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2015 – Edition 6 – July 2

the hotline 1984


Table of Contents

Hotline with Christian Klein

Hotline Features

Meet the Interns

ARSA Works

Legal Briefs

ARSA on the Hill 

Regulatory Outlook 

Quality Time

Training 

Membership

AVMRO News Portal 

Upcoming Events


Hotline with Christian Klein – Maximize ROI in Three Simple Steps

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:

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.

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Hotline Features

 Minutes to Midnight – ARSA Unveils FAA Countdown Clock

By ARSA Communications Staff

On June 23, ARSA unveiled its countdown to the FAA Modernization & Reform Act of 2012’s expiration. The current law, which expires at the end of Sept., has officially entered its final 100 days.

The association – in concert with a number of aviation industry allies – has been working for months to help Congress craft a reauthorization bill that will allow the FAA to support American aviation and provide world-class service on behalf of the flying public. Congressional leaders have been calling for a “transformational” overhaul of the agency and the time is drawing near for that inspiration to become reality.

“With 100 days until the FAA’s current authorization law expires, the aviation industry awaits congressional action,” said Daniel B. Fisher, ARSA’s vice president of legislative affairs. “While there have been encouraging signs of progress, failure to enact long-term, stable FAA reauthorization legislation will cost real jobs and undermine the competiveness of the U.S. aviation industry.”

House Transportation & Infrastructure (T&I) Committee Chairman Bill Shuster (R-Pa.) recently highlighted certification reform and a re-design of the air traffic control (ATC) system as his top priorities for reauthorization. While behind-the-scenes work has begun and battle lines have been drawn, the reality is that time is running out.

Considering the political situation, Fisher concluded: “It’s our shared responsibility to serve the flying public. If we expect the FAA to be the world’s preeminent aviation safety organization, Congress must give the agency the certainty it needs as soon as possible. If that clock strikes zero before the president’s signature is on a new FAA bill, we will have failed the pilots, crewmembers, controllers and mechanics that work every single day to keep the world safely in flight, not to mention the businesses and families depending on them. That’s simply not an option.”

See how much time is left, visit arsa.org/FAA-countdown.

 ARSA on New TSA Administrator – Good Security is Always Good Business

By ARSA Communications Staff

Daniel B. Fisher, vice president of legislative affairs for the Aeronautical Repair Station Association (ARSA), released the following statement after the Senate voted on June 22 to confirm Coast Guard Vice Adm. Peter Neffenger as the new administrator of the Transportation Security Administration:

“ARSA congratulates Peter Neffenger on his confirmation to lead the Transportation Security Administration. As TSA continues the repair station security rule’s implementation, the aviation maintenance industry looks forward to working with the agency to ensure it understands that for ARSA members good security is good business regardless of government oversight.”

 ARSA Remembers: Jay Pardee

By ARSA Communications Staff

Jay Pardee, the FAA executive who was instrumental in multiple initiatives that greatly improved aviation safety, passed away suddenly on June 12. He was 68.

Pardee devoted his 44 years of FAA public service to improving the safety and reliability of aircraft engines and using data to reduce risk in commercial aviation through the work of the Commercial Aviation Safety Team (CAST), which he helped create.

“Jay Pardee’s leadership and innovation is in large part responsible for today’s outstanding U.S. commercial aviation safety record” said FAA Administrator Michael Huerta.

Pardee pioneered the establishment of ETOPS (Extended Range Twin-Engine Operations), which is one of the major contributors to the drop in the U.S. commercial fatal accident rate.

With CAST’s creation in 1997, Pardee helped forge a remarkable government and industry partnership that became the model for the world. By 2008, CAST achieved an 83 percent fatality risk reduction in commercial aviation through the voluntary adoption of safety enhancements. In that year, CAST was presented the Collier Trophy in recognition of its achievements.

He also helped transform the focus of aviation safety management from a forensics approach to a more prognostic approach through the establishment of the Aviation Safety Information Analysis and Sharing (ASIAS) program.

