Exemption Toolkit for “Current” Maintenance Data Requirement
On Nov. 19, ARSA released a members-only toolkit providing a draft petition for exemption – and instructions for its submission – from the requirement under 14 CFR § 145.109(d) that repair stations have “current” manufacturer’s data available even when it is not needed and will not be used.
As many maintenance providers are aware, the FAA does not require design approval holders (i.e., manufacturers) to make maintenance data available as they are required to by 14 CFR § 21.50(b). However, the agency aggressively enforces the requirement for repair stations to possess the most current version of those documents. By submitting petitions, FAA-certificated repair stations will pressure the agency to uniformly apply both design and maintenance requirements in addition to aligning parts 145 and 43.
The association encourages its members to utilize the toolkit to submit a petition; the included draft requires minimal editing/update and is ready to be placed on company letterhead and delivered to the agency. Not only will the effort directly benefit each repair station by helping alleviate an unnecessary regulatory burden, it will also help ARSA develop a broader public policy case for removing the requirement from § 145.109(d).
To access the toolkit:
(1) Log in to the association’s secure online portal (arsa.member365.com). If you have not done so previously or have lost your credentials, enter the email address associated with your membership and follow the instructions for “Forgot Password?”
(2) From your member dashboard, select “Workspaces” from the top menu.
(3) From the workspaces page, select “Publications: Tools for ARSA Members” under the “ARSA Members” category.
(4) On the left side of the workspace screen, select “File Library.”
(5) On the file library page, select “Petition from Exemption from 14 CFR 145.109(d)” from the category drop-down.
(6) Click the filename “ARSA-145-109ExemptionToolkit-20181110.docx” to download the toolkit, which is in a Word Document format.
Keep the association informed by including [email protected] on any correspondence regarding exemption requests and use the inquiry system to submit any questions.
Related
While you’re requesting exemption from 145.109(d), share your experiences regarding “current” maintenance data requirements with ARSA through the following “quick question”:
