In my opinion, the efforts by OEMs to limit our access to data has become the most important topic for all independent FAA repair stations. The FAA has been enforcing non-compliance with 14 CFR. § 145.109(d) when repair stations can’t verify or obtain current maintenance data but have done nothing to enforce Part Approval Holder’s (PAH) requirement to provide this data in accordance with (14 CFR. § 21.50(b).  We are stuck in a catch-22 with our businesses, employees, and customers at risk of losing everything to mega-OEM’s monopolistic endeavors.

The Aeronautical Repair Station Association (ARSA) has been working for years to clarify the rules regarding access to continued airworthiness data and PAH’s legal obligation to provide it.

All of us who own, work for, or support small businesses now have some action items! Please see the email below from ARSA and take the time to summit a comment to the SBA (took me 20 min, I spend more than that checking some CMMs).

I encourage you to join ARSA, if you haven’t already, and get involved to keep our industry alive with vibrant small businesses! Please send this to others in our industry to make the biggest impact we can.


Christian A. Klein
Executive Vice President
Aeronautical Repair Station Association:

 After years (decades, actually) of engaging the FAA on this issue, ARSA is shining another public spotlight on FAA’s unfair practices.  The association filed a comment with the U.S. Small Business Administration National Ombudsman’s office this summer urging it to review FAA’s inconsistent enforcement of the maintenance manual rules.  The point is simple – many small businesses face unnecessary administrative and financial burdens and significant loss of commercial opportunities as a result of FAA’s policies.

 While the ombudsman’s office does not have the authority to change FAA policy, it is charged to investigate small business issues and work with regulatory agencies to resolve them. Additionally, the ombudsman’s annual report to Congress highlights unfair regulatory activities, which lays the foundation for legislative queries and action.  In other words, the SBA process is another way to put pressure on FAA and shine a bright light on the problem.

 If you’re concerned about the maintenance manual issue, take this opportunity to make your voice heard and make a difference by filing your own SBA comment.  ARSA has developed a toolkit to make it easy and painless.  It will take you less than half an hour and you can choose to have your comment kept confidential.  Access the toolkit here. Review ARSA’s complete comment here.

 Please help all of our small business succeed by participating in our endeavor!

Brian Tyminski
Accountable Manager
Compressed Gas Systems, LLC