“Jay was always supportive of mutually beneficial meetings,” said Sarah MacLeod, ARSA’s executive director. “He never dismissed the industry’s concerns or solutions merely because they weren’t aligned with the agency or his own view of a situation. With his ability to listen and understand multiple positions, the solutions he endorsed were always feasible.”

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Meet the Interns

 Meet the Interns: Josh Klein, Communications Intern

By Josh Klein

I was born in the suburban town of Manorville, New York, 70 miles east of New York City. After graduating high school in 2010 I began my studies in Materials Science and Engineering at the University of Illinois at Urbana-Champaign. After eight weeks of engineering, I realized that science labs were not my interest and switched to a dual degree in Mathematics and Political Science. I loved Illinois corn country so much that I decided to stay at UIUC even though I was no longer studying engineering, a celebrated focus of the institution.

During my studies, I became fascinated with the intersection of policy and mathematics. While at first I associated public policy with law and political science, I realized that data, mathematics and statistics are also vital to the policy process. Following this interest, I spent that last two years of undergrad focused almost entirely on statistics and economics – trying to gain a deep understanding of the quantitative underpinnings of public policy.

After four years of undergraduate study, I thought I still had a lot to learn so I decided to pursue a graduate education. Ultimately, I enrolled in a three-year dual-master’s program in Public Policy and Computer Science at the College of William and Mary. I finished the first of those years this past May.

I was drawn to ARSA because of another realization I had: All of the mathematics, law, statistics and economic and political theory I learn mean nothing if I am unable to apply them in practice. Where the rubber meets the road is working for a real organization on real policy issues. ARSA was the best place for me to be able to develop the skills necessary to be active and successful in the policy arena. I believe that my quantitative background will be an asset to ARSA’s policy work.

After I finish my final two years of school I hope to enter the public policy or consulting fields. I believe that my experiences with ARSA will put me well on my way to being successful in that goal.

Meet the Interns: Katelynn Johnson, Legal Intern  

By Katelynn Johnson

I was born and raised in Buffalo, New York, and went off to college at John Carroll University in Cleveland, Ohio. I majored in Political Science and minored in English and Philosophy. I enjoyed my opportunity to dabble in different concentrations, gaining unique perspectives from each. Looking for a broader experience, I studied overseas in London and was able to travel to nine European countries. I returned to the United States and graduated from JCU in 2014.

This past fall, I returned to Buffalo and began studying at the State University of New York Buffalo Law School. During my first year, I made the decision to immerse myself in a new city before returning for my second year in September. As a law student, I was naturally drawn toward the nation’s capital and the endless legal possibilities it offers. My time so far with ARSA has been the embodiment of that possibility; I am enjoying this opportunity to experience D.C. and its suburban neighbors.

Before joining ARSA as a legal intern, I didn’t know much about the aviation maintenance industry. The extent of my knowledge stemmed from personal experiences – as a result of having family all over the country, I’ve been flying since I was very young. I was introduced to the association professionally by my uncle, David Latimer, a member of ARSA’s Board of Directors.

I enjoy forcing myself to broaden my knowledge in new areas of law – my last internship was for a medical malpractice firm – so I am excited to learn more about the behind-the-scenes work that’s helped me to fly safely since I boarded my first aircraft as an 8 year old.

I hope to use the skills I have learned during my first year of law school and contribute them to my work at ARSA. Every day I learn something new, and my time here will prepare me for my professional life, which I hope will be spent in a small firm.

 Meet the Interns: Sarah Hartley, Communications Intern

By Sarah Hartley

I’m a native of Norman, Oklahoma, a graduate of the University of Tulsa and a recent Washington, D.C. transplant. I chose TU because although I grew up just one mile from the University of Oklahoma, I wanted to branch out. Tulsa was the perfect fit, offering all of the perks of a small school plus the added bonus of NCAA Division One athletics. After graduating from Tulsa in May, I made the trip to the nation’s capital and joined the ARSA communications team.

In college, I studied communications and public relations and interned for a number of different organizations: a PR and consulting firm, a private foundation, a non-profit, a university and a large corporation. Each of these experiences helped me improve my writing and PR skills, so I figured it was time to add an association to the list and could think of no better place than right outside Washington, D.C.

