The FAA’s recently formed Regulatory Consistency Communication Board (RCCB) has agreed to resolve questions surrounding the ability of repair stations to replace an "article" during maintenance. The RCCB review comes in response to Aeronautical Repair Station Association (ARSA) concerns that past agency attempts to determine when a particular action is manufacturing—and requiring a production approval—are not supported by the regulations. “The regulations do not directly or indirectly prohibit the replacement of all parts in an article during a single maintenance visit,” ARSA said. “There are no limits on the number of parts that can or should be replaced during a maintenance action.”
ARSA last month asked the RCCB to clarify that repair stations could replace 100 percent of an article that is not an aircraft, engine, propeller, propeller hub or blade during maintenance without a need for production approval. “The industry and the agency have been attempting to address this issue for years,” ARSA told the RCCB. “However clear direction on compliance does not exist.”
The FAA officially went live with the RCCB earlier this year after testing the initiative for months. Borne out of a recommendation from the industry-government Consistency of Regulatory Interpretation Aviation Rulemaking Committee (CRI-ARC), the RCCB was created to act as a central board to clarify questions about regulatory interpretations from the various regions and district offices.
The board has already issued its first few decisions and told ARSA on July 11 that “has carefully evaluated [the article replacement] issue and determined it will be accepted by the RCCB for resolution.” ARSA expects to receive a status update within 45 days.