FAA Reasserts Repair Station Ability To Fabricate Replacement Articles

Legal opinion upholds repair stations’ ability to fabricate replacement parts and modifications.

Printed headline: Fabricated Facts

The FAA recently responded to a request for legal interpretation after a repair station’s local flight standards district office refused to approve its fabrication quality control system. According to the requester, the local office rejected the idea that a repair station can fabricate replacement parts when those parts are available from the type certificate holder.

Under Title 14 the Code of Federal Regulations §21.9(a)(6), repair stations can consume fabricated parts as part of an approved quality system. The FAA assistant chief counsel regurgitated the regulation in his response, adding, “the fact that a type certificate holder may have parts available has no bearing on the permissible use of parts fabricated in accordance with §21.9(a)(6).”

The requester also asked for—and received—confirmation that a repair station may produce and stock multiple parts of the same part number for future repairs and modifications. As the assistant chief counsel pointed out, that practice is specifically provided for in Advisory Circular 43.18, Fabrication of Aircraft Parts by Maintenance Personnel. 

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