Hotline Highlight: Giving Form to Regulatory Reform
The hotline – ARSA’s premier member newsletter – contains news, editorial content, analysis and resources for the aviation maintenance community. All members should ensure they receive their edition the first week of each month. Not getting yours? We can fix that.
White House Order Brings Some Form to Regulatory Reform
By Brett Levanto, Vice President of Communications
On Feb. 24, President Donald Trump issued an executive order providing general instruction for staffing and procedure to execute his policies for controlling regulatory burden.
The order directs the head of each agency to designate a regulatory reform officer (RRO) to oversee implementation of reform initiatives. Each RRO will chair a to-be-established regulatory reform task force to evaluate existing regulations for recommended repeal, replacement or modification.
In performing this assessment, each task force must seek out rules that, among other things, eliminate jobs, “impose costs that exceed benefits” or are “outdated, unnecessary or ineffective.” The boards are further instructed to “seek input and other assistance…from entities significantly affected by federal regulations, including…small businesses, consumers, non-governmental organizations and trade associations.”
ARSA is uniquely positioned to offer counsel on behalf of repair stations and eager to help thoroughly review existing regulations. Through service on the Aviation Rulemaking Advisory Committee (ARAC) and other stakeholder bodies, the association can serve as the voice of the maintenance community to help the FAA comply with White House directive.
The executive order provides the first insight into logistics for the president’s regulatory reform initiatives. In a series of actions taken during his first week in office, Trump froze regulatory activity and made good on his “two for one” campaign promise – consistent but vague expressions of a sea change in oversight policy. As that reform begins to take real shape, a lingering question remains: What exactly is a “regulation”? More than a thought exercise for an ARSA training session, the White House’s Jan. 30 executive order left the issue open by use of an expansive definition:
“Sec. 4. Definition. For purposes of this order the term ‘regulation’ or ‘rule’ means an agency statement of general or particular applicability and future effect designed to implement, interpret or prescribe law or policy or to describe the procedure or practice requirements of an agency, but does not include:
(a) regulations issued with respect to a military, national security, or foreign affairs function of the United States;
(b) regulations related to agency organization, management, or personnel; or
(c) any other category of regulations exempted by the Director.”
For FAA certificate holders, the definition could apply to any agency rule or guidance – a great but expansive opportunity to review every statement produced by the agency in execution of its duties.
In the meantime, ARSA members should:
(1) Review the entire executive order: www.whitehouse.gov/the-press-office/2017/02/24/presidential-executive-order-enforcing-regulatory-reform-agenda.
(2) Catch up on ARSA’s previous coverage of President Trump’s regulatory reform efforts: arsa.org/reg-reform-2017.
(3) Begin practicing the guidance in last month’s hotline: “Analysis for Action – Control Regulatory Costs by Reporting Them.”
Previous Hotline Highlights
Feb. 3, 2017
Analysis for Action – Control Regulatory Costs by Reporting Them
By Sarah MacLeod, Executive Director and Christian A. Klein, Executive Vice President
President Trump’s executive order to control regulatory costs enhances the director of the Office of Management and Budget’s role as the “hall monitor” for executive agencies. The director is to ensure that every agency “manage the costs associated with the governmental imposition of private expenditures required to comply with Federal regulations. Toward that end, it is important that for every one new regulation issued, at least two prior regulations be identified for elimination, and that the cost of planned regulations be prudently managed and controlled through a budgeting process.” Additionally, unless contrary to law, the president directs that “[f]or fiscal year 2017, which is in progress, the heads of all agencies are directed that the total incremental cost of all new regulations, including repealed regulations, to be finalized this year shall be no greater than zero…”
The directive also defines the word “regulation” very broadly to include ‘“an agency statement of general or particular applicability and future effect designed to implement, interpret, or prescribe law or policy or to describe the procedure or practice requirements of an agency…” Given that expansive definition, the order may very likely apply to guidance, which articulates (i.e., interprets) acceptable methods of compliance with a regulation (i.e., law). We expect OMB to soon provide clarification about how the Order is to be implemented.
The presidential directive may be heartening to those of us in aviation being inundated by orders and policy in the guise of regulations, but it will take more work on industry’s part to ensure that the director of OMB and the FAA actually understand the executive order’s impact. This is our chance to remove redundant and confusing rules, but without explaining the amount of money that will be saved, the presidential objectives cannot be achieved for either the agency or the industry.
If you’re not already, you should start thinking about regulations not simply in terms of the frustration and headaches they cause you, but in how much time is associated with compliance and how much money that is worth. Organizations that are able to articulate those metrics will be the most successful in the new regulatory environment.
December 12, 2016
Successful Oversight Requires Collaboration
By Ryan M. Poteet, Regulatory Affairs Manager
The aviation maintenance industry is complex and, often, requires regulators from different countries to oversee and countenance a certificate holder’s operations. Similarly, the FAA’s highly specialized lines of business have caused intra-agency divisions that lead to rules and guidance being created in a vacuum. As such, the development of rules and advisory materials takes significantly more time and resources because the FAA is forced to reconcile duplicative or ambiguous requirements in response to public comment.
What if the aviation maintenance industry was able to provide its perspective before the FAA began drafting guidance or proposing new regulations?
To see the full “legal brief” and learn how ARSA is working to re-engage the Aviation Rulemaking Advisory Committee (ARAC), check out this month’s edition. This material is provided as a service to association members for educational and informational purposes only. It does not constitute legal or professional advice and is not privileged or confidential.