This is the land of opportunity for recent college graduates and I hope to launch my career in public relations here while also living as a post-grad in an exciting, new city. Working for ARSA this summer is a great starting point.

I put my communication skills to good use every day by monitoring industry news, writing and editing content, updating websites, formatting and distributing publications and providing other communication-related services to ARSA and on behalf of Obadal, Filler, MacLeod & Klein, the firm that manages the association.

After a few years of real world PR experience, my tentative plan is to go to graduate school so I can work in higher education administration and one day become the communications director of a college or university. Until then, school’s in session for me right here in support of the aviation maintenance industry.

 OFMK Intern Program

By Brett Levanto, Vice President of Communications

Obadal, Filler, MacLeod and Klein, PLC, the firm that manages the Aeronautical Repair Station Association, continually accepts law and graduate student applications for its internship program. Interns will gain firsthand 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.

To submit an application, click here.

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ARSA Works

To see all the ways that ARSA is working as the voice of the aviation maintenance industry, visit our ARSA Works page.

 Aviation Coalition Shows Government How to Count

By ARSA Regulatory Staff

On June 4, a coalition of aviation trade associations took the first step towards solving the aviation maintenance workforce crisis by helping the government to define it. The group, spearheaded by the Aviation Technician Education Council (ATEC), asked the Standard Occupational Classification (SOC) Policy Committee and the Office of Management and Budget (OMB) to revise the SOC system to more accurately reflect the aviation maintenance industry.

A broad alliance, including ARSA, the Aerospace Maintenance Council, Airlines for America, the Cargo Airline Association, the General Aviation Manufacturers Association, the National Air Carrier Association, the National Air Transport Association,  the Regional Airline Association and a Former Member of the National Transportation Safety Board, joined ATEC in submitting comments to the SOC revision process, the results of which are set for implementation in 2018.

The SOC system provides the framework for all occupational statistics collected and disseminated by federal agencies. For federal statistical purposes, it determines precisely which occupations exist and has a significant impact on the legislators, educators, employers and job seekers who utilize that data. The aviation maintenance industry has been stuck in a void – trapped under incorrect classifications – for years. Within the current system, nearly all aviation maintenance professionals are classified into a single occupation titled “Aircraft Mechanics and Technicians.”

The group requested that this lone category be replaced with three separate occupations: certificated mechanics, certificated repairmen and non-certificated technicians. Classifying workers using FAA certification is the most logical and useful method; since aviation safety rules use the same definitions to dictate precisely who is allowed to perform maintenance, preventive maintenance and alteration tasks.

Along with a requested clarification of the “Transportation Inspectors” category, the submission proposed elimination of “Avionics Technicians” as a distinct category. These professionals should be tracked based upon certification, ATEC and its allies contend, just like every other aviation maintenance worker.

“Data empowers organizations to make sound decisions,” says Ryan Goertzen, ATEC President, “With Today’s SOC structure we can’t build a world class work force because the data is unreliable and inaccurate to capture our industry needs.”

 Celebrate the Maintenance Workforce, Help Build its Future

By Brett Levanto, Vice President of Communications

Nominations are open for the AMT Next Gen Awards.

To grow the aviation maintenance workforce of the future, the industry must celebrate those young, talented professionals already working on flight lines and in component shops every day to ensure the safety of the global flying public. By spotlighting the men and women on whom the world relies for safe transport, repair stations can attract new talent while re-enforcing their commitment to a world-class workforce.

“This year [AMT Magazine] will celebrate 40 aircraft maintenance professionals less than 40 years of age who clearly demonstrate the talent, ambition and characteristics of the Next Generation Aircraft Maintenance Professional,” said Ron Donner, chief editor of AMT Magazine. “It is not a ranking, but rather a listing of individuals who have shown initiative, a capacity, or have made an impact to the aviation maintenance industry.”

Know somebody who should be an example for the entire industry? Click here to submit a nomination.

For more information on the program, click here.

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Legal Briefs

The Perils of Ambiguity

By Ryan Poteet, Regulatory Affairs Manager

In the highly regulated world of aviation maintenance, knowing the rules ensures your business stays compliant. So what happens when a word has more than one meaning? How about when the everyday vernacular departs from legal parlance?

