2016 – Edition 1 – February 5
Table of Contents
ARSA Works…in 147 Words
By Brett Levanto, Vice President of Communications
In honor of the effort to modernize the AMTS rule, 147 words on ARSA’s current work:
Effective rules: Getting part 147 “right” is an industry imperative (see more on the effort in ARSA Works and Legal Briefs). Aviation maintenance technician schools provide a vital resource; AMTs are the foundation of the entire aviation community.
Reasonable laws: An FAA bill has finally been introduced in the House. Air traffic control is grabbing attention, but repair stations always face those bad ideas that never go away. Join the association for Legislative Day on March 16 and show Congress how much maintenance matters.
Good sense: As ARSA works in Washington (and around the world), arm yourself with the knowledge to manage your own compliance. The 2016 online training schedule is growing, so get started with the first three classes and stay tuned to arsa.org/training.
See more: ARSA works for you.
Symposium 2016
By ARSA Communications Team
ARSA’s Legislative Day and Annual Repair Symposium provide direct, positive engagement with lawmakers, regulators, customers and colleagues.
It does not happen without financial support. Is the congressional directory useful? Thank Aircraft Electric Motors. Glad you can start with a good breakfast? Columbia Helicopters filled your plate.
In addition to AEM and Columbia, the following companies have committed to supporting the value-added gathering for 2016:
Barfield, Inc.
Component Repair Technologies, Inc.
Fortner Engineering
HAECO Americas
Moog Inc. Aircraft Group
NATA Compliance Services
Penton Aviation Week Network
SONICO, Inc.
TPS Aerospace
Present your business to the most dedicated members of the maintenance community, by investing in its future. Register for the symposium and join the sponsor list.
Have questions? Contact Caroline Kneip to learn more about sponsorship opportunities.
Legislative Day – Stay Off the Congressional Menu
By ARSA Communications Team
There’s a saying in Washington: “If you’re not at the table, you’re on the menu.” Reserve your spot at ARSA’s 2016 Legislative Day and Annual Repair Symposium and help keep your job from ending up on a congressman’s plate.
This year, Congress will take on the heavy challenge of reauthorizing the FAA. Every single time lawmakers consider the agency’s future, proposals hostile to contract maintenance find their way into the debate. ARSA has protected the industry from these legislative attacks so far, but it needs your help to keep uninformed leaders from grounding us all.
Come to the nation’s capital in March and show your senators and representative that maintenance matters.
To learn more about ARSA’s legislative program, and to get involved, visit arsa.org/legislative.
Hotline Features
ARSA Gets Technical, Urges Congressional Action on Perkins
By Brett Levanto, Vice President of Communications
On Jan. 8, ARSA joined more than 350 other organizations in a letter urging Congress to reauthorize the Carl. D. Perkins Career and Technical Education Act. Perkins supports career and technical education (CTE) programs through grants to states. It is long-overdue for overhaul and has come under fire in recent years for being out of touch with the needs of the modern workforce.
The broad show of industry support for action on Perkins represents the growing recognition that technical, hands-on training provides students with more opportunity and employers with essential human capital. The law has long been the federal government’s central tool in supporting efforts by schools and businesses to grow essential skills; the association and its allies asked lawmakers to enhance areas that can boost the modern economy.
The group contends the government can most effectively utilize federal spending on technical programs when curricula consider workforce demand. To ensure such consideration exists, the letter asked that reauthorization legislation align CTE programs with the needs of labor markets and support collaboration between educators and employers.
“CTE is an effective tool for improving student outcomes and helps prepare both secondary and postsecondary students with the necessary academic, technical and employability skills required for successful entry into the workforce,” the letter said. “Indeed, CTE prepares students both for college and careers.”
The association will continue to support this broad coalition of businesses and industry groups to build the right educational infrastructure. After graduating from programs rooted in strong CTE skills, students will have options. By taking advantage of federal policy and working locally to meet labor demand, so will aviation businesses.
Do your part: Visit ARSAaction.org and tell your elected officials to help build the technical workforce of the future.
ARSA Remembers: Mary Alice Rice (1932–2016)
By ARSA Communications Team
Mary Alice Rice, who was instrumental in the operation of the Northrop Rice Foundation, passed away on Jan. 26 at her home near Houston, Texas.
Alice’s long commitment to the aviation community began with a job at Braniff Airways in Kansas City, where she met her husband James in 1956. The two moved to California and eventually Houston, where they helped put a man on the moon before founding Rice Aviation (later renamed Northrop Rice USA, Inc.) in 1972. She led the company as chief executive officer for 44 years.
In addition to NRF, where she helped support the careers of thousands of aspiring aviation professionals, Alice was actively involved in the Aviation Technician Education Council and the Association for Women in Aviation. She leaves behind her husband, six children, nine grandchildren and a legacy of dedicated commitment to the future of flight.
NRF provides the annual ARSA Scholarship, which helps a selected AMT student with money for books, tuition and fees. The scholarship honors Alice’s commitment to the men and women who keep the world safely in flight by investing in their future.
