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Drug and Alcohol Proposal Flawed, Industry tells FAA

WASHINGTON, D.C., August 17, 2004 – Led by the Aeronautical Repair Station Association (ARSA), a broad-based aviation industry coalition submitted comments in response to the Federal Aviation Administration’s (FAA) proposed rule to drastically expand the scope of its Antidrug and Alcohol Prevention Program.

“Thirteen aviation industry groups and companies endorsed ARSA’s comments and joined as signatories,” according to ARSA Executive Director Sarah MacLeod. “The aviation world is clearly united in opposition to this unnecessary, costly and misguided FAA proposal.”

The proposed rule would require non-certificated maintenance subcontractors (NCMS) working for FAA-certificated repair stations to participate in an FAA-approved drug and alcohol screening program if the articles in question are ultimately installed on air carrier aircraft.

NCMS businesses provide technical services in support of aviation and other industries such as metal finishing, dry cleaning, machining and heat treating. They are not subject to direct regulatory oversight because they cannot take airworthiness responsibility for the work they perform under FAA maintenance regulations. Certificated repair stations remain responsible for the airworthiness of any maintenance function performed by their non-certificated subcontractors. In addition, all maintenance employees of the airlines and their direct contractors are already covered by the FAA’s drug and alcohol rules.

ARSA asked the FAA to withdraw the proposed rule in light of evidence that the agency vastly underestimated its economic impact. Based on surveys the Association conducted over the past two months, noted aviation economist Darryl Jenkins determined that as many as 22,000 NCMS from a variety of industries would find themselves subject to the new rule. This number starkly contrasts with the FAA’s estimate of 297 companies that would be impacted.

The survey results reinforce the Association’s concern that a substantial number of NCMS would decline to serve aviation customers if the proposed rule goes into effect — shrinking competition and driving up costs.

The Joint Industry Comments also noted the FAA’s failure to consider the safety mechanisms already in place to protect the flying public. The current regulatory scheme ensures the airworthiness of articles and products maintained by the aviation industry. Therefore, the FAA’s proposal is unnecessary, costly and burdensome to the small businesses that would be primarily impacted.

ARSA will continue its efforts to prevent the implementation of this duplicative and economically damaging rule.

Signatories/Supporters of the Joint Industry Comments:

Aeronautical Repair Station Association
Aerospace Industries Association
Aircraft Electronics Association
Alaska Air Carriers Association
Aviation Suppliers Association
The Boeing Company
General Aviation Manufacturers Association
Helicopter Association International
Jet Aviation
Loureiro Engineering Associates, Inc.
National Air Carrier Association
National Air Transportation Association
Regional Airline Association
United Technologies Corporation

About ARSA

The Aeronautical Repair Station Association is the international not-for-profit trade association for certificated repair stations. ARSA represents the interests of aviation maintenance and alteration facilities before the FAA, the National Transportation Safety Board and other agencies. Founded in 1984, ARSA is the leading provider of regulatory training and compliance information for aviation design, production and maintenance.



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