In the aviation industry Title 14 of the Code of Federal Regulations (CFR) is the bible and we hang on every word. Unfortunately, neither the aviation safety rules nor agency guidance is consistent; the same word can have different meanings from one rule[1] or document[2] to the next. Unfortunately, the agency’s inconsistencies carry over to industry manuals, which fail to define operative terms and use common dialect to direct regulatory activities. By relying on everyday word usage, audits will be less than enjoyable and civil penalties can result.

Let’s take the use of the words “should” and “shall” since they are used to convey a mandate, a recommendation, or something in between. Many—if not most—of us use the word “should” to indicate a recommendation. For instance, you should jog facing oncoming traffic, or you should match your belt to your shoes. Agency guidance seems to agree. Aircraft traffic controllers are instructed to use the word “should” when “a procedure is recommended.” ASIs are similarly instructed that the word “indicates actions that are desirable, permissible, or not mandatory, and allow flexibility.”[3] On the other hand, the word “shall” connotes a duty or obligation.[4] Both Title 14 and agency guidance comport with the dictionary definition; the word “shall” indicates “directive information,” used to communicate an imperative regarding mandatory or prohibited actions.[5]

The problem is that everyday usage of a word can become “legally” incorrect.[6] If the rule, guidance or a manual fails to define a term and use it appropriately, an operator can find that what it thought was a recommended procedure is a mandate. An air carrier encountered this exact problem by interpreting its fueling procedures manual (FPM) one way and having its ASI read it another.[7]

The airline believed conducting certain receiving tests during fuel deliveries were merely advisory because the FPM stated the tests “should” be conducted. At trial the administrative law judge (ALJ) assessed a civil penalty for failing to follow the FMP. The ALJ looked at other facts,[8] but made a simplistic decision: the dictionary defines should as the past tense of shall. As such, the company had a duty to perform the tests.

This is a perfect example of when a word’s everyday usage can result in a finding of non-compliance. It is imperative that operative phrases be defined. Better yet, avoid using “should” and “shall” altogether. Order 8900.1 even discourages their use.[9] Instead, use strong verbs such as “must” to convey an obligation, or “may” for discretionary circumstances.[10] By defining or removing ambiguous verbs in a manual, you increase the likelihood that employees follow its directions and ASIs (and ALJs) find compliance.

[1] Compare the definition of article in § 21.1(b)(2) with the definition of that same word in § 145.3(b).
[2] Compare FAA Order JO 7110.65V, ch. 1, § 2, ¶ 1-2-1 (Apr. 3, 2014) (defining the word “should” to mean a “procedure is recommended”) with FAA Order 8900.1, vol. 1, ch. 1, § 2, ¶ 1-26(L) (May 29, 2014) (stating “should” indicates an “expectation”).
[3] FAA Order 8900.1, vol. 1., ch. 1, § 2, ¶ 1-26(L) (Sept. 13, 2007); the most recent revision instructs that “should” indicates actions that are expected and when an expectation cannot be met, what was done to comply must be documented, FAA Order 8900.1, vol. 1, ch. 1, § 2, ¶ 1-26(L) (May 29, 2014).
[4] Black’s Law Dictionary (10th ed. 2014) (“[h]as a duty to; more broadly, is required to”); see also
14 CFR § 1.3(b)(1) (“[s]hall is used in an imperative sense”).
[5] 14 CFR § 1.3(b)(1); FAA Order 8900.1, vol. 1., ch. 1, § 2, ¶ 1-26(J) (May 29, 2014); FAA Order
JO 7110.65V, ch. 1, § 2, ¶ 1-2-1 (Apr. 3, 2014) (Air Traffic Control); FAA Order JO 7610.4J, Ch. 1 § 2, ¶ 1-2-3 (Jul. 12, 2001) (Special Military Operations).
[6] See, e.g., MacMillian’s Dictionary (online ed.) (noting that “[s]hould can sometimes be used as the past tense of shall, for example, in indirect speech introduced by a verb in the past tense: I hoped that I should not need to defend myself.”); Black’s Law Dictionary (6th ed. 1990) (defining should as “[t]he past tense of shall; ordinarily implying duty or obligation although usually no more than an obligation of propriety or expediency”).
[7] See FAA v. Alaska Airlines, Inc., FAA Docket No. CP03NM0003, DMS No. FAA-2003-15056 (2003).
[8] The airline also lost its case before the ALJ because other terms indicated that the testing was required.
[9] FAA Order 8900.1, vol. 3, ch. 32, § 1, ¶ 3-2121(G)(4) (“Terms that command actions should be clearly defined, such as “checked,” “set,” and “as required.” Since auxiliary verbs such as “may” and “should” are ambiguous and can create room for doubt, they should not be used when a definite action is commanded.”).
[10] Office of the Federal Register, Federal Register Document Drafting Handbook, Introduction, ¶ B (1998 and 2011 Revisions), available at http://www.archives.gov/federal-register/write/handbook/ddh.pdf.

