Maintenance and Modifications
ARSA: FAA Policy Jeopardizes AD Compliance
The association is urging the agency to spell out explicitly what is required for compliance with an AD.

The Aeronautical Repair Station Association (ARSA) has requested that the FAA revise a legal interpretation regarding second- and third-tier documents that are purportedly incorporated by reference in an Airworthiness Directive (AD). ARSA’s letter points out that the legal interpretation—and existing guidance—violate the Administrative Procedure Act and force maintenance providers to determine what is required to comply with the AD. According to ARSA, an AD specifically references a Service Bulletin (SB) and mandates that maintenance providers accomplish specific instructions therein. The SB then references a manual and that document references a standard practice manual. The only document referenced in the AD is the SB.