2015 – Edition 4 – May 8

The next time you catch yourself dancing to Edwin Starr’s “War”, imagine that you are celebrating the promulgation of world aviation regulations. This “WAR,” unlike Starr’s topic, could unify the aviation world.

This isn’t the first time I’ve evoked the 1969 song in ARSA’s communications, I am not even the brainchild of the concept of one set of rules of aviation maintenance. It was introduced during a breakout session on creating a single manual to satisfy multiple civil aviation authorities that was being used by a prominent international maintenance supplier.

Unfortunately, then as now, WAR is not on the verge of breaking out. In its absence, aviation maintenance providers must create the resources for performing work on an international scale.

Without a single world-wide regulatory regime, civil aviation authorities utilize national laws and bilateral aviation safety agreements (BASAs) to collaborate and to create avenues for mutual recognition. These government-to-government arrangements regulate the operation of international air services between countries (or in the case of the European Union, “communities”). The United States has entered into dozens of these cooperative contracts.

Regrettably, the many BASAs bearing American signatures do little for the maintenance community. Overarching agreement is great for the appearance of cooperation, but without robust maintenance implementation procedures (MIP), there is little of value to repair stations seeking to manage international responsibilities. For those few U.S. agreements that contain any consideration for maintenance operations, only Canada’s is truly reciprocal; our northern neighbors do not require the issuance of an additional certificate, saving the associated costs of applying for and maintaining it.

(Last year, ARSA reminded an FAA inspector of the U.S./Canadian MIP when three members – two repair stations and an air carrier – called for help while aircraft were stuck on the ground. The association got them in the air.)

Without our WAR, the international aviation world is far from peaceful; without MIPs what must one do for international customers and growth?

• When expanding internationally, research existing agreements between the United States and the potential new market. Without a BASA or MIP, find and translate the applicable regulations (not just for obtaining repair station certificates but for your customer’s maintenance requirements). Understand the costs involved in earning and maintaining certifications overseas. (See this month’s “A Member Asked,” for more on this calculation.)
• Follow Mark Twain’s wisdom: “When you need a friend, it’s too late to make one.” For global regulatory compliance forge ongoing relationships with international partners and regulators. Attend international meetings and seek information on similarly situated companies and their successes or failures. (See this month’s “Have You Seen This Person” to understand how ARSA advocates on behalf of its members internationally.)
• As leaders in a global industry, ARSA members help build a healthy worldwide community for aviation maintenance. The global aviation maintenance industry will surpass $100 billion in the next decade. There is opportunity across the world, but for repair stations to seize it they have to navigate a turbulent international regulatory world. Look for opportunities to promote international knowledge and understanding, acknowledge and prepare for differences in laws, regulations and personal relationships.

WAR would be good for quite a lot in aviation maintenance; the industry’s challenge is to avoid being world-weary before it breaks out.

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Hotline Features

ARSA Remembers: Fred Emery (1933-2015)

By Brett Levanto, Vice President of Communications 

On Wednesday, April 29, Frederick Joseph Emery passed away at his home in Washington, D.C.

Born in Buffalo, N.Y., Fred moved to the nation’s capital in 1963 to serve the FAA and Department of Transportation as a regulatory lawyer and eventually as Director of the Office of the Federal Register. While in public service, he remained connected with future legal minds as a professor of administrative law at Antioch Law School.

In 1980, Fred started The Regulatory Group, Inc. to advise government agencies on the rulemaking process. The firm provides both training and consultant services in regulation writing, policy development, training, indexing, management of regulatory systems and report writing. Fred’s son Andrew (one of his three children, along with nine grandchildren and countless friends) continues that work today as the Regulatory Group’s president.

Through his long career as public leader, mentor and coach, Fred has been an indelible part of the Washington, D.C. community. For ARSA and its members, his passing marks the loss of a great friend to the aviation community and cause to celebrate his long service on behalf of the American people.

A celebration of Fred’s life will be held on June 14, 2015, at 2:00 pm at the Thomas Room, University of Maryland golf course clubhouse, MD 193 and Stadium Drive, College Park, Md. Memorial contributions may be made to SOME or a charity of your choice.