To learn more about the ARSA Scholarship, and to see how you can get involved in NRF’s mission, visit: http://northropricefoundation.org/index.php/scholarships/amt-student-awards-and-scholarships.
To view Alice’s full obituary and to learn about funeral arrangements, visit: http://www.crowderfuneralhome.com/obituaries/mary-alice-rice/.
ARSA Works
To see all the ways ARSA works as the voice of the aviation maintenance industry, visit our ARSA Works page.
Part 147: Aviation Industry Stands Up for Competency
By Brett Levanto, Vice President of Communications
On Feb. 1, ARSA joined a broad effort to get the new 14 CFR part 147 – the long awaited update to the rule governing aviation maintenance technician schools – right. The association united with 13 other organizations, including Airlines for America, the Aviation Technician Education Council and a broad swath of aviation, maintenance and educational interests to demand the FAA produce a competency-based final rule.
The group submitted comments to the agency’s notice of proposed rulemaking (NPRM) to update part 147. The submission decried the NPRM’s continued reliance on class time at the expense of technical capability.
“Put simply, the proposal would impose 20th century educational practices on a 21st century industry,” the group said. “It maintains its predecessor’s antiquated concern with the time a student spends in a classroom seat rather than focusing on the skills he or she actually gains. A competency-based standard, free of defined schedules and specific hour requirements, will allow industry to transition away from seat time in favor of a structure that creates flexibility and allows students to progress as they demonstrate mastery of subject matter, regardless of time, place, or pace of learning.”
By sending a single message to the FAA, the group demonstrated industry-wide commitment to supporting A&P schools. Broadly calling for emphasis on technical capabilities over classroom hours allowed the association’s educational allies – particularly ATEC – to focus on building a structure that would allow institutions to adhere to regulatory standards while tailoring programs to meet industry needs.
“Industry has suffered the repercussions of an outdated rule for far too long,” ATEC’s separate comments said. ““[Aviation maintenance technician school] students have been forced to spend wasted effort and time learning antiquated skills, and industry has borne the cost. We desperately need a competency-based rule that gives educators flexibility to teach the future workforce the skills needed to support the ever-changing, technology-driven, dynamic aviation industry.”
Getting part 147 right is vital not just for education institutions, but for the aviation businesses that depend on their product – qualified, technically skilled technicians. ARSA will continue to support the effort to develop a rule that enables effective schools to grow competent students that serve a flourishing aviation community.
To view the combined industry comments, click here.
ARSA Listened – Online Session on Data Collection & Approval
By ARSA Communications Team
On Jan. 27, ARSA hosted a listening session about draft Advisory Circular AC 43-210A, “Standardized Procedures for Requesting Field Approval of Data, Major Alterations and Repairs.” The draft AC was considered in context of other information on how to obtain approval of data under section 21.8(d).
During the session, ARSA’s regulatory team introduced and discussed information pertinent to issues with obtaining data approval for repairs and alteration. It also gathered information to support general comments on the draft AC and help plan to address broader industry issues.
AC 43-210A Listening Session
Price: $25 for members ($50 for non-members)
Coupon code: ARSA members – from organizations listed in the member directory – must register using the coupon code “ARSAMEMBER” (entered on the checkout page).
On-Demand – Available Anytime
Click here to register and get access for 90 days.
While this is not a training session, it is provided – as ARSA training is – through Obadal, Filler, MacLeod & Klein, P.L.C., the firm that manages ARSA. To go directly to OFM&K’s online training portal, visit potomaclaw.inreachce.com. For more information about ARSA-specific training, please visit arsa.org/training.
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
Waves Come Crashing—Part 147 NPRM
By Crystal Maguire, Vice President of Operations
On Oct. 2, 2015 the FAA released a notice of proposed rulemaking (NPRM) for Title 14 Code of Federal Regulations (CFR) part 147, the regulation governing the operation of FAA-certificated aviation maintenance technician schools (AMTS) (see related story, Part 147, Aviation Industry Stands Up for Competency, Feb. 3, 2016). While the proposal could provide welcome relief from outdated curriculum requirements, many provisions are reiterations of those deemed unacceptable in the last repair station rulemaking (see Know the New Part 145, Nov. 10, 2014).
Most notably the 147 proposal would subject surrendered AMTS certificates to “acceptance for cancellation”. ARSA continues to oppose the same provision that was, up until now, unique to part 145. The association’s rally cry was premised on the threat that the requirement would expand to other aviation certificate holders; it appears that possibility has come to fruition for AMTS.
The agency claims, as it did in the preamble to the 145 rulemaking, that the “inability to voluntarily surrender” prevents those under investigation from circumventing enforcement action. On the contrary, the FAA’s charge is safety in air commerce (as opposed to collecting a civil penalty) thus certificate surrender furthers aviation safety. In reality, the vast majority of surrendered certificates are mere formalities. To require the exchange of formal documentation does not further safety interests or relate to the FAA’s oversight authority. Indeed, once an institution determines it no longer wants to operate and surrenders its certificate, it ceases to be an air agency and thus