ARSA Asks FAA to Clarify Current Mx Program Advice
After issuing a letter of interpretat

After issuing a letter of interpretation reminding the maintenance community of the meaning of the word “current” in 14CFR 91.409(f)(3), the FAA has received widespread criticism. The rules require aircraft owners and operators to maintain their aircraft in accordance with a “current inspection program recommended by the manufacturer.” However, the interpretation states that owners and operators are not legally obligated to adhere to the most recent updates to maintenance instructions or inspection programs, but only the maintenance requirements in place when the aircraft was built. The Aeronautical Repair Station Association (ARSA) has asked the FAA for guidance because “the new interpretation is causing significant confusion among certificated repair stations that provide inspection services and FAA [inspectors] in terms of how to apply 91.409(f)(3).” Immediate guidance is needed, according to ARSA, because repair stations might have aircraft disassembled for inspections “implicated by this new interpretation; numerous other aircraft are scheduled to undergo such inspections in the near future.”