ARSA on the Road – MRO Americas

By ARSA Communications Staff

From April 14-16, Miami was the center of the aviation maintenance world. On the exhibit floor and in the lecture halls, ARSA was there.

Brett Levanto and Crystal Maguire, the association’s vice presidents of operations and communications, attended Aviation Week’s MRO Americas. They visited association members, met with industry and media allies and took in the energy of the Aerospace Maintenance Competition (AMC).

Of course, the association also provided substantive value to the event’s agenda; Managing Director and General Counsel Marshall Filler joined the Tuesday-afternoon panel “Regs and Reality – The Status of the FAA’s Plans for the Future.” Alongside representatives from the industry, the FAA and ICAO, Filler brought his decades of experience to the table as the group explored how to better deal with safety challenges facing commercial aviation.

The association has invested considerable effort championing the value of event attendance. Whether through the voice of Executive Director Sarah MacLeod or on AviationPros or in the discussions on Aviation Week’s IdeaXchange forum, the message is clear: the business of the aviation community cannot be done without the personal interaction possible at professional events.

Getting out of the office is a great way to get things done.

“We’re a tiny piece of the big work of keeping the world flying safely,” Levanto said. “Here [at MRO Americas] we can put ourselves right in the middle of everything. Not only is it professionally rewarding, it’s personally gratifying to be face-to-face with the industry members whose work is so vital to our lives and livelihoods.”

Levanto and Maguire were on hand to celebrate AMC’s victors during the competition’s awards ceremony on April 16. Recognition was given to teams across six categories in a series of events that tested the skill, stamina and focus of both the professional mechanics and AMT students who had come to Miami to compete.

At an event like MRO Americas, the work of the association comes together. Through personal engagement and substantive excellence, ARSA represents the interests of the aviation community from the convention hall to the maintenance line.

Walk in ARSA’s shoes; click here see the photos from MRO Americas 2015.

Open House: SONICO Welcomes Congressional Staffer

By ARSA Legislative Staff

Seeds planted on Legislative Day didn’t take long to blossom as a staffer from Sen. Maria Cantwell’s (D-Wash.) office visited SONICO, Inc.

On April 2, Matthew McCarthy, Sen. Cantwell’s aerospace legislative assistant, toured the company’s Moses Lake, Washington facility and witnessed first-hand a repair station’s contributions to the local economy and aviation safety.  The visit resulted from SONICO Vice President Jim Perdue’s meeting with McCarthy during ARSA’s 2015 Legislative Day on March 18. In addition to his role for SONICO, Perdue is the current president of ARSA’s Board of Directors.

“Hosting congressional staff and lawmakers is the single most important grassroots activity repair stations can pursue,” said Perdue.  “It’s great exposure for your company and helps educate officials about the industry’s great work and economic activity.  We must engage back home to ensure bad ideas on Capitol Hill don’t turn into burdensome mandates.”

L-R: Matthew McCarthy, Sen. Cantwell’s Office; Art Wentworth, Sonico’s Quality Assurance Manager; Matt Davis, Sonico’s Maintenance Manager; and Jim Perdue, ARSA’s President and Sonico’s Vice President.

Sen. Cantwell is a key player in FAA reauthorization in her role as the top Democrat on the Senate Aviation Operations, Safety, and Security Subcommittee.  As such, discussions between Perdue and McCarthy focused on FAA repair station oversight and the reauthorization process.  Perdue also treated McCarthy to the new, ARSA-produced documentary, You Can’t Fly Without Us: The World of Aviation Maintenance.

Want to schedule a congressional facility visit?  ARSA’s legislative team is standing by to help!

Learn more about how your business can get involved in legislative advocacy at http://arsa.org/legislative/get-involved/.

Pride in Professionalism – Research Study Needs Input

By Brett Levanto, Vice President of Communications

The association was recently contacted by Mr. Hussain Alhallaf, a Ph.D. candidate at Florida Institute of Technology’s doctoral program in Aviation Sciences in the College of Aeronautics. Mr. Alhallaf is examining aviation professionalism and is seeking assistance from industry members through completion of an online questionnaire. Mr. Alhallaf’s research is the first to empirically study perspectives on professionalism and personal development in aviation.

