2015 – Edition 10 – November 5
Table of Contents
Sarah Says
Tricks of the Trade
By Sarah MacLeod, Executive Director
The “trick” – if you want to call it that – to regulatory compliance is to read the rule. First and every time, in every case, for every issue or question: Start with “what does the rule say?”
ARSA’s staff previews the hotline’s regulatory compliance training questions with key contacts across the industry. It’s our chance to apply quality control measures to the questions and answers so each month we can provide a training and learning tool for members (see this month’s edition).
In September one particular question, regarding § 145.213, tripped up several of our “guinea pigs”:
True or False: A certificated repair station must inspect each article for which it has completed work to determine whether the entire article is airworthy before it can be approved for return to service.
FALSE! A certificated repair station must inspect each article upon which it has performed maintenance, preventive maintenance or alterations before approving that article for return to service (§ 145.213(a)); but the approval for return to service is only for the work performed (§§ 145.213(b)) and 43.9(a)(4)).
Missed the questions? Go back and test yourself on the other three questions from that month. While you are taking the close reading test, remember a member comment: “[Question 4] is a trick question and most people will say ‘true,’ but we know different! I say trick question, but what I really mean is it makes you read what the rule really says.”
Isn’t that interesting? A “trick” question is simply one where you have to read the rule, understand what it says and apply it to the real world. As the voice of (and sometimes to) the highly regulated aviation community, ARSA’s mission has always been to shine light on simple truth: regulatory compliance starts and ends with reading and truly understanding the regulations.
To serve this end, the association provides analysis, instruction and guidance for repair stations and regulators. Ensure that you are taking the best possible advantage of these resources:
(1) Never miss a regulatory compliance training sheet in the hotline. They are built to easily print (front and back) for wide distribution. Add the tests to your employees’ training requirements and track completion.
(2) Explore ARSA’s other training resources – both live sessions and on-demand recordings – and help build future offerings by telling us what you need.
(3) Distribute the association’s newsletters to your entire staff (get our administrative team the contacts and we’ll make it easy).
(4) Regularly access and review the regulatory issue pages on the ARSA website. Is there a topic you’d like to have a quick reference sheet available for? Let us know.
(5) Ask ARSA first! If you have a question on regulatory compliance, ask your regulatory experts. (I often ask members that have requested assistance from the agency only to become more confused or be met with resounding silence whether they go to the IRS for tax advice. It seem incongruous to me that an ARSA member would not seek information from independent experts before approaching a government agency, but hey, I am not “tricked” by much anymore.)
Halloween is over, so neighborhood “trick or treat” requests are silenced for a year. For the aviation industry – one of the most heavily regulated – the only “trick” that matters is to read the rule first, every time. (We’ll leave the “treats” up to you.)
Hotline Features
Aviation Week Network 2016 MRO of the Year Award
By Sarah Hartley, Communications Coordinator
Nominations are open for the 2016 Aviation Week Network MRO of the Year Awards presented by Aviation Week & Space Technology. Each year the awards recognize outstanding organizations in the following categories:
(1) Outstanding Airline Maintenance Group
(2) Military Center of Excellence
(3) Leading Independent MRO Organization
(4) Innovative Supplier/OEM Services Provider
Winners will be announced at the MRO Americas Conference and Exhibition in April 2016. To nominate an organization submit this form before Jan. 4, 2016.
FAA Issues AC 21-44A, Leaves Unanswered Questions
By ARSA Regulatory Staff
AC 21-44A, Issuance of Export Airworthiness Approvals Under 14 CFR Part 21, Subpart L was issued on Oct. 1, the same date the FAA published a final rule allowing production approval holders (PAH) to issue FAA Form 8130-3 as an Authorized Release Certificate (ARC). In spite of having taken great pains in the preamble to the part 21 amendments to distinguish between an airworthiness approval (something only the FAA or an authorized designee can issue) and an ARC (something the PAHs will be able to produce effective March 29, 2016), paragraph 8 of the AC states there are three kinds of “Export Airworthiness Approvals”: (1) Form 8130-4, Export Airworthiness Certificate issued by the FAA or its authorized designee for aircraft, (2) Form 8130-3 issued by the FAA or an authorized designee for aircraft engines, propellers and articles, and (3) yes, you guessed it … an ARC issued by the PAH without a designee!