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ARSA on the Hill

Reauthorization Update: Everything Old [and Bad] Is New Again

By Daniel Fisher, Vice President of Legislative Affairs

News on Capitol Hill is an FAA reauthorization bill could appear in the House of Representatives any day and amendments hostile to the aviation maintenance industry and its customers are once again percolating to the surface.

Lawmakers are pulling out the same old tricks to drive up costs on repair stations and restrict the expanding global maintenance market. As I’ve said before: Once a bad idea is unveiled in Washington, it never goes away. Here are some of the bad ideas we will likely see again:

  • Imposing unnecessary background checks on aviation maintenance workers.
  • Prohibiting new FAA-certificated foreign repair stations.
  • Expediting drug and alcohol requirements on foreign repair station employees.
  • Mandating surprise FAA inspections at overseas maintenance facilities.

Of course, these are unnecessary, lack a safety rationale, hurt U.S. competiveness and violate international agreements.  Nonetheless, politics often trumps policy, and powerful interests will push for their amendments to receive consideration.  ARSA and its members will be ready to go to battle on these recycled, bad ideas.

Unfortunately, a threat is emerging on Capitol Hill to impose new costs on the alternative parts sector.  Possible reauthorization language could mandate an unnecessary and duplicative FAA rulemaking pertaining to the identification and marking of “influencing parts.”  The current regulatory framework (including rules and related guidance) dealing with all aircraft parts, particularly “life-limited” and so-called “influencing parts,” has a proven safety record. Unfortunately, without any safety justification, self-interested parties are targeting the alternative parts industry by pursuing anti-competitive policies that will increase costs for repair stations, private aircraft owners and operators, small and large businesses, air carriers and the flying public.

The FAA has limited resources and many congressional mandates. Forcing the agency to conduct an unnecessary rulemaking is a misallocation of scarce funding and creates inefficiencies. Furthermore, small businesses, which are predominant in the alternative parts sector, will bear the economic burden. No business can afford the time and few have the inclination to respond to extraneous proposals and implement unnecessary rules.

Congressional leaders have prioritized an FAA reauthorization framework that will streamline regulatory processes and provide for greater collaboration with industry; an effort that is supported by a majority of lawmakers. To go beyond this basic structure by imposing burdensome mandates without any real safety benefit would only misdirect limited agency resources from serving the aviation community and the flying public.

ARSA is leading the way in opposition to efforts to impose redundant and excessive regulatory burdens on the aviation maintenance sector and its customers.  Can we count on your support?  Email me at daniel.fisher@arsa.org to learn what you can do to advocate for your company and your industry.

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Regulatory Outlook

 ARSA on the Road: Filler Moderates at FAA-EASA Conference

By ARSA Communications Staff

On June 11, ARSA’s Managing Director and General Counsel Marshall S. Filler moderated the maintenance panel at the 2015 FAA-EASA Conference in Brussels, Belgium. Joined by regulators and industry representatives, the discussion addressed interim and long-range mechanisms to reduce redundant requirements and surveillance activities for Approved Maintenance Organizations (AMOs).

