Industry Helps FAA Reconstruct Recordkeeping Guidance

On June 12, an ARSA-led coalition of ten industry partners submitted a complete rewrite of the agency’s proposed Advisory Circular 43-ARTS, “Use of FAA Form 8130-3 for Approval to Return to Service Under Part 43.”

The signatories, most of whom also joined a February request for extension to the comment period, made good use of the additional time provided. They compared the draft AC as written to existing maintenance recordkeeping rules and agency guidance and determined that the draft should not be issued.

“Release of the draft AC without a complete rewrite will, among other things, cause both industry and the FAA to expend considerable resources to ensure continued compliance with section 43.9 and international commitments,” the letter said.

The coalition instead submitted a replacement for the existing AC 43-9C, which is not current and fails to address 43.9 requirements. The new draft walks through the rule and described what it requires for mechanics, repairmen and repair stations performing work on aircraft with U.S. airworthiness certificates. The submission also describes the steps for handling, correcting or reissuing maintenance records as well as completion of FAA Form 8130-3 for the FAA, EASA and other civil aviation agencies.

“[Maintenance records] associated with a civil aviation aircraft, its installed products, appliance and articles are essential to making determinations of the aircraft’s airworthiness,” the group’s draft AC describes, underscoring the importance of correctly aligning agency guidance with recordkeeping regulations. “Maintenance records provide tangible evidence that the work on the aircraft and its installed products and articles was performed appropriately and correctly.”

In addition to providing the replacement for AC 43-9C, the signatories also urged the agency to issue separate advisory circulars on 43.11 inspection records and part 91 owner/operator records.

To read the full submission (cover letter and rewritten AC), click here.

The following organizations joined ARSA in the submission:

Aircraft Electronics Association
Airlines for America
Aviation Suppliers Association
General Aviation Manufacturers Association
Gulfstream Aerospace Corporation
Modification and Replacement Parts Association
MOOG Aircraft Group
National Air Transportation Association
Professional Aviation Maintenance Association