Now that the issue of whether an ARC is an export airworthiness approval is “resolved,” the FAA and EASA will have to clarify the Technical Implementation Procedures (TIP) because currently the certification required on Form 8130-3 for articles imported by the EU must be made by the FAA, which, of course, will not be the case when it’s issued by the PAH after March 29, 2016.
The remainder of the AC primarily addresses the requirements for exporters under part 21, subpart L.
ARSA recognizes there are many unanswered questions about how the authorities are going to roll out these Form 8130-3 changes in view of the current Maintenance Annex Guidance (MAG) Change 5 implementation date of Dec. 8. The transition period for the new requirements was the subject of an Oct. 7 letter to the FAA and EASA signed by ARSA as well as 12 other trade associations. There are other issues such as how the requirements will interface with Order 8130.21H, which the FAA reaffirmed in the preamble is guidance and therefore not mandatory. Nevertheless, that won’t stop individual FAA offices from holding their designees to that order.
One key issue: in view of the agencies’ position that domestic shipments from PAHs to U.S. repair stations are exports under the TIP, how will the PAH know which country the article is being exported to when even the U.S. repair station ordering the part won’t know until the part is installed in a top assembly? Order 8130.21H contains the permissive “should” when describing the recommended statement that the article complies with the importing country’s requirements. Undoubtedly, Order 8130.21H will need to be revised once the agencies figure all this out. There is NOTHING in the regulations that requires the form to state that it meets the requirements of a specific country UNLESS that country requires it. Whether the statement is there or not, it still has to meet those requirements.
Certainly, the fallout from the new MAG 5 requirement is significant as PAHs and repair stations cope with the new mandates and the uncertainty of when the changes will take effect. In the meantime, the two agencies can start by giving the industry the transition period requested in the trade associations’ letter from Oct. 7.
More within this edition of the hotline…
[Hotline Feature] Comparison: FAA-EASA TIP Revision 5
[ARSA Works] MAG Change 5 – Aviation Coalition Requests Orderly Transition Period
[ARSA Works] EASA Model Supplement Revision 2 Now Available
[Legal Briefs] More on the MAG Change – Section A
[Training] MAG Change 5 – Briefing & Listening Session Recap
[A Member Asked] Early Compliance with § 21.137(o)
Comparison: FAA-EASA TIP Revision 5
By ARSA Regulatory Staff
On Sept. 15, the FAA signed agreements with two international regulatory partners, EASA and Transport Canada (TCCA):
- The FAA-EASA Bilateral Aviation Safety Agreement, Revision 5 of the Technical Implementation Procedures is available at http://arsa.org/wp-content/uploads/2015/10/EUTIP.pdf.
- The FAA-TCCA Bilateral Aviation Safety Agreement, Amendment 1 of the Implementation Procedures for Airworthiness is available at http://arsa.org/wp-content/uploads/2015/10/Canada-IPA-Amdt-1.pdf.
A document highlighting the specific changes to the FAA-EASA TIP is available at http://arsa.org/wp-content/uploads/2015/10/ARSA-TIP-Change4vs5-20151013.pdf (to view the old and new text comparison for each highlighted section, download a copy of the PDF to your desktop and open in Adobe Reader).
More within this edition of the hotline…
[Hotline Feature] FAA Issues AC 21-44A, Leaves Unanswered Questions
[ARSA Works] MAG Change 5 – Aviation Coalition Requests Orderly Transition Period
[ARSA Works] EASA Model Supplement Revision 2 Now Available
[Legal Briefs] More on the MAG Change – Section A
[Training] MAG Change 5 – Briefing & Listening Session Recap
[A Member Asked] Early Compliance with § 21.137(o)
ARSA Works
To see all the ways ARSA works as the voice of the aviation maintenance industry, visit our ARSA Works page.
Aviation, Education Groups Request Time to Help Get 147 Right
By Brett Levanto, Vice President of Communications
On Oct. 26, a team of aviation and education industry groups requested an extension to the comment period for the FAA’s proposed update to 14 CFR part 147. The group requested more time to consider and analyze the long-awaited notice of proposed rulemaking (NPRM) to help the agency produce an effective final rule, which has not been substantively updated since the 1970s.