November 7, 2016
From SLC to Symposium
By Brett Levanto, Vice President of Communications
In the last hotline, we celebrated a successful trip to Montreal for ARSA’s 2016 Strategic Leadership Conference (if you somehow missed the association’s coverage of the event, visit arsa.org/slc-2016). As we worked with maintenance industry leaders in Canada, the team at ARSA’s headquarters opened registration for the 2017 Legislative Day and Annual Repair Symposium in the U.S. capital next March.
The symposium and SLC are the key points on the association’s calendar. ARSA’s team builds its yearly schedule around planning, preparation for and execution of each event, and you should, too.
Help the team put the finishing touches on the symposium agenda by completing the questionnaire that pops up on the event page.
Attending ARSA events provides you with personal access to a global network of maintenance community stakeholders. You’ll hear presentations from industry leaders and government officials, participate in discussions with international regulators and strengthen your connections with colleagues and peers. You will also be supporting the only organization dedicated to providing a voice to repair stations around the world.
So, whether you had a great time with us at IATA’s headquarters on Oct. 5 and 6 or jealously followed along at home (have you been to arsa.org/slc-2016 yet?), you can reserve your spot at next year’s symposium right now. Early registration is open; submit yours before Dec. 31, 2016 and get 2016 rates.
For more information and to register, visit: arsa.org/news-media/events/arsa-symposium.
Whether you’re an “early bird,” an “eager beaver” or just a passionate supporter of ARSA and its members, register now.
October 14, 2016
Elections Have Consequences
By Daniel B. Fisher, Vice President of Legislative Affairs
Editor’s Note: This is the fourth part in a series on active political engagement.
If you’re living in the United States, you’ve been bombarded with television and radio ads, reflected on what is and isn’t “locker room talk” and met Kenneth Bone, an unassuming citizen who asked an insightful, policy-related question to the presidential candidates during the second debate…and immediately became an overnight sensation.
I’m pleased to announce the 2016 election cycle is in the home stretch; however, no matter how much you want the campaigns to end, it’s important not only that you vote, but also that you encourage your employees and colleagues to head to the polls on election day (if not before, as absentee voting is already in full swing).
Make sure you’re registered and know where to go on election day (or get your absentee ballot) by clicking here to visit the 2016 election voter toolkit provided by ARSA’s management firm, Obadal, Filler, MacLeod & Klein, P.L.C.
There’s a bunch a stake both on a federal, state and local level. The battle for the White House and control of both houses of Congress will determine the future of tax, trade, environmental, regulatory and aviation policy for the next decade. While the House is expected to remain Republican into 2017 (though in this political environment, anything can happen), GOP margins will likely shrink. In the Senate, Democrats have a legitimate shot at overtaking the Republicans’ 53-47 majority; GOP-held seats in North Carolina, Missouri, Florida, New Hampshire, Indiana, Wisconsin and Pennsylvania remain “toss-ups” and incumbent Sen. Mark Kirk (R-Ill.) needs to pull-off the upset of the year to keep his seat.
While federal elections get all of the attention, don’t forget state and local races. Governorships, legislatures, county councils and city halls are up for grabs across the country. The outcome of these races will oftentimes have a larger impact on your business and your day-to-day life than the national elections. Educate yourself about your local candidates and issues (including ballot measures) and vote!
Get educated, get engaged, and make your mark at the polls on Nov. 8. Remember, you can’t really complain about the results – or celebrate them – if you don’t vote.
September 2, 2016
State Department Relaunches Company Visit Program to Assess ITAR Compliance
By Thomas McVey, Esq. and Williams Mullen, a firm of more than 200 attorneys that blends law, government relations and economic development across 16 practice areas.
Editor’s Note: Readers with questions about import and export compliance issues – particularly relating to the application of ITAR – should review Thomas McVey’s previous submissions:
And register for the upcoming free webinar:
The State Department’s Directorate of Defense Trade Controls (DDTC) has relaunched its Company Visit Program to review compliance activities under the International Traffic In Arms Regulations (ITAR). With its resumption, every repair station with activities regulated under ITAR must understand how the Program works.
Companies are selected for a one to two day visit by DDTC Compliance Office officials under DDTC’s screening criteria. Visits include meetings with senior executives and compliance personnel to review the company’s activities. DDTC has recently issued additional information about the program, including a series of Frequently Asked Questions, The following selected FAQ’s are instructive:
What is the Company Visit Program?
The Company Visit Program entails visits by DDTC officials to U.S. entities registered with DDTC as manufacturers, exporters or brokers of defense articles and defense services, as well as others involved in ITAR-regulated activities, to include foreign companies and foreign governments.
What is the purpose of the Company Visit Program?
The program has several purposes. First, it ensures DTCC understands how compliance programs are implemented in accordance with ITAR. Second, the program enables DDTC to gather information to support the directorate’s development of regulatory policy and practice. Finally, DTCC uses site visits to glean, assess and disseminate industry best practices, provide feedback to individual companies on their compliance programs, and share information on compliance programs industry-wide.
How is the DDTC team staffed for each visit?
A team typically consists of two or more staff from DDTC, depending on the size of the individual company/site being visited and number of companies/facilities visited per trip. On some visits, staff members from DDTC’s Offices of Licensing and Policy, or other relevant agencies, may participate. One DTCC team member serves as team lead and primary point of contact with the company.
How is a visit conducted and what should a company expect?
Once a company is selected for a potential visit, DTCC contacts the company for scheduling. The company can elect not to participate in the visit. Once visit dates are finalized, DTCC sends the company a formal visit notification letter and may request pre-visit materials. Before the visit, DTCC will work with the company to finalize the agenda.
At the visit’s opening, DTCC meets with senior management to explain the purpose and agenda. The company should provide an overview of its operations and export activity during opening discussions. Visits generally last one to two days, depending on the purpose and occur on the company’s premises in offices and conference rooms and include tours of business operations departments. At the visit’s conclusion, the DDTC team briefs company senior management and export control staff to share information the team gathered. DDTC invites the company to provide feedback, ask questions, or raise concerns for follow-up.