Why does it matter? Mr. Alhallaf has seen first-hand the dangers of inattention in the cockpit (or, by extension, on the maintenance line): a friend barely walked away after failing to recover from a low-altitude stall. As a result, Mr. Alhallaf has chosen to dedicate his own professional career to studying the personal factors that ensure safety in the air. This research will be a seminal part of that work and the participation of the repair station community is vital to its success.

To participate, you may access the online survey via the following link (or by pasting the address into your browser): http://questionpro.com/t/ALRnkZSa9Y.  The questionnaire will take no more than 15 minutes to complete. 

In  addition to completing the survey, aviation professionals are encouraged to share it with contacts and colleagues. For more information, please contact Mr. Alhallaf directly via e-mail at halhallaf2014@my.fit.edu or by phone at (386) 847-7671.

By supporting academic research and donating time and input to the institutions that train the next generation of aviation professionals, ARSA is active in ensuring the future safety of the flying public. Get involved with us.

Road to Reauthorization: Another Day, Another FAA Hearing

By ARSA Legislative Staff

On April 28, the Senate Aviation Operations, Safety, and Security Subcommittee held its fourth hearing in a month as it prepares to draft the next FAA reauthorization bill.  The panel examined aviation safety and general aviation issues.

Hot topics included pilot training and rest and regional airline safety.  Witnesses were:

• Margaret “Peggy” Gilligan, Associate Administrator for Aviation Safety, Federal Aviation Administration
• The Honorable Christopher Hart, Chairman, National Transportation Safety Board
• Faye Malarkey Black, Interim President, Regional Airline Association
• Captain Chesley Sullenberger
• Mark Baker, President and CEO, Aircraft Owners and Pilots Association

Witness testimony, opening statements, and a live video is available at 1.usa.gov/1EsKxzo.

Last Chance to Complete ARSA Member Surveys

By ARSA Communications Staff

The association’s annual member survey is in your primary contact’s inbox. Don’t miss your opportunity to contribute to ARSA’s work on behalf of the industry.

This year’s survey is supplemented by a separate set of recruitment questions that will fill gaps in existing data regarding the aviation maintenance workforce. This separate questionnaire is to be forwarded to the persons responsible for human resource activities.

Responses are invaluable to ARSA staff as we work with regulators and lawmakers, develop content on key issues and find solutions to the challenges most impactful to the repair station community. This information will also be provided to your company as a tool for developing plans and responding to market needs. We are capturing your snapshot of aviation maintenance – make it useful.

To review last year’s survey results, click here.

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Legal Briefs

“Directly in Charge” of the New Contract Maintenance Rule

By Daniel B. Fisher, Vice President of Legislative Affairs

Last month, Legal Briefs introduced readers to the congressionally-mandated final rule on air carrier contract maintenance requirements.

The regulation was the result of a decades-long battle over the safe and efficient practice of contracting air carrier maintenance. ARSA’s engagement reduced the impact on maintenance providers and air carriers. The association focused on ensuring the FAA and Congress utilized definitions that mesh with operational reality and industry practice. Unfortunately, not all language is optimal, but it is certainly better as a result of the association’s concerted efforts.

The new regulation, which takes effect March 4, 2016, defines “covered work” that will result in several mandates and restrictions.

Is Your Work Covered?
“Covered work” may be accomplished by “any person who performs maintenance, preventive maintenance, or an alteration for a certificate holder other than a person who is trained by and employed directly by that certificate holder.” The first step to understanding the regulation’s impact on repair stations and their customers is to look at the definition of “covered work” (which adopted Congress’ language). That is:

• Essential maintenance that could result in a failure, malfunction or defect endangering the safe operation of an aircraft if not performed properly or if improper parts or materials are used;
• Regularly scheduled maintenance; or
• A required inspection item (as defined by the Administrator).

Thanks in part to ARSA’s engagement, the FAA revised OpsSpecs D091 (replaced “substantial maintenance” with “essential maintenance”) and updated guidance material (Notices 8900.102 and 8900.103) before the final law was passed. Therefore, “essential maintenance” is any on-wing accomplishment of any maintenance or alteration that the air carrier designates as required inspection items (RII).

