RCCB to Clarify Guidance on 100 Percent Replacement

Update: On July 11, the FAA responded via email to ARSA’s June 29 request for clarity on the ability of repair stations to replace 100 percent of an article while performing maintenance. The agency’s Regulatory Consistency Communication Board (RCCB), to which the request was submitted, “has carefully evaluated [the] issue and determined it will be accepted by the RCCB for resolution.”

The agency will provide a status update within 45 days, so stay tuned for more information. To learn about the complete request, read below…


RCCB to Clarify Guidance on 100 Percent Replacement

July 6, 2017

On June 29, ARSA submitted a request to the RCCB to help the FAA clarify that repair stations can replace 100 percent of an article while performing maintenance.

Previous agency attempts to determine when a particular action is manufacturing, thus requiring a production approval, are not supported by a plain read of regulations. “The regulations do not directly or indirectly prohibit the replacement of all parts in an article during a single maintenance visit,” the submission said. “There are no limits on the number of parts that can or should be replaced during a maintenance action.”

The request cites the definitions of “maintenance” and “repair” under § 1.1 and their relation to the term “replacement of parts.” It also addresses the prohibition against the reuse of § 45.11 identification plates. Based on a plain reading of these definitions as well as parts 21 and 43 and a review of existing agency guidance, ARSA informed the RCCB that both the Aircraft Certification and Flight Standards services should provide clear direction on how compliance can be shown.

The FAA created the RCCB based on recommendations of the Consistency of Regulatory Interpretation Aviation Rulemaking Committee (CRI ARC). The board’s goal is to provide clarification to FAA personnel, certificate/approval holders and applicants on issues that span the jurisdiction of multiple FAA divisions. In this case, it can provide sensible instruction on the duties and obligations of maintenance providers when performing part replacement.

To read the full submission, click here.

To learn more about the RCCB and ARSA’s recommendations for its development, visit ARSA.org/rccb.

To see all of the ways ARSA works as the voice of the aviation maintenance industry, visit the ARSA Workspage.