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Industry Recommends Rewrite Of FAA Recordkeeping Guidance

ARSA and other stakeholders push FAA to rewrite guidance on record-keeping and other instructions for completing required forms.

The FAA recently proposed new guidance for the use of return-to- service approval tags. In its comments to the draft document, an industry coalition submitted for consideration an alternative: In lieu of new material, add supplemental information to current recordkeeping guidance, and fix that document while you’re at it.

Spearheaded by the Aeronautical Repair Station Association, the proposed revision to FAA Advisory Circular (AC) 43-9, Maintenance Recordkeeping, walks through what is required for “mechanics, repairmen and repair stations performing work on aircraft with U.S. airworthiness certificates,” including instructions for completion of FAA Form 8130-3.

The recommendation was made in response to the FAA’s request for comment on draft AC 43-ATRS, Use of FAA Form 8130-3 for Approval to Return to Service Under Part 43. That document was resisted by industry groups, which argued that the language suggested the guidance was mandatory and lacked alignment with international regulatory obligations.

With the re-write, industry recommended that the agency develop separate instructions for inspection and owner/operator recordkeeping requirements.

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