Of course, “essential maintenance” encompasses an RII, adding confusion and redundancy, which ARSA pointed out to both Congress and the FAA. Ultimately, RII is defined in §121.369(a)(2) and contains nearly identical language to the FAA’s (and Congress’) essential maintenance definition making the analysis for both the same.

“Regularly scheduled” maintenance is more problematic. According to the rule’s preamble, “regularly scheduled” maintenance would occur “in cases in which a component (e.g., an engine, landing gear) is scheduled for removal and overhaul, or when other off-wing maintenance is scheduled at some regular interval.” In its comments, ARSA encouraged the agency to limit “regularly scheduled” to an air carrier’s in-depth maintenance visits that take an aircraft out of service for a planned and predetermined amount of time, such as “C-check,” “heavy check” and “heavy maintenance”. Unfortunately, the agency’s adopted definition lacks specificity and will prove challenging for air carriers to implement.

New Mandates & Restrictions
Once it is determined that the maintenance provider is accomplishing covered work, new mandates apply to the air carrier relationship.

First, the air carriers must be “directly in charge” of the activity. This term has a longstanding definition and meaning. While the air carrier must be available for consultation on matters requiring instruction or decision, it doesn’t need to physically observe and direct each maintenance provider constantly. Put simply, when the maintenance provider is performing “covered work” (essential maintenance, regularly scheduled maintenance and required inspection items) the air carrier must be available for discussion, but doesn’t need to have a constant presence or personally oversee the work’s performance.

The rule also contains mandates for repair stations. It requires that maintenance providers perform all “covered work” in accordance with the air carrier’s maintenance manual. This is also nothing new and is unnecessary and duplicative to §§ 121.363(a)(2) and 145.205.

Importantly, the FAA also appears to restrict maintenance providers’ ability to perform “covered work” by requiring it to be carried out under the “supervision and control” of the air carrier. “Supervision and control” isn’t specifically defined in the regulation; in fact, in its notice of proposed rulemaking, the agency suggested that the air carrier must have a constant presence for personal observation of work, effectively forcing micromanagement of part 145 certificated repair stations.

ARSA adamantly opposed and succeeded in encouraging the agency to eliminate its definition. In the rule’s preamble, the FAA states “supervision and control” equates to “directly in charge.” In other words, maintenance providers may only perform “covered work” if the air carrier is available for consultation on matters requiring instruction or decision.

The final rule also requires the development of policies, procedures, methods, and instructions for the accomplishment of contract maintenance. Air carriers should clearly delineate the technical instructions its maintenance providers must follow. While the language is ambiguous and is further complicated by an individual carrier’s particular manual requirement; it is redundant because the air carrier already must provide that information under § 121.369.

Finally, the regulation expands existing reporting requirements, mandating that air carriers “provide a list of maintenance providers that includes the name and physical (street) address, or addresses, where the work is carried out for each maintenance provider that performs work for the certificate holder, and a description of the type of maintenance performed at each location.”

ARSA asserts the new mandate duplicates the requirements of § 121.369(a), as well as operations specifications requirements for identifying persons who perform essential maintenance (see Operations Specifications paragraph D091). The burden for both the air carrier, and the FAA, in maintaining the list in a specified format is greatly underestimated and is purely for the benefit of the agency’s auditors (i.e., the Department of Transportation’s Inspector General and the Government Accountability Office).

Conclusion
While the final rule is a mixed bag, ARSA helped ensure it will have minimal impact on maintenance providers and well as their customers. Figuring out what constitutes “regularly scheduled” maintenance will plague air carriers; however, repair stations come out unscathed. ARSA will continue engaging the FAA to ensure implementation is consistent with congressional intent and educate the industry on the rule’s new requirements.

Join the association for a webinar on complying with the maintenance rule on May 28. In the meantime, get back to “covered” work!

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.

