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ARSA’s Filler Highlights Need for Risk-Based Oversight at Asia-Pacific Conference

On July 19, regulators and industry stakeholders touched down in Washington D.C. for the FAA’s second annual Asia-Pacific Flight Standards Conference. Marshall Filler, ARSA’s Managing Director and General Counsel, joined members of the FAA, other CAAs and their industry counterparts to discuss risk-based oversight of aviation maintenance organizations (AMOs).

Filler highlighted that AMOs accomplish and receive more audits from more parties than any other entity in the aviation industry. Unfortunately, the current system has resulted in more duplication of oversight as more states have exercised their ICAO State of Registry rights and obligations in the last decade.

In order for the risk-based Safety Assurance System (SAS) and Safety Management System (SMS) to realize the potential of minimizing regulatory burdens, Filler noted that the surveillance model for AMOs must fundamentally change. In particular, aviation authorities should start sharing and accepting audit results and should encourage mutual recognition of AMOs through validation. If bilateral agreements truly mean that the signatories recognize and accept the other’s regulatory system as equivalent, the number of special conditions must be minimized. Finally, Filler explained that ICAO must continue its work to develop standards, recommended practices and associated guidance for stand-alone AMOs that encourage their mutual acceptance or at least the reciprocal acceptance of audit data.

Next Stop on Filler’s D.C.-Based “World Tour” with FAA: Asia-Pacific

July 5, 2016

On July 19, ARSA’s Managing Director and General Counsel Marshall S. Filler will speak at the FAA’s 2016 Asia-Pacific Flight Standards Meeting in Washington, D.C. Fresh off an appearance at the FAA-EASA International Safety Conference, Filler continues his “world tour” on international regulatory matters…without leaving the U.S. capital city.

The FAA’s purpose in organizing the meeting is to bring together stakeholders from throughout the Asia-Pacific region to promote collaboration, identify areas of mutual concern and share best practices in the interest of aviation safety. The agenda includes discussions of maintenance oversight, technology implementation, safety enhancements, training standardization, unmanned aircraft systems and regulatory challenges.

On the first of three days of content, Filler will join regulators and industry representatives from the United States, the Philippines and Chinese Taipei on a maintenance-focused breakout. His presentation will cover risk-based oversight and efforts to streamline audits, topics that have garnered considerable attention from both the FAA and ARSA.

The association’s most-recent audit survey found that, on average, the responding repair stations each received nearly 100 paper and in-person audits per year. Reviews from agencies (including the FAA and foreign CAAs), customers and commercial certificate providers (e.g., ISO, NADCAP) on top of internal audits continue to impose an impressive and redundant burden on maintenance providers. Pursuing a legitimate transition to a risk-based model that limits redundant audits will save both the agency and industry valuable time and resources. (To learn more about the audit survey, contact ARSA.)

To learn more and register to attend the meeting, visit

To personally and professionally benefit from Filler’s international expertise, check ARSA’s online training page for the on-demand recording of his session “Going Global” (and stay tuned for upcoming live sessions).

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