After the visit, the DDTC team generates an internal report. The team also follows up on company feedback. DTCC will send a formal close-out letter to the company to summarize the visit, indicate best practices, recommend areas for improvement and address feedback, questions or concerns raised by the company. DTCC also requests feedback on the visit’s quality and usefulness and suggestions for improving the program.
It is important to be ready if DDTC requests a visit with your company. Companies are advised not to wait until the last minute but rather have their ITAR compliance house in order in prior to being contacted for a visit.
To make sure your house is in order, join a free export compliance webinar on Thursday, Sept. 8. The session is provided as a benefit to ARSA members, click here for more information and to register.
This article contains general, condensed summaries of actual legal matters, statutes and opinions for information purposes. It is not meant to be and should not be construed as legal advice. For more information, please visit www.williamsmullen.com or contact Thomas B. McVey, 202.293.8118 or email@example.com.
July 1, 2016
As American’s prepared to celebrate 240 years of independence, the Kingdom of Great Britain suddenly – and somewhat unexpectedly – voted to remove itself from the European Union. How will this modern insurrection affect aviation maintenance providers? Find out in your July 1 edition of the hotline, as Regulatory Affairs Manager Ryan Poteet answers this month’s “A Member Asked…”
May 6, 2016
ARSA on the Hill – By Daniel B. Fisher, Vice President of Legislative Affairs
ARSA’s been sounding alarm bells for years: the FAA reauthorization process is wrought with threats and opportunities for the aviation maintenance sector. Unfortunately, as in past years, dangers from unnecessary, burdensome mandates divert the association’s time and energy away from actually seeking productive policies that would improve conditions for repair stations. The industry has to play defense and the reason is simple—scarce resources.
The aviation industry and lawmakers rely upon ARSA for its expertise and savvy. We organized industry lobbying efforts to defeat burdensome mandates regarding life-limited parts and restricting FAA foreign repair station certifications. The association is seeking modifications to the “repair station” specific provisions in both the House and Senate reauthorization bills. While the broader aviation industry is willing to support our campaigns, ARSA is expected to carry the water. And the association does it on a shoestring budget.
Examine the first quarter 2016 lobbying disclosure reports. The Transport Workers Union of America (AFL-CIO), Transportation Trades Department (AFL-CIO) and the International Association of Machinists and Aerospace Workers are leading the charge for provisions to drive up costs on contract maintenance providers. Included are burdensome pre-employment background checks and foreign drug and alcohol testing requirements (that would once again halt foreign repair station certifications until finalized). These well-heeled organizations spent $735,000 during the first three months of the year compared to about $30,000 from ARSA—nearly 24 times more resources obviously buys more lobbyists, Capitol Hill contacts, and access.
ARSA’s Capitol Hill successes have been the result of hard work, adeptness at navigating the legislative process, regulatory and industry expertise. We’ll continue to fight hard and win battles, but well-funded organizations are perpetuating false safety, security, and economic arguments against contract maintenance. To win the war we need greater resources. There’s a saying in Washington, “if you’re not at the table, you’re on the menu.” ARSA’s is certainly at the table, but it can’t afford all the courses.
Lobbying resources come from the portion of member dues set aside for advocacy. Help grow this pot by recruiting new members, making sure all of your company’s locations pay dues or upgrade your membership. Even better, help all ARSA programs by purchasing a publication, utilizing the services of a preferred provider, sponsoring an event or attending an online training session.
Your investment furthers the association’s efforts on behalf of the maintenance community in all arenas. I promise you’ll see an exponential return.
April 4, 2016
The association recently conducted an industry survey to quantify repair station audit burdens. The survey received a total of 69 repair station respondents, representing a combined 369 facilities certificated under various national aviation authorities.
Of those facilities, 42 percent hold ratings for completed products, 73 percent for components and 39 percent specialized services. All respondents are FAA certificated, 82 percent hold EASA certification, 29 percent hold Civil Aviation Administration of China (CAAC) certification and 20 percent a certificate from the National Civil Aviation Agency of Brazil (ANAC).
On average CAAC proves the most costly certificate to maintain, with respondents reporting auditing fees and expenses of more than $11,000 on average.
Reporting facilities received 6,723 paper and in-person audits in the last year including 797 from the FAA (including 209 from the certificate management office [CMO], which illustrates the continuance of redundant agency reviews), 1,183 from internal sources, 2,698 from customers and 277 for commercial certification (e.g., ISO, NADCAP).
The audits resulted in 561 findings, 79 of which were from the FAA, 173 found internally, 70 from customers and 41 from commercial certifications.
Of those findings, 57 percent were administrative (e.g., typographical errors), 25 percent contradictory (i.e., different opinions on what constitutes compliance), 21 percent duplicative and 10 percent concerned commercial requirements (i.e., contractual or business obligations).
Thank you to the repair stations that participated in the survey. The response data is a valuable tool in the effort to simplify auditing requirements. Stay tuned.
February 9, 2016
In August 2014, the Federal Register published the FAA’s final rule amending 14 CFR part 145. The new repair station rule omitted the word “serious” from the service difficulty reporting requirement in § 145.221. ARSA led a coalition of aviation interests in petitioning the agency to re-insert the word, which was done in concert with the rule’s Nov. 10 effective date; in 88 days, the association and its allies averted a “serious” problem.
Register today for the 2016 Annual Repair Symposium and attend a Friday morning breakout session on the FAA’s Aviation Data Exchange (AVDEX) program – join the effort to improve the agency’s system for managing service difficulty reports.