In addition to Filler, the panelists were:

  • Juan Anton, Maintenance Regulations Section Manager, EASA
  • Steve Douglas, Manager Aircraft Maintenance Division, FAA
  • Flavio Izzo, EAQG MRO Relationship Growth Str. Leader, International Aerospace Quality Group (IAQG)
  • Todd Duncan, Chairman, Duncan Aviation
  • Rainer Lindau, VP Quality Management, Lufthansa Technik

Though the group’s suggestions covered a broad range of strategies, many focused on involvement by the International Civil Aviation Organization (ICAO) or some other body that could play the role as single oversight authority. Specific proposals included development of guidance, creation of oversight networks and establishment of more international agreements for joint certification and surveillance.

The association’s leadership in the important discussions of international maintenance issues is leverage for every ARSA member to help build a healthy, global future for the industry. Keep track of aviation industry events by visiting the association’s industry calendar.

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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arsa-20141203

Quality Time

Editor’s note: The views and opinions expressed by contributing authors do not necessarily state or reflect those of ARSA and shall not be used for endorsement purposes.

Legal Waypoints – Are Your Crown Jewels Safe?

By Steven E. Pazar, Attorney at Law, spazar@pazarlaw.com

QualityTime

Click here to learn more about Pazar Law.

Steven counsels businesses operating in high-risk industries – including aviation – he provides templates, tools and training that will improve contracting efficiency, close deals faster and control costs.

 To deal with risk, ask the right questions:

 Question 1
How long would it take for someone to download critical data from a repair station computer onto a small thumb drive, put it in their pocket, and walk right out the door?

Best guess for even a novice hack – probably a minute or less.

Question 2
How long would it take to detect the incident, or even investigate the scope of the loss?

Probably days of IT, legal and management time and effort – if you even notice the breach at all.

Question 3
How long will it take to recover from this type of incident?

Getting back to normal will likely take months and the damages could accrue for years into the future.

We don’t think of aircraft repair stations as a hotbed for cybercrime but the shift from the “old school” paper repair manuals and drawings to electronic data and files at each technician’s workstation has opened the door to risk.  The days when the certified maintenance manual was housed in heavy three ring binders filling a wall-sized book shelf are gone; no longer can you spot an employee carrying a roll of drawings and a box of documents out the door to a vehicle or see them weighing down the trunk of a car.

Now the crown jewels can leave the building on a device the size of a postage stamp.

Worse yet, now that everything is electronic, this company-critical information may be exposed to a hack from outside the facility over a public or private portal.  The crime may be committed by an insider or, almost as easily, by someone who has no company connection from anywhere in the world.

So is cyber risk the just latest form of corporate scare tactic designed to create another third party audit, a call for immediate action and more insurance?  No, but like most management problems the best first step is identifying the risk. Can you articulate the nature and location of your company’s crown jewels?  Can you list just the most critical 2% of all the company information you have that accounts for most of the company’s actual value, at least from an intellectual property standpoint?

The first step is to know what is important and where it is.  Only then can you start to consider the security of your intellectual property, mitigate the risk of loss and get back to work serving your customers.

 Steven E. Pazar, Attorney at Law, 11 Carriage House Lane, Boxford, Massachusetts 01921 (617)797-7277  spazar@pazarlaw.com.

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Training

Personal Development —  The Workforce Crisis of 2030 — and How to Start Solving it Now

By ARSA Communications Staff

It sounds counterintuitive, but by 2030, many of the world’s largest economies will have more jobs than adult citizens to do those jobs. In this data-filled — and quite charming — TED talk, human resources expert Rainer Strack suggests that countries ought to look across borders for mobile and willing job seekers. But to do that, they need to start by changing the culture in their businesses.

Only 15 years to go, get started by clicking here.

Regulatory Compliance Training

Test your knowledge of 145.211(c)(1) – Quality Control System.
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Membership

Member Spotlight – Texas Pneumatic Systems, Arlington, Texas

By ARSA Communications Staff

Founded in 1994, Texas Pneumatic Systems (TPS) speciaTPSlizes in testing and maintaining pneumatic components for commercial, business and military aircraft. The company was started to provide superior quality, quick turn and cost effectiveness through the use of state-of-the-art, computerized testing equipment.

Operating advanced equipment designed to meet the high-quality standards of the airline industry, TPS is able to diagnose and repair systems to the standards established by manufacturers while reporting an average turnaround time that is well under the 30-day industry benchmark.

In the 21 years since it opened, TPS has remained an industry leader for utilizing advanced technology to better serve its customers. With high-quality testing products and an advanced bar-coded inventory system, the company keeps its 23,000 square foot test facility at work supporting repair of a wide range of components.

On behalf of members like TPS, ARSA works every day to ensure that businesses have the opportunity to innovate in ways that best serve the aviation marketplace. Regulations and inspectors often seem stuck in the past, but through aggressive advocacy the association can support maintenance industry’s constant push towards the future.

To learn more about TPS, visit: http://www.txps.com.


Have You Seen this Person? Dennis A. Muilenburg, Boeing

By ARSA Communications Staff

Each month, the hotline spotlights key regulatory, legislative, and business leaders making important contributions to the aviation industry. 

muilenburg_dennis_bio_pic_400x400

Click here for full bio

On July 1, Dennis Muilenburg succeeded James McNerney as the chief executive officer of The Boeing Company.

With more than 165,000 employees across the United States and in more than 65 countries, Boeing is the world’s largest aerospace company and top U.S. exporter. It is the leading manufacturer of commercial airplanes, military aircraft, and defense, space and security systems; it supports airlines and U.S. and allied government customers in more than 150 nations.

Prior to assuming his position as CEO, Muilenburg served as vice chairman, president and chief operating officer of The Boeing Company and as president and chief executive officer of Boeing Defense, Space & Security (BDS). Muilenburg, who joined Boeing in 1985, spent the first 15 years of his career in the Puget Sound region, where he held a number of program management and engineering positions in support of both the commercial airplanes and defense businesses.

Muilenburg holds a bachelor’s degree in aerospace engineering from Iowa State University and a master’s degree in aeronautics and astronautics from the University of Washington.

Muilenburg is a member of the board of directors of Caterpillar Inc., the U.S.-China Business Council, the Congressional Medal of Honor Foundation and FIRST (For Inspiration and Recognition of Science & Technology). He serves on the steering committee of the Defense Industry Initiative, is a member of the Aerospace Industries Association (AIA) board of governors and serves on the AIA executive committee. He also serves on the boards of trustees for the National World War II Museum and Washington University (St. Louis).

He is a Fellow of the American Institute of Aeronautics and Astronautics (AIAA), a Fellow of the Royal Aeronautical Society, and the Boeing executive focal for Iowa State University.

To learn more about the new head of Boeing, please visit www.boeing.com.


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/.


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 – Working Away

Q: I have a customer who is an aircraft owner/operator that wants me to perform work at his hangar facility on an infrequent, but recurring basis. Can I do this?

A: Yes, provided the work itself is intermittent, and your repair station manual includes the requisite procedures. 14 CFR § 145.203(b) allows work to be performed away from a repair station’s fixed location where it is “necessary to perform such work on a recurring basis and the repair station’s manual includes the procedures for accomplishing maintenance, preventive maintenance, alterations, or specialized services at a place other than the repair station’s fixed location.”

So, if the customer has suitable housing and/or facilities (see § 145.103), intermittent but recurring work may be performed as long as the repair station manual contains the requisite procedures (see § 145.209(f)).

For more information on this topic and/or to provide feedback, see ARSA’s Working Away Advisory, which is currently open for industry comment.

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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

EAA AirVenture Oshkosh – Oshkosh, Wisconsin – July 20-26

AAAE/ACI-NA Airport Summer Fly-In – Washington, D.C. – July 20-21

South Carolina Aerospace Industry Conference & Expo – Columbia, South Carolina – August 26-27

Air Capital Aviation Expo – Wichita, Kansas – August 27

Previous editions:

2015: Jan Feb Mar Apr May
2014: Jan Feb Mar Apr May June July
Aug Sept Oct Nov Dec
2013: Jan Feb Mar Apr May June July
Aug Sept Oct Nov Dec
2012: Jun Jul Aug Sep Oct Nov Dec

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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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