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ARSA on the Hill

Regulatory Outlook

FAA Agrees with ARSA on Work Instructions

By Brett Levanto, Vice President of Communications

On April 20, ARSA received a positive response from the FAA to a May 29, 2014 request for clarification of (1) a repair station’s ability to develop and use work instructions and (2) the exact requirements for accessibility of relevant maintenance data during the performance of maintenance functions.

It its response, the agency agreed with each of ARSA’s recommendations and specifically confirmed that a repair station may create work instructions for its technical personnel. “An appropriately certificated and rated repair station may develop its own work instructions/shop travelers based on manufacturer’s maintenance data and/or other methods, techniques and practices acceptable to the FAA,” the letter said.

Prior to this clarification, the Miami Flight Standards District Office (FSDO) and the FAA’s Southern Region Office had determined the use of internally developed work instructions, even with only minor differences from manufacturer information, was unacceptable without prior FAA approval.

The FAA also contradicted the determination of the local and regional offices that personnel must have “physical possession” of the manufacturer’s maintenance data even if it was not relevant to the work being performed. The FAA agreed with ARSA that – as stated in 14 CFR part 145.109(d) – appropriate documents must only be “current and accessible when the relevant work is being done.”

The success of ARSA’s request, which had been jointly submitted by Metal Improvement Company LLC, eliminates an unnecessary limitation placed on southern region repair stations without regulatory foundation.

Final Documents/Your Two Cents

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.

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Quality Time

Leaning Business Processes

By Bill Peterson, University of Tennessee’s Center for Executive Education © 2015 William Peterson ALL RIGHTS RESERVED

Lean has been an invaluable tool in manufacturing for 30 years. As with many businesses, it can be a great tool for aviation maintenance providers across all operations. The processes used in the front office will have a big impact on the hangar or shop floor.

The work of AMTs is ripe for “leaning,” but even when the technicians have completed their five s’s, they often are stuck in idle – waiting for assignments, information, paperwork and tooling, or management decisions.

It’s time to apply Lean to aviation MRO on a whole new plane. Finding the waste and bottlenecks in business processes and applying Lean countermeasures can reduce turnaround times dramatically.

Although administrative departments were created to support the primary mission of the maintenance organization, at many repair stations these processes—such as accounting, finance, engineering, safety, environmental, human resources, material management and inspection review—have become bottlenecks. Often, in an effort to increase effectiveness, these departments have evolved into specialized, functional silos with expanding and expansive management processes.

In many ways, administrative processes can constrain the hangar or shop floor. Some examples:

• Up-to-the-last-minute contract negotiations and approvals reduce lead times needed by mechanics. Also, by executing proposals and contracts without standard work/product definitions, sales departments create scenarios that are difficult for purchasing, quality, customer service and maintenance to execute.
• Material management departments use too much of a production cycle’s lead time to order or source key parts; or, purchasing departments order too many of a particular part that is not yet needed because of a “deal” on quantity.
• Internal representatives of regulatory agencies provide unnecessarily broad policy interpretations that constrain production.
• Engineering departments use up lead time by delaying the submittal of necessary documentation and/or by requiring a long queue for the turnaround of revision requests submitted by maintenance.
• Facilities, human resources and IT departments provide one-size-fits-all solutions that optimize their own processes at the expense of the production they serve.
• Delays in strategic and tactical management decisions chew up lead time, leaving less time for execution.

A few MRO companies already have elevated their Lean efforts to the “administrative plane” and documented impressive results. For example, after two years of applying Lean to administrative processes such as cost capture and material management, an aviation component MRO increased gross profit margins 5 percent, decreased late-delivery penalties 93 percent, decreased warranty repairs 50 percent and decreased work in progress 72 percent, all while paring inventory 39 percent. The company now has excess capacity in facilities and staff, which enables future growth and expansion without additional capital outlay.

Leaders of MRO operations have a tremendous opportunity—if not an obligation—to apply Lean analytical tools to their administrative processes. Focus on these areas, and you are sure to take your continuous improvement efforts to a whole new level.

Bill Peterson is a lean consultant and practitioner and creator of the workshops Lean Applied to Business Processes, Disciplines of Speed, and Lead Smarter. He teaches in the University of Tennessee’s Department of Graduate and Executive Education. 

Editor’s Note: This piece first appeared in Aviation Week, October, 2011. Reproduced with the author’s permission.

Membership

Member Spotlight – Ameco Beijing

By ARSA Communications Staff

Aircraft Maintenance and Engineering Corporation (Ameco Beijing), a joint venture between Air China Limited and Lufthansa German Airlines, was established on August 1st, 1989. The joint venture agreement was signed for 40 years.

Ameco Beijing provides maintenance, repair and overhaul services for airframe, engines and components of commercial aircraft. It also offers services in training, engineering and logistics, as well as GSE calibration. Ameco Beijing authorized by CAAC acts as a Designated Modification Design Organization Representative (DMDOR). It is a MRO provider licensed by numerous national aviation agencies including CAAC, FAA and EASA.

Today, Ameco Beijing employs about 6,000 employees. Ameco Beijing offers services to nearly hundred domestic and international carriers in addition to Air China. In recent years, it has established long-term cooperation and partner relationships with many major international airlines. In 2005, Ameco Beijing was awarded as “The Best Asia/Pacific Independent MRO Operation of the Year” during MRO Asia.

Ameco Beijing has always kept itself up-to-date in technologies, service concepts, market trends and in supporting the aviation industry with world-class services.

ARSA’s broad international membership is well-represented by Ameco Beijing. With its European and Asian parentage, the repair station is a perfect example of international growth in MRO markets: the bigger things get, the closer we become.

To learn more, visit: http://www.ameco.com.cn/.

Have You Seen this Person?

Each month, the hotline spotlights key regulatory, legislative, and business leaders making important contributions to the aviation industry. This month we look at Thomas Mickler, Washington representative for the European Aviation Safety Agency (EASA).

Thomas Mickler became EASA’s Representative in Washington, D.C. in August 2014.

Before his arrival in the American capital, Mr. Mickler was Head of Standardization at EASA. While there, he worked closely with the European Commission and European States to ensure the correct implementation of European Aviation Safety Regulations to ensure a high and uniform level of aviation safety across the continent.

Before joining the EASA team in November 2009, Mr. Mickler served as Director Air Operations, Personnel Licensing, Accident Investigation and Aviation Safety Programmes at the German Ministry of Transportation. He was responsible for the oversight of Air Operations and Personnel Licensing for the German Luftfahrt-Bundesamt (LBA), as well as the German Accident Investigation Body. As a member of various committees – including the European Council Aviation Working Group – he contributed to a number of Europe-wide aviation safety initiatives.

Mr. Mickler’s long aviation career includes representation at the International Civil Aviation Organization and membership on the Air Navigation Commission. He also worked for the German LBA on a broad range of type certification projects.

Through Mr. Mickler, ARSA is excited to continue its strong relationship with EASA. For association members, the European agency’s Washington representative can be a conduit to information and response on matters related to international certification and operation.

On April 29, ARSA staff welcomed Mr. Mickler for his first visit to the association’s Alexandria, Virginia office. Over lunch, the group discussed international regulatory issues and reviewed the areas where EASA and ARSA continue to work together on behalf of the aviation maintenance industry.

Take Advantage of ARSA’s Members Getting Members Program, Get 10% Off on Membership Dues

The best form of advertising is word of mouth. Use the Members Getting Members Toolkit to recruit an ARSA member and your company will receive a discounted membership rate for your next membership term. Get more information at http://arsa.org/membership/members-getting-members/.

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Target Your Message: Advertise Today in ARSA’s Newsletters and Website!
ARSA has a menu of advertising opportunities for arsa.org, the hotline and the ARSA Dispatch. Take advantage of these great opportunities today to showcase your company, a new product or event. For more information go to http://arsa.org/advertise/

Exhibit, Sponsor the 2016 Repair Symposium
As the maintenance industry’s top event devoted exclusively to regulatory compliance, the ARSA Symposium attracts a highly qualified professional audience. Use this opportunity to promote your company while showing support for ARSA. Get more information at http://arsa.org/news-media/events/arsa-symposium/arsa-annual-repair-symposium-sponsorship/

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A Member Asked…

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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.

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Upcoming Events

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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.

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