December 4, 2016
In 1963, an iconic episode of The Twilight Zone shook the nerves of travelers everywhere with a haunting suggestion: There’s something on the wing. Passenger Bob Wilson spent his “nightmare at 20,000 feet” desperately trying to alert others to a wing-walking gremlin bent on destroying the aircraft and dooming its passengers.
The aviation maintenance community’s gremlin is not a physical (or hallucinated) being, but rather the uninformed, hackneyed and all-too-well publicized fears that the “rise” of contract maintenance has a negative impact on aviation safety. The association has long battled with forces bent on dooming the entire industry. It has, despite extremely limited resources, repeatedly repelled false safety and economic campaigns designed to denigrate “outsourced” labor.
ARSA’s positive publicity campaign, media relations and communications efforts have succeeded in counteracting negative press. Similarly, ARSA’s legislative effectiveness has dissuaded lawmakers from openly micromanaging repair stations. However, the industry can’t take the association’s recent feats for granted. Contract maintenance’s opponents are well-funded and politically connected. They, just like ARSA, understand that media (whether factual or not) drives Capitol Hill action and reaction.
It is no coincidence that with the FAA reauthorization process underway in Congress, the aviation maintenance gremlin has returned in full force. In November, Vanity Fair (the same publication that promises the ultimate holiday gift guide, from cashmere to kayaks) took a strong interest in aviation safety. It published James B. Steele’s “Disturbing Truth About How Airplanes are Maintained Today.” Disturbing is putting it mildly.
As a work of fiction, Mr. Steele’s story is entertaining. Unfortunately, when his “investigation” of contract maintenance stumbles upon actual truth, it is repeatedly presented mendaciously: misleading, incomplete and designed to arouse popular passions rather than accurately assess a vital industry. It’s a shame to miss an opportunity for a frank discussion about the men and women who keep the world safely in flight; in its place we got a lazy, half-hearted exposé that scores useless points based on old or inadequate references.
Christian A. Klein, ARSA’s executive vice president and a fellow managing member of Obadal, Filler, MacLeod and Klein, PLC, wrote an incisive and direct response to Mr. Steele’s bile. To paraphrase Christian’s assessment: the author is either ignorant or dishonest. Either way, he has underscored the need for repair stations to have a strong voice.
By replacing Mr. Steele’s skewed narrative with the truth – the world can’t fly without the hard working, safety conscious, talented men and women who turn wrenches and run tests every day – ARSA and its allies provide an invaluable service. For maintenance providers, the association’s efforts translate into a more-favorable regulatory and business climate. For the flying public, this work means open access to the safest era in the history of air transport.
To continue to combat opponents, the association needs your financial support. It is time for you to get new ARSA members, attend and sponsor the annual symposium, and participate in ARSA training. While the association does champagne work, it is on a beer budget. Without resources, success won’t continue; the better funded will inevitably prevail. In other words, ARSA will continue fighting; but, without financial resources, that thing on the wing can bring us all down.
November 6, 2015
A: The new rule, which will allow PAHs to issue FAA Form 8130-3s instead of requiring an FAA designee’s signature, becomes effective on March 29, 2016.
Industry has requested that the agency allow early compliance so PAHs may implement issuance of the FAA Form 8130-3 prior to that date. The ability to exercise the privilege early will facilitate system transitions. Early compliance may be allowed by the end of this year, but there has been no definitive response from the agency to date.
Obviously, allowing early compliance would help ease the workload for the Manufacturing Inspection District Offices (MIDOs) review of the PAH procedures to implement the new privilege.
Resources and guidance on the MAG change can be found throughout this month’s edition of the hotline. To learn more about this and other issues related to the new rule and MAG Change 5 visit http://arsa.org/mag-change-5/ or access the on-demand recording of ARSA’s recent listening session The FAA, EASA and MAG Change 5.
October 5, 2015
As the 2015 Strategic Leadership Conference approaches, ARSA thanks the following sponsors for their contributions. This invitation-only event for aviation maintenance executives is made possible due to the generous support of sponsors.
September 3, 2015
Engaging with the government is not always easy, but persistence is key to aviation safety and business success. Contrary to what you may think, angry mobs with pitchforks don’t form over compliance issues. Even more importantly, anger, mobs and pitchforks have very little impact on the highly-regulated civil aviation industry. There are more modern and civilized tools for righting regulatory wrongs.
Any person who is affected by the FAA’s regulations – codified in Title 14 of the Code of Federal Regulations (14 CFR) – may petition for either exemption from an existing rule, or for the issuance, amendment, or repeal of a rule. These are known as petitions for exemption and petitions for rulemaking. If either of these types of petition is denied, the petitioner may seek reconsideration. The process for submitting these petitions is outlined in 14 CFR part 11.
No matter the outcome, petitioning for rulemaking or exemption can be a meaningful way to implement change or call attention to a matter. When the existing regulatory framework doesn’t allow a particular action or inaction, consider asking for a change in the rule, or for exemption from it.
Learn more about the process of petitioning for rulemaking or exemption and access templates, examples and other resources on ARSA’s petitions issue page.
August 7, 2015
A Self-Paced Training Session
The FAA has issued another legal interpretation on the term “overhaul” – stimulating a flurry of member questions about the term’s applicability to the everyday work of maintenance providers. In this edition of the hotline, ARSA offers a complete education on the matter using the association’s three levels of training. Class is in session.
Required Reading: [Hotline Feature] Overhaul Reviewed Yet Again
Get background on the issue from ARSA’s initial post on the newest interpretation, including the association’s previous engagement with the agency on the topic.
Level 1: [Legal Brief] “Overhaul” – The Price of a Word
Learn the details and follow the word’s journey through decades of interpretation and debate.
Level 2: [A Member Asked] Inspected, Repaired or Overhauled?
Put the issue in context by considering it through the questions of fellow ARSA members.
Level 3: [Sarah Says] ARSA Insurance: Your Policy Against Bad Policy
Apply the lesson to your operations in the regulatory world. More importantly, apply ARSA’s work to your success in that world.
July 6, 2015
By Christian A. Klein, Executive Vice President
Paying ARSA dues is a resource investment that makes your company stronger. Just like any other business asset, the return on investment (ROI) depends on how well the association’s products and services are incorporated into business strategy. Frequent use by employees who are encouraged to take advantage of an asset or resource increases its value and ROI.
How does ARSA make your business better?
- Ensures you can understand and comply with aviation safety regulations.
- Connects you with top regulatory and elected officials.
- Elevates your profile and brand with aviation industry customers and peers.
- Shares best-practices to improve business efficiency.
- Supports employee recruitment, training and retention.
- Provides industry economic data for long-term trending and effective business planning.
- Improves your public and media relations.
Step 1 – Communicate
Understanding and sharing ARSA’s products and services is the first step in maximizing ROI.
If you’re the only one in the company receiving ARSA communications, you’re definitely not maximizing ROI. ARSA recommends you add:
- Owners and C-level executives so they can be in the loop on major policy developments, economic data and opportunities to engage other industry leaders and government officials at the Annual Repair Symposium and at the “by invitation only” Strategic Leadership Conference.
- Quality and/or legal team members so they can obtain regulatory content in the communications, at the symposium and through ARSA online resources that keep members abreast of developments. They also need to know ARSA specialists can provide guidance on regulatory compliance questions in real time and that Obadal, Filler, MacLeod & Klein, PLC provides discounted legal fees for ARSA members should compliance and enforcement matters arise that need confidential handling.
- Your human resources people to keep them abreast of drug and alcohol testing issues, online and in-person training programs and recruitment tools.
- Your PR folks so they are aware of ARSA’s media outreach resources.
- Your marketing team so you can take advantage of ARSA’s resources to reach new customers (advertising in ARSA publications and sponsoring conferences).
Step 2 – Delegate
While individuals in all roles should be getting ARSA communications and updates, maintaining the relationship with ARSA (and other trade associations to which you belong) needs to be part of someone’s job description. Ensure the relationship and ROI is institutionalized and designate a primary point of contact. Being the association liaison shouldn’t be something that person does in his or her spare time as an extracurricular activity; it should be part of their daily responsibilities. Incorporating that role into a job description sends a powerful message from management that trade association relationships matter. It becomes the company’s stated commitment to keeping its ROI strong because someone is accountable for maintaining the most beneficial relationship, even if the person in the position changes.
- The company expects the employee to spend time on the ARSA relationship (e.g., reading its communications and passing on pertinent information, attending meetings, responding to industry surveys and keeping an eye on short, medium and long-term industry and government strategies).
- Someone will be held responsible for the company’s ROI (for example, by briefing coworkers about key takeaways from ARSA meetings, keeping teammates abreast of new association resources and making sure the association has updated contact information for all appropriate employees).
Step 3 – Allocate
Membership dues are your core investment in a trade association. At ARSA dues give you access to a wealth of information and support aggressive regulatory and legislative advocacy on the industry’s behalf. But the more a company invests in strong resources, the more that business can benefit. At the very least, annual budgets should include money for registration fees and travel costs for ARSA events, access to training programs and necessary publications.
Budgeting to sponsor ARSA meetings or advertise in publications will raise your profile or reinforce your brand as an industry frontrunner. Leading companies are committed to budgeting money to support special ARSA projects (a great recent example is Lufthansa Technik, HAECO, Coopesa, and HEICO’s sponsorship of “You Can’t Fly Without Us,” the industry documentary the association recently helped produce for PBS).
ARSA’s staff has built an organization that provides enormous value to its members and the industry; make sure you’re getting the ROI you deserve. The steps are not only easy, particularly considering the value to your business – not to mention your customers and the flying public – they are necessary.
“Recreational or Medical” Marijuana vs FAA/DOT Drug Testing
June 5, 2015
By Shirley Negri, NATA Compliance Services © 2015 Shirley Negri ALL RIGHTS RESERVED
Nearly 50 percent of the United States currently has laws legalizing marijuana in some form. (See Map.)
How does this impact your repair station? Technically it doesn’t, if your operation performs maintenance on commercial aircraft operations including air tour for hire.
The Department of Transportation and the FAA maintain requirements that all “safety-sensitive or covered” employees (e.g., A&P Technicians, Sheet Metal Mechanics, Avionics Technicians) be subject to drug and alcohol testing. Further, regardless if marijuana was used for recreational or medicinal purposes in a state that has “legalized” the activity, detection of use will result in a positive drug test.
NATA Compliance Services (NATACS) is the aviation industry’s only full-service employee background investigation and HR-compliance company and an ARSA preferred provider. To learn more, visit http://info.natacs.aero.
April 2, 2015
On Mar. 4, the Northrop Rice Foundation announced the 2015 ARSA Scholarship had been awarded to Paul Mart of Daytona Beach, Florida. Mart is an AMT student at Embry Riddle Aeronautical University (ERAU).
Mart is pursuing a Bachelor of Science in Aviation Maintenance with a concentration in maintenance management in addition to minors in aeronautical studies and flight. Before arriving at ERAU, Mart earned credits at Green River Community College and the University of Colorado, Boulder.
Mart has a passion for advancements in industry-leading avionics and an interest in business aviation. His goal is to someday be Director of Maintenance at a corporate flight department, but Mart understands the work ahead and looks forward to it. Crediting his parents, who immigrated to the United States from Romania, with teaching him invaluable lessons about hard work and sacrifice, Mart has a clear vision of where he’s going and what it will take to get there.
“It is clear that Paul will be a leader in the industry,” noted one of his instructors in a recommendation letter. “He has all the right characteristics that will help him be a great mechanic and [give him] the desire to grow.” Those characteristics, outlined across all of Mart’s recommendations, include effective personal skills, a meticulous nature and the highest level of integrity.
In short, Mart will be a great asset to the aviation maintenance community and the flying public. It is for people like him that ARSA supports this annual scholarship through NRF; those that will grow the industry, uphold the highest ideals of its work and keep the world safe in flight for years to come.
To see all of NRF’s scholarships and winners, click here. Start getting your materials ready for next year; applications are due December 1, 2015.
March 5, 2015
In addition to the aviation maintenance industry’s premier event, spring is a fertile time for the aviation community to come together. Take every opportunity to represent your business in front of colleagues, partners and decision makers.
Stay tuned to ARSA’s industry calendar for more opportunities to come together.
AEA – Aviation Leadership Summit – Dallas, Texas – April 8-11
ATEC Annual Conference – Orlando, Florida – April 11-14
MRO Americas – Miami – April 14-16
Aerospace Maintenance Competition – Miami – April 14-16
Aircraft Interiors Expo – Hamburg, Germany – April 15
Many Signs of New Life – For Industry, ARSA and Its Partners
February 5, 2015
In March, ARSA will release its annual Global MRO Market Assessment. This year’s release marks a special milestone for the consulting firm formerly known as TeamSAI, the association’s partners in providing analysis and insight into the growing aviation maintenance market.
On Feb. 2, Atlanta-based TeamSAI was acquired by Oliver Wyman to be integrated into CAVOK, the firm’s aviation technical services and consulting practice. The combined entity creates a deep source of expertise with over 130 dedicated, full-time specialists who assist airlines, MRO providers, lessors and other aviation and aerospace stakeholders with mission-critical issues surrounding certification, safety and performance and execution support for technical operations.
CAVOK will be at this year’s Legislative Day and Symposium, be sure to see them.
“The expanded content from this change of ownership should be a great advantage in providing even wider content and resources to ARSA and its members,” said Chris Doan, friend of the association and new vice president of CAVOK.
To celebrate this union, and to look forward to the 2015 Global MRO Economic Assessment, this month’s Quality Time highlight highlights Signs of New Life, the report of Oliver Wyman’s MRO Survey 2014. Going on its second decade, the annual survey is an industry standard for information about changing trends in aviation maintenance.
MRO Survey 2014: Signs of New Life – New Partnerships, Fresh Hiring, 3D Printing
Authors: Chris Spafford, Partner and Darryl Rose, Principal
Original equipment manufacturers won the market for high-value, aftermarket aviation services, leaving independent maintenance, repair and overhaul providers scouting for paths to evolve and grow.
The survey found engine and component MROs are preparing to fortify their remaining footholds through strategic partnering and by accelerating development of unique services. Airframe MROs, meanwhile, seek to capitalize on shifts caused by rising labor costs in emerging economies.
- M&A in the sector to heat up.
- S. MROs to step up hiring.
- 3-D printing to be used to make expendable parts, but not proprietary materials.
Have you read the full report? Download it now at: http://www.oliverwyman.com/insights/publications/2014/apr/mro-survey-2014.html.
January 7, 2015
Obadal, Filler, MacLeod and Klein, PLC, the firm that manages the Aeronautical Repair Station Association, is continually accepting law and graduate student applications for its internship program. Interns will gain first-hand knowledge of the legislative and regulatory process and get a behind-the-scenes look at public policy and the impact it has on critical sectors of the economy. Interns will monitor developments in the nation’s capital, draft content for various publications, conduct research on a variety of policy issues, attend industry and congressional events and play a hands-on role in support of the aviation maintenance industry.
Applicants must work well in a team setting and demonstrate independence and initiative in achieving specific tasks and overall objectives, in addition to possessing excellent written and verbal communication skills. Compensation and/or school credit is available, and hours are flexible to accommodate student schedules.
December 4, 2014
The 2015 Aerospace Maintenance Competition (AMC) skills event will be co-located with Aviation Week’s MRO Americas in Miami, Florida on Apr. 14-16, 2015. The 2015 AMC promises to be bigger and better with more teams and a larger audience – a battle of the best skilled maintenance professionals in the industry.
The AMC’s sole purpose is to raise awareness of the training and skills needed to provide safe and airworthy aircraft worldwide. Compete with current and future maintenance professionals as they test combined abilities against their peers.
Competition Categories include:
- Commercial Aviation
- General Aviation
Don’t miss the competition of the decade and see who will take home the William F. “Bill” O’Brien Award for Excellence in Aircraft Maintenance and the Charles E. Taylor Professional AMT Award.
Limited sponsorship opportunities are available. Contact Beth Eddy or Mimi Smith at Aerospace Marketing Group for more details: email firstname.lastname@example.org or email@example.com or call +1 561-279-4646.
Sign up your team to compete: Contact John Goglia at firstname.lastname@example.org or call +1 703-597-4502.
November 7, 2014
By Mohan S Perumal, Ramco Systems
The MRO is a key component to keeping aircraft in the air – safely and efficiently. The mechanic is called to do multiple things in servicing a component, an engine or an aircraft. These highly skilled and important functions are the heart and brain for the equipment and the industry. The more time s/he allocates to ‘actual’ servicing tasks, the better the outcome, for the customer, the public, the job and the MRO business.
