contain the word “overhaul”; rather they dictate the scope of work necessary to ensure that all tasks are accomplished (or determined unnecessary).

Therefore, a repair station may use the term “overhaul” provided the necessary work scope has been accomplished in accordance with the § 43.13(a) methods, techniques and practices. In other words, an “overhaul” manual is not required to perform the work scope necessary to use that term in a maintenance record.

ARSA’s letters to the FAA may be found here, and here.

UPDATE: On August 31, 2009, the FAA responded to ARSA’s letters.

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