The effort, led by the Aviation Technician Education Council (ATEC), was supported by representatives from aviation groups and technical education interests. In addition to ARSA, the submission was signed by:
Aerospace Maintenance Council
Aircraft Electronics Association
Aircraft Owners and Pilots Association
Airlines for America
Aviation Suppliers Association
Helicopter Association International
Modification and Replacement Parts Association
National Air Carrier Association
National Air Transportation Association
Regional Airline Association
STEM Education Coalition
University Aviation Association
“[The final rule will impact] not only the hundreds of institutions that educate our workforce, but also the thousands of businesses that rely on AMTS graduates to keep aircraft in flight,” the group explained. “With the additional time requested, the aviation industry and its partners in technical education will help the agency develop a rule that supports schools, aids students at the beginning of a rewarding career and serves an important and growing industry.”
As the agency reconsiders the deadline, interested parties can now focus on substantive comments. Stay tuned…
ARSA, AIA, GAMA Support Development of AFS Guidance Methodology
By ARSA Regulatory Staff
On Oct. 9, ARSA joined the Aerospace Industries Association (AIA) and the General Aviation Manufacturers Association (GAMA) on comments to the Flight Standards Service’s (AFS) Draft Order 8000.AFSGDD, “Flight Standards Service Guidance Document Development.”
The draft follows the recommendations of the Consistency of Regulatory Interpretation Aviation Rulemaking Committee (CRI ARC), on which all three associations participated. The comments applaud the FAA for working to broadly apply standardization principles already employed by the Aircraft Certification Service (AIR) in Order 8100.16.
“The proposed FAA Order 8000.AFSGDD represents an important step in promoting consistency of regulatory interpretations and application,” the comments state. “As stated in the CRI ARC, one of the root causes of inconsistency was inadequate and nonstandard regulatory application. The ARC highlighted that the absence of guidance development instructions for FAA personnel allowed for guidance to be published that was not based [on] or consistent with regulations which contribute to inconsistent application of the rule and confusion.”
To assist with the process, the associations provided suggested clarity in 8000.AFSGDD to ensure that rules and statutes take precedence over guidance material. With careful review for consistency, the final order will be an effective tool for regulators while shaping aviation safety and business practices.
MAG Change 5 – Aviation Coalition Requests Orderly Transition Period
By Brett Levanto, Vice President of Communications
On Oct. 7, a coalition of aviation trade associations sent a letter to the FAA and EASA addressing a major issue in the international agreement between the two bodies. The complication: documentation of aircraft parts that are subject to the jurisdiction of both the European Union and the United States.
The letter was signed by representatives of ARSA, the Aerospace Industries Association, the Aircraft Electronics Association, the Aircraft Owners and Pilots’ Association, Airlines for America, the Aviation Suppliers Association, the Cargo Airline Association, the General Aviation Manufacturers Association, Helicopter Association International, the International Air Transport Association, the Modification and Replacement Parts Association, the National Air Carrier Association and the National Air Transportation Association. The letter’s delivery was announced on Oct. 8 during an international regulatory panel at ARSA’s 2015 Strategic Leadership Conference (SLC) in Washington, D.C.
The coalition provided a means for smooth implementation of the most recent update to the Maintenance Annex Guidance (MAG) issued under the Bilateral Aviation Safety Agreement between the United States and the European Union. A BASA is a government-to-government agreement meant to simplify regulatory oversight across borders. Unfortunately, the Sept. 9 MAG update imposes an unrealistic compliance deadline on U.S. industry to conform its practices to those of the EU.
The MAG change creates a clear requirement for a specific FAA Form – the 8130-3 – to accompany all new parts installed by U.S. repair stations on articles that may be exported to the European Union. Unfortunately, under current FAA rules the agency must issue the document, usually through a production approval holder’s (PAH) designee.
“Even though the U.S. and EU regulatory systems are equivalent, our members’ hands are effectively tied,” said Marshall S. Filler, managing director and general counsel for ARSA. “As things currently stand, in order to serve European customers many U.S. repair stations will be legally obligated to possess parts documentation that U.S. manufacturers cannot issue.”
The FAA addressed that problem in a final rule published Oct. 1 that will allow U.S. PAHs to issue Form 8130-3 without needing an FAA designee. Unfortunately, aerospace manufacturers will be unable to implement the new privilege until the final rule’s March 29, 2016 effective date, with longer timelines required for FAA regulatory review and approval.
To allow for a smooth and orderly transition to the new MAG requirement, the industry letter requests the FAA and EASA delay its implementation date for six months after the effective date of the FAA final rule.
“The FAA has provided the remedy for the Form 8130-3 problem [with the Oct. 1 publication of its new rule],” Filler continued, “The simple, common sense solution is to give U.S. industry the time it needs to align its quality systems with the new MAG requirement. In the meantime, repair stations should not have to suffer adverse consequences when the fundamental problem lies outside their control.”
Since the letter’s submission, both the FAA and EASA have indicated general agreement with the coalition’s position. The agencies are working together to address industry’s concerns and smooth the implementation of the MAG change.
More within this edition of the hotline…
[Hotline Feature] FAA Issues AC 21-44A, Leaves Unanswered Questions
[Hotline Feature] Comparison: FAA-EASA TIP Revision 5
[ARSA Works] EASA Model Supplement Revision 2 Now Available
[Legal Briefs] More on the MAG Change – Section A
[Training] MAG Change 5 – Briefing & Listening Session Recap
[A Member Asked] Early Compliance with § 21.137(o)
EASA Model Supplement Revision 2 Now Available
By ARSA Communications Staff
The model EASA supplement was created for U.S.-based, FAA-certificated repair stations who work, or wish to work, on civil aeronautical components under the regulatory control of EASA. The model supplement’s second revision incorporates MAG change 5, specifically adding newly defined terms to the list of definitions and updating language regarding new part tagging requirements.
The ARSA member price for the publication is $300.00; non-members can purchase the model supplement for $600.00. The revision is available free to previous purchasers.
More within this edition of the hotline…
[Hotline Feature] FAA Issues AC 21-44A, Leaves Unanswered Questions
[Hotline Feature] Comparison: FAA-EASA TIP Revision 5
[ARSA Works] MAG Change 5 – Aviation Coalition Requests Orderly Transition Period
[Legal Briefs] More on the MAG Change – Section A
[Training] MAG Change 5 – Briefing & Listening Session Recap
[A Member Asked] Early Compliance with § 21.137(o)
Legal Briefs
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
More on the MAG Change – Section A
By Crystal Maguire, Vice President of Operations
Last month’s Legal Briefs focused on the recent change to Section B (pages 74-120) of the United States (U.S.)-European Union (EU) Maintenance Annex Guidance (MAG), which provides guidance for repair stations located in the United States for obtaining an EASA Part-145 certificate.
The MAG contains two other parts, Section A (pages 10-73), which provides the framework for EASA and FAA coordinated oversight of certificated entities, and Section C (pages 121-165) that provides guidance for EU-based maintenance organizations to obtain an FAA part 145 air agency certificate. This month’s column will review the revisions to Section A, next month’s will look at Section C.
Section A, entitled “Authority Interaction,” provides guidance to FAA and EASA workforces and will therefore have an impact on the certification, on-going compliance and renewal process for repair stations in both jurisdictions.
Most notably, MAG Change 5 clarifies the process by which industry may elevate a disagreement on MAG implementation (see section A, part I, paragraph 6 [page 13]). For repair stations located in the United States, the path to resolution looks like this:
EU-based repair stations path to resolution of differences:
Section A also provides a method for the FAA and EASA to “observe…each other’s activities, and to discuss significant audit findings and reports as a result of these activities” (see section A, part II [page 16]). In other words, while the bilateral agreement provides mutual acceptance of regulatory systems, the authorities use the sampling inspection system (SIS) to audit each other. The results of these “observations” are reported to and discussed by the JMCB. (The JMCB is a committee led by FAA and EASA directors of flight standards, which meets at least annually to review the reports and discuss and vet potential MAG revisions.)
For industry, SIS equates to an audit of repair stations by representatives from both EASA and the FAA. Visit schedules are set a year in advance with the EU team’s calendar for U.S.-based repair station visits provided by Dec. 31 and FAA submitting its schedule for EU-based repair stations by Sept. 1. Facilities are chosen based on risk assessments (indeed, many of the recent revisions address the method by which the FAA will make its selections); areas with a large concentration of repair stations that allow for a diverse sampling are favorable.
If your facility is lucky enough to host such an event, you can generally expect at least two visitors, one from each of the certificating authorities. You will also likely see your local contact (either the Flight Standards District Office FAA Aviation Safety Inspector [ASI] or AA representative) and, for those located in the United States, the FAA regional coordinator.
While the purpose of the SIS visits is to ensure proper agency implementation of the bilateral agreement and implementation procedures, they can, and often do, result in regulatory “findings” for certificated entities. If findings are documented as a result of the SIS visit, the domestic authority is responsible for following-through on “level 1 findings” (as defined in EASA 145.A.95), all other findings are handled by the local offices through corrective action planning.
Finally, though relatively unchanged, Section A includes the special conditions applicable to U.S.-based repair stations seeking EASA approval (section A, part V, paragraph 1 [page 31]) and EU-based organizations approved in accordance with FAA 14 CFR part 145 (section A, part V, paragraph 2 [page 33]). Those special conditions are regurgitated in checklists the authorities use to document general surveillance (e.g., section B, appendix 3 [page 117]) and SIS visits (for U.S.-based repair stations, see section A, appendix 2 [page 41], for EU-based repair stations see section A, appendix 8 [page 70]).
Recent post-SIS visit correspondence suggest the authorities still have some work to do to ensure audit systems coalesce with the bilateral agreement and implementation procedures. For instance, under the agreement, repair stations must comply with FAA regulations plus the special conditions provided for in the MAG; however, documented findings subsequent to SIS visits at U.S.-based repair stations sometimes cite EASA regulations. Industry must therefore ensure understanding of the governing regulations, bilateral agreement and implementation procedures to ensure it has the regulatory knowledge to properly respond to “demands” that may or may not be tied to regulatory requirements.
Stay tuned next month for an analysis on the MAG’s Section C, addressing implementation procedures for E.U.-based maintenance organizations.
More within this edition of the hotline…
[Hotline Feature] FAA Issues AC 21-44A, Leaves Unanswered Questions
[Hotline Feature] Comparison: FAA-EASA TIP Revision 5
[ARSA Works] MAG Change 5 – Aviation Coalition Requests Orderly Transition Period
[ARSA Works] EASA Model Supplement Revision 2 Now Available
[Training] MAG Change 5 – Briefing & Listening Session Recap
[A Member Asked] Early Compliance with § 21.137(o)
ARSA on Parliament Hill
Liberal Party Flies High in Canadian Elections
By Christian A. Klein, Executive Vice President
In October, Canadian voters went to the polls in much-anticipated federal elections. As the United States’ closest trading partner and the only country with which the FAA shares a truly reciprocal bilateral relationship, ARSA members should keep an eye north of the border.
Justin Trudeau’s Liberal party shocked the political world on Oct. 19, winning 184 out Canada’s 338 parliamentary seats – an outright majority. The Liberals’ decisive victory, which polls and pundits failed to anticipate, means Trudeau will be Canada’s next prime minister and brings an end to almost ten years of Conservative Party rule in Canada. The 44-year old Trudeau, son of former Prime Minister Pierre Trudeau, is now the second youngest prime minster in Canadian history.
Prime Minister Stephen Harper was the night’s biggest casualty. Harper resigned as Conservative party leader shortly after the results, which relegated his party to official opposition, were announced.
The New Democratic Party (NDP) under the leadership of Tom Mulcair is also licking its wounds. In what was billed as a “change” election, NDP clearly failed in its efforts to convince voters of its vision for a new direction in Canada. The party lost more than half its parliamentary seats along with its opposition status.
The new Liberal government is poised to usher in sweeping policy changes that will inevitably impact the economy, society and Canada’s role in the world. Trudeau has promised increased taxes on upper earners, more spending on health care, marijuana legalization, a realignment of Canada’s defense resources and withdrawal from the bombing campaign against the Islamic State.
Trudeau has also said he will make infrastructure investment a top priority. He plans to run federal budget deficits for up to $10 billion over the next two fiscal years to strengthen the backbone of Canada’s economy by building roads, bridges, public transit and ports.
As Trudeau’s government invests in the Canadian economy by strengthening its infrastructure “backbone,” aviation businesses working (or expanding) across the border could play a crucial role in supporting the nation’s development.
To learn more about Canadian government, visit: www.canada.ca/en/government/system.
To review the government’s “New Building Canada Plan” for infrastructure investment, visit: www.infrastructure.gc.ca/plan/.
Regulatory Outlook
EC Investigates Maintenance Manual Availability
By Daniel Fisher, Vice President of Legislative Affairs
The European Commission (EC) has opened a preliminarily investigation into how manufacturers may be limiting the availability of maintenance manuals and possible anti-competitive effects.
According to a statement by the EC, it “is closely monitoring competitive conditions as regards maintenance of engines and components of large commercial aircraft.”
Individual companies and aviation industry trade groups (including ARSA) received questionnaires seeking in-depth information on certain practices of specific design approval holders. ARSA’s responses focused on aviation safety rules and how the national aviation authorities’ failure to enforce regulations even-handedly effects competition.
While an encouraging development in the international aviation maintenance world, industry shouldn’t expect quick action as the commission is in the very early stages of determining if a full investigation is warranted.
This list includes Federal Register publications, such as final rules, Advisory Circulars and policy statements, as well as proposed rules and policies of interest to ARSA members. To view the list, click here.
Quality Time
Full Series: I Need a DER, or Do I?
By Peter Lauria, Principal, JT Consulting, LLC © 2015 Peter Lauria ALL RIGHTS RESERVED
In the July 2014 hotline, Peter Lauria began with a simple question: what can a repair station do with articles that require repairs beyond those listed in the manufacturer’s documents?
Six installments later, Lauria has completed the journey from initial assessment to completed data package. Re-trace his path to ensure you’re asking the right questions and getting the right answers:
(1) Repair vs replace: Which is the best option when damage is noted on an article in your shop or facility?
(2) The major/minor determination: The distinctions between repairs and alterations, as well as between major repairs and minor repairs.
(3) History and types of delegations: How the FAA arrived at delegating some of its engineering functions and which functional areas are delegated.
(4) Selecting and contacting a DER: which DER(s) might be the best fit for approval of a major repair, based on the DER’s specialty, location and delegated areas?
(5) Developing the data package: a short summary of the three types of data in a complete package, and guidance for developing the package.
(6) Coordinating with the DER and completing the package: set the scope of the DER’s role, complete the package and get an authorized FAA Form 8110-3 “Statement of Compliance with Airworthiness Standards.”
Peter Lauria (www.jtcengineering.com) has over 30 years’ experience with aircraft manufacturers, test equipment manufacturers, repair stations and airlines. He is the owner and principal of JT Consulting, LLC., providing engineering consulting, DER services and ODA guidance.
Training
The association’s training program is provided through Obadal, Filler, MacLeod & Klein, PLC, the firm that manages ARSA. To go directly to OFMK’s online training portal, visit potomaclaw.inreachce.com. To learn more about the association’s training program and check course availability, visit arsa.org/training.
Personal Development: I Leapt From the Stratosphere. Here’s how.
On Oct. 24, 2014, Alan Eustace donned a custom-built, 235-pound spacesuit, attached himself to a weather balloon, and rose above 135,000 feet, from which point he dove to Earth, breaking both the sound barrier and previous records for high-altitude jumps.
Hear his story of how — and why.
MAG Change 5 – Briefing & Listening Session Recap
By Brett Levanto, Vice President of Communications
On Nov. 3, ARSA’s regulatory team hosted a discussion – headlined by Managing Director and General Counsel Marshall S. Filler – of Change 5 to the U.S.-E.U. Maintenance Annex Guidance (MAG). The session engaged members in order to complement the association’s assistance to industry as the FAA and EASA work to effectively implement the change.
Filler detailed the regulatory implications of change 5, and then overviewed ARSA-led efforts to address issues resulting from the “new” requirement for FAA Form 8130-3 to accompany parts installed by U.S. repair stations on articles that may be exported to the European Union. Before opening discussion, Filler closed by addressing the MAG change’s remaining “open questions.”
Briefing outline:
(1) Important MAG Dates
(2) What changed as it relates to documentation requirements for new parts?
(3) What new components are covered by section B, appendix 1, paragraph 10 of MAG CHG 5?
(4) Other paragraph 10(k) requirements pertaining to new parts
(5) What are the current and future regulatory requirements for issuing Form 8130-3 for new parts?
(6) What components are likely to be excepted from the paragraph 10(k) requirement?
(7)What are the other open questions?
(a.) Used parts
(b.) New to Used??
(8) Questions/Discussion
For ARSA members who were unable to attend, a recorded version is available for purchase. Click here for more information and to access the recording.
For specific issues or questions regarding the MAG change or any other issue, ARSA members are encouraged to use the “Ask ARSA First” function to contact the association.
More within this edition of the hotline…
[Hotline Feature] FAA Issues AC 21-44A, Leaves Unanswered Questions
[Hotline Feature] Comparison: FAA-EASA TIP Revision 5
[ARSA Works] MAG Change 5 – Aviation Coalition Requests Orderly Transition Period
[ARSA Works] EASA Model Supplement Revision 2 Now Available
[Legal Briefs] More on the MAG Change – Section A
[A Member Asked] Early Compliance with § 21.137(o)
The association’s training program is provided through Obadal, Filler, MacLeod & Klein, PLC, the firm that manages ARSA. To go directly to OFMK’s online training portal, visit potomaclaw.inreachce.com. To learn more about the association’s training program and check course availability, visit arsa.org/training.
On Demand Training: Overhauling Overhaul
By ARSA Communications Staff
Overhauling Overhaul – Part 43’s Most Misunderstood Word
Instructor: Sarah MacLeod
Description: In June, the FAA 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. This course provides the regulatory context, an overview of the term, a review of its interpretations and tools for applying it in a business context.
On-Demand – Available Anytime
Click here to register and get 90-days access to the recording.
The association’s training program is provided through Obadal, Filler, MacLeod & Klein, PLC, the firm that manages ARSA. To go directly to OFMK’s online training portal, visit potomaclaw.inreachce.com. To learn more about the association’s training program and check course availability, visit arsa.org/training.
On Demand Training: Aircraft Parts in Three Parts
By Brett Levanto, Vice President of Communications
Regulations Impacting the Purchase of Aircraft Parts
Instructor: Sarah MacLeod
Description: The course will review the civil aviation regulations in Title 14 Code of Federal Regulations (14 CFR) that impact the purchase of civil aviation parts, as well as other requirements that should be considered.
On-Demand – Available Anytime
Length: 60 minutes
Click here to register and get 90-days of access to the recording.
Regulations Impacting the Receiving, Inspection and Stocking of Aircraft Parts
Instructor: Sarah MacLeod
Description: The course will review the civil aviation regulations in Title 14 Code of Federal Regulations (14 CFR) that impact the receiving, inspecting and stocking of civil aviation articles for maintenance purposes, as well as other requirements that should be considered.
On-Demand – Available Anytime
Length: 60 minutes
Click here to register and get 90-days of access to the recording.
Regulations Impacting the Sale of Aircraft Parts
Instructor: Sarah MacLeod
Description: The course will review the rules in Title 14 Code of Federal Regulations (14 CFR) that impact the sale of civil aviation articles, as well as other requirements that should be considered when selling parts.
On-Demand – Available Anytime
Length: 60 minutes
Click here to register and get 90-days of access to the recording.
Interested in all three? Click here to purchase them together and save.
The association’s training program is provided through Obadal, Filler, MacLeod & Klein, PLC, the firm that manages ARSA. To go directly to OFMK’s online training portal, visit potomaclaw.inreachce.com. To learn more about the association’s training program and check course availability, visit arsa.org/training.
Regulatory Compliance Training
Membership
2015 ARSA Strategic Leadership Conference Attendees
Thank you to the ARSA member organizations and partners that attended the 2015 Strategic Leadership Conference from Oct. 7-9. Their participation and engagement made the 2015 SLC a success.
Have You Seen this Person? Dr. Fang Liu, Secretary General of the International Civil Aviation Organization (ICAO)
By Sarah Hartley, Communications Coordinator
Dr. Fang Liu, ICAO Secretary General
In August 2015, Dr. Fang Liu was appointed to a three-year term as Secretary General of the International Civil Aviation Organization (ICAO). In October, ARSA Executive Vice President Christian A. Klein welcomed Dr. Liu to this new role at a Washington, D.C. reception for industry allies. As the voice of the international aviation maintenance industry, ARSA will work with ICAO’s leadership to insure strong commerce and reliable safety around the world.