Any ‘tool’ that reduces a mechanic’s paper work and other administrative tasks frees crucial time to do ‘real’ work – ‘wrench time.’ As a direct result, owners realize a cumulative positive impact on the business’ bottom lines.
Talk about stating the obvious!
In reality, exploring the deployment of technology-driven ‘tools’ into most MROs’ daily work routines brings to light several significant needs for improvement.
In this and subsequent articles we will explore the Information Technology (IT) infrastructure, systems and applications that can be used to enhance an MROs efficiency. This knowledge will, in turn, open doors for deployment of newer, tested and credible technologies to achieve even greater business benefits.
To set the stage, let us look at the simple yet profound example of the use of technology in fulfilling our banking needs. Most, if not all, of us seldom go to a bank these days. From reviewing statements to paying bills and transferring funds–it is done using smart phones, tablets or at least a computer! This reduces time expended on this routine task, freeing us to expend it on more valuable pursuits. This example has a serious parallel to the MRO workplace.
To begin, let us look at the routine task of labeling and tagging parts. The picture provides a simple evolution.
The change from hand written, paper labels to bar codes was good. However, only the part number and serial number could be bar coded. Today Quick Response (QR) codes can contain all the information available on a given article. The data can be generated and incorporated on a tag or in or on the component itself along with human-readable information. Scanning the QR code can provide information on time between overhauls (TBO), service bulletin incorporation, etc. The data will help decision making for picking articles and repairs and tracking performance.
A Radio Frequency Identification (RFID) can even store more information and does not require a scanner. Walking through the area, the tag can tell the person where an article is located, what its performance and/or life status. This allows distant decision-making and ensures the right part is picked for the right application.
These technical advances have increased efficiency and are routinely used on the airline operations and passenger side of the business, from the
electronic boarding passes on smart phones to the RFID checked bag tags that allow the routing of the bags to the correct flights. When such tools are already in action supporting the safety and efficiency of the aviation industry, it is time to deploy similar tools in MRO operations.
Here is a sample QR Code; use your smart phone QR code scanner available through a free app to read the information!
The views and opinions expressed in this article are those of the author’s and do not necessarily reflect the policy or position of Ramco Systems, hence shall not be liable for any damages arising out of the same.
October 2, 2014
By Daniel Fisher, Vice President of Legislative Affairs
Aviation stakeholders and lawmakers are once again gearing up for another round of Federal Aviation Administration (FAA) reauthorization lawmaking on Capitol Hill.
The current authorization, the FAA Modernization & Reform Act, expires on September 30, 2015. The reauthorization process, which should happen every few years, allows lawmakers to set funding levels and policy priorities for the agency. As Congress crafts new FAA legislation, threats and opportunities abound, and undoubtedly, old ideas will resurface, many that are detrimental to the aviation maintenance industry.
ARSA and its industry partners scored major victories in the FAA Modernization & Reform Act; however, our success was based on preventing detrimental policies from enactment. While ARSA is already engaging lawmakers on the association’s top legislative priorities, the industry will once again be playing defense to stop recycled, anti-contract maintenance proposals and countering false safety and economic arguments about aviation maintenance companies.
ARSA fully expects efforts to curtail contract maintenance on U.S. air carriers, drug and alcohol testing of foreign repair station employees, and mandatory inspections to resurface. Once a bad idea is unveiled in Washington it never disappears. Through education and engagement, ARSA and its members have laid a strong foundation to counteract interests opposed to our industry. However, those hostile to contract maintenance are well-funded, well-connected, and adept at swaying public perception.
Consequently, the aviation maintenance industry must remain engaged both with lawmakers and the media. Below are five activities every ARSA member company should do to ensure favorable policy outcomes in the next Congress:
1. Host candidates and elected officials to visit your facility. The most effective way for policymakers to understand the industry and see the role your repair station plays in the local community is through a company tour.
2. Attend ARSA’s Legislative Day on March 18, 2015. Stay tuned for Legislative Day/Symposium registration in the coming weeks.
3. Learn more about ARSA PAC. ARSA PAC is a special fund that enables the entire aviation maintenance industry to speak with a common voice in the political process and elect candidates who share its legislative goals.
4. Vote on November 3. Participation in the democratic process is an important part of active citizenship. ARSA encourages its members to vote – it’s one of your most basic and important democratic rights. You can’t complain about your member of Congress if you don’t vote!
5. Engage the media. Any opportunity you have to educate the media about contract maintenance’s excellent safety record and contribution to the local economy will help shape policy.
We need your assistance to ensure recycled, bad ideas don’t become terrible laws. ARSA’s legislative and communications team is standing by to facilitate your engagement with key audiences.
September 5, 2014
By Sarah MacLeod, Executive Director
We interrupt your regularly scheduled programming to bring aviation maintenance to a screen very near you…
Coming Soon: ARSA’s in the director’s chair. You’re the producer.
For over 100 years, aviation has captured the world’s imagination and inspired many to soar higher and faster in search of adventure and service of mankind. It’s a great drama with many great actors – from the pilot’s seat to the mechanic’s work station to the passenger cabin. Telling that story is central to ARSA’s mission.
Commercial Break: What is an Aircraft Mechanic?
A key way we communicate this narrative is through constant engagement with regulators. Our team of experts from the law firm of Obadal, Filler, MacLeod & Klein PLC works every day to manage the intersection of business and government. They write letters, attend meetings, make phone calls, provide advice and wear a path around Washington, D.C. and across the world to represent ARSA’s members.
Commercial Break: Beauty over the North Atlantic.
