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Helping FAA Quickly Meet New Foreign Oversight Requirements

On Oct. 4, ARSA joined Aircraft Electronics Association and Airlines for America in confirming for the FAA that new foreign oversight mandates from Congress’ reauthorization law are easily met through existing policy and regulation.

The letter cosigned by the three trade associations addressed the new requirements in 49 U.S.C. § 44733. The letter provided the following analysis of each mandate for the FAA:

(1) Inspect foreign repair stations annually without notification from the FAA consistent with bilateral aviation safety agreements (bilaterals) and the applicable laws of the country in which the repair station is located. (See, § 44733(e).)

The FAA must inform foreign civil aviation authorities to conduct unannounced inspections under its bilateral agreements. It need not notify the repair station subject to inspection. No changes no changes are needed to guidance or procedures to fulfill the statutory requirement when overseeing a foreign repair station in a bilateral country.

(2) Gather and analyze data on heavy maintenance work performed for air carriers. (See, § 44733(g).)

Multiple existing sections in part 121 require the collection, retention, and availability of maintenance data for analysis by the FAA. The agency must require “appropriate actions” by air carriers and repair stations based on any identified safety issue. No change to air carrier procedures is required since the mandate is already met under current regulations through the airlines’ procedures and safety management systems.

(3) Ensure minimum qualifications of supervisors of supervisors and personnel authorized to approve a repair station’s work for return to service. (See, § 44733(i).)

Current guidance can easily be adjusted to ensure §§ 145.153(b)(2) and 145.157(b) requirements are fulfilled by a license or certificate issued by any State signatory to the International Civil Aviation Organization (ICAO) that adheres to Annex 6. The requirements of the annex meet the requirements of the statute for supervisory personnel and those authorized to approve work for return to service under the cited sections. The letter provided suggested language for an update to Order 8900.1.

The letter concluded that the FAA need not change its guidance or practices – with the exception of the suggested small adjustment to its Order – to adhere to the new stator provisions. To read the complete letter, click here.

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