Before joining ICAO, Liu filled a number of roles at the General Administration of Civil Aviation of China (CAAC). She served as legal counsel, deputy director, director and deputy director general of the Department of International Affairs and Cooperation. Liu oversaw China’s international air transport policy and regulations, bilateral and multilateral relations with international and regional organizations including ICAO, the World Trade Organization, the Asia-Pacific Economic Cooperation (APEC), the European Union and the Association of Southeast Asian Nations.
Over the course of her 20 years at the CAAC, Liu was elected chair of the Aviation Group of APEC and was nominated by China to participate in the ICAO Air Transport Regulation Panel. She also served as an expert on mediation and dispute resolution and was chief negotiator for the Chinese government for bilateral and multilateral air transport agreements with foreign countries.
Liu earned a PhD in international law at Wuhan University in China and a master’s degree in air and space law at Leiden University in the Netherlands. She is the director of the Association of Air Law of China and of the Association of Private International Law of China, and has published articles and delivered lectures on a wide range of topics in international air transport regulation and air law. She speaks Chinese and English and has knowledge of French.
To learn more about this international aviation expert, click here.
Take Advantage of ARSA’s Members Getting Members Program, Get 10% Off on Membership Dues
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Exhibit, Sponsor the 2016 Repair Symposium
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Q: Will the FAA allow early compliance by production approval holders (PAHs) wishing to issue FAA Form 8130-3 prior to the effective date of the new part 21 rule (section 21.137(o))?
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.
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.
More within this edition of the hotline…
[Hotline Feature] FAA Issues AC 21-44A, Leaves Unanswered Questions
[Hotline Feature] Comparison: FAA-EASA TIP Revision 5
[ARSA Works] MAG Change 5 – Aviation Coalition Requests Orderly Transition Period
[ARSA Works] EASA Model Supplement Revision 2 Now Available
[Legal Briefs] More on the MAG Change – Section A
[Training] MAG Change 5 – Briefing & Listening Session Recap
AVMRO News Portal
ARSA strives to provide resources to educate the general public about the work of the association’s member organizations; should you need to provide a quick reference or introductory overview to the global MRO industry, please utilize AVMRO.ARSA.org.
AVMRO Industry Roundup
ARSA monitors media coverage on aviation maintenance to spread the word about the valuable role repair stations play globally by providing jobs and economic opportunities and in civic engagement. These are some of this month’s top stories highlighting the industry’s contributions.
You can explore these stories through ARSA’s Dispatch news portal.
Upcoming Events
Industry Calendar
MRO Asia-Pacific – Singapore – November 3-5
Dubai Airshow – Dubai, UAE – November 8-12
EAAP Human Factors in Aviation Safety Conference – Derby, UK – November 9-10
ALTA Airlines Leaders Forum – San Juan, Puerto Rico – November 15-17
NBAA2015 – Las Vegas, Nevada – November 17-19
Airline E&M: Central & Eastern Europe Conference – Tallinn, Estonia – November 18-19
Aerospace Meetings Brazil – Sao Paulo, Brazil – December 8-10
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the hotline is the monthly publication of the Aeronautical Repair Station Association (ARSA), the not-for-profit international trade association for certificated repair stations. It is for the exclusive use of ARSA members and federal employees on the ARSA mailing list. For a membership application, please call 703.739.9543 or visit http://arsa.org/membership/join/. This material is provided for educational and informational purposes only. It does not constitute legal, consulting, tax or any other type of professional advice. Law, regulations, guidance and government policies change frequently. While ARSA updates this material, we do not guarantee its accuracy. In addition, the application of this material to a particular situation is always dependent on the facts and circumstances involved. The use of this material is therefore at your own risk. All content in the hotline, except where indicated otherwise, is the property of ARSA. This content may not be reproduced, distributed or displayed, nor may derivatives or presentations be created from it in whole or in part, in any manner without the prior written consent of ARSA. ARSA grants its members a non-exclusive license to reproduce the content of the hotline. Employees of member organizations are the only parties authorized to receive a duplicate of the hotline. ARSA reserves all remaining rights and will use any means necessary to protect its intellectual property.
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