Working behind the scenes is powerful, but setting the scene for the public through media relations and positive publicity is essential. Filmmakers have taken to the skies for years, trying to capture and package the majesty of flight for audiences stuck on the ground. The catalogue of aeronautical motion pictures – from sensationalized feature films to sober documentaries – has covered nearly every corner of the flying world. While repair stations have made it to the screen, the industry still needs a central, seminal work that will tell the world who we are.
Commercial Break: Aircraft Mechanic Training.
The association has been working for months with a professional production company to develop a short documentary about the aviation maintenance industry. It will be the definitive profile of the industry for years to come. The piece will run on public television stations around the country as part of the Leading Edge series, which is hosted by former NFL coach and TV sports commentator Jimmy Johnson. The broadcasts will be a great way to get your message in front of an educated and influential audience.
Commercial Break: Aviation – The Invisible Highway.
But more importantly, the video will be a tool for you. The association will distribute it to members all over the world, who will use it to paint a picture of a dynamic, growing, technologically-sophisticated industry that is improving aviation safety and making major contributions to the global economy. Join this work by sponsoring the project and displaying your logo prominently at the end of the film. Your company will get visibility and recognition as an industry leader around the world for years to come.
Commercial Break: The FAA Talks Maintenance.
Through the examples in this piece, you’ve seen a small sampling of the industry’s catalogue of works. With your support, ARSA can produce one definitive work to show the world who you are and how vital aviation maintenance is to their lives and livelihoods. They can’t fly without you. Become a participating sponsor and be celebrated every time the credits roll.
Credits: Help ARSA tell your story.
August 7, 2014
By Brett Levanto, Director of Operations
Come together with us. Start planning now for ARSA’s 2015 Annual Repair Symposium.
Sarah has already described how important industry-wide cooperation is for ARSA and its members. Individually, we complete work and serve customers. Together, we enhance the maintenance industry and protect the flying public.
The repair station community must work together to guarantee the safety of crews and passengers worldwide. ARSA ensures that happens. The symposium is the perfect place to connect with officials from the FAA and other authorities, as well as key members of Congress and your colleagues. It is an opportunity to join aviation professionals from around the world and engage on issues that directly impact the maintenance industry. Indeed, last year’s conference created an opportunity for quick resolution — “ARSA Works: Engagement Sparks FAA Action.”
The 2015 Annual Repair Symposium will be held March 18-20 in Arlington, Va. For more information, visit our events page.
July 1, 2014
By Ciara Chambers
Access to regulatory, business, and legislative knowledge is one of the key benefits of ARSA membership. We are standing by for your calls, questions, or clarifications. The association will go a step further, though, and give you the tools to build your own knowledge before the problem even arrives.
Our recorded webinars and training sessions are one way ARSA will “teach you how to fish.” They’re all waiting for you; you can start a session right now.
One of the featured training courses available through ARSA is “How to Answer a Letter of Investigation.” In this session, ARSA Executive Director Sarah MacLeod outlines the steps for a company to take in order to answer a letter of investigation from the FAA in writing.
Regardless of the alleged violation, a company will want to handle the scenario in the same way, with a written response. As an “alleged violator”, this is how you tell your side of the story. MacLeod describes the effective format to properly respond to all of the allegations in a factual manner.
You don’t have to panic when you receive an LOI. Take 30 minutes right now to prepare yourself: sign up to view Sarah MacLeod’s training webinar. Editor’s note – Direct registration for this session is no longer available. Interested registrants should contact ARSA directly for assistance.
There was a popular movie released in 1985 about time travel; you might remember it. While the film didn’t choose to address aviation — a flying car in the last sequence doesn’t count — its year feels like a fitting destination for some ARSA time traveling. Let’s take a peek back at this very publication in December of 1985:
For the past 30 years, this association has used every means available to educate its members, inform the public, and communicate with government about the aviation maintenance industry. Then, as now, we have always sought to trumpet our successes and highlight every way that we have made things better for our members.
In the best of cases, we can simply step aside and let our members tell the story for us. In December of 1985, we did just that. Let’s look back:
Members Speak Out (December 1985)
We have been telling prospective new members as well as existing members how we felt they could benefit by joining ARSA. All of these “good things” which we say we can do for you, may seem vague and uncertain and perhaps you have considered such problems not really “my problems”.
Rather than repeat a list of typical items on which we feel ARSA can be effective, we would like to reprint a portion of a letter received from one of our members detailing his experience in a particular issue which was brought to our attention. We quote from his letter:
“We were in the process of expanding our powerplant repair station operations to include crankcase repairs when the FAA put a halt on our operations. They advised us to go through ‘Engineering’ to obtain official approval for such repairs.
However, our region couldn’t handle our request for approval because of lack of expertise in this field. In fact, some engineers in our region never heard of welding or repairing of crankcases and even said it would be better if I bought out another business that already had approval for that repair.
That’s when I called ARSA. I received your letter about the time I was ready to call my Congressman.
ARSA was on the problem immediately, and in fact, we were cutting through red tape in weeks. … ARSA’s persistence in finding us the ‘right’ people in the FAA to deal with won out. … We now have our approval.
That’s why I think that ARSA is a must for anyone in the repair station business in general aviation. At least, we now have knowledgeable spokesmen on our side to help us form ONE FAA with the same rules and guidelines for everyone.
Thank you again, ARSA, for your consideration and promptness in dealing with this matter.
George Czarnecki ,
President Central Cylinder Service, Inc.
Repair Station No. 312-9”
[View the edition here.]
Sound familiar? There is certainly more work to be done, but ARSA’s commitment to finding the “right” people and getting the “right” answers is as steadfast today as it was 29 years ago.
Central Cylinder Service is still an ARSA member. Learn more about them at http://www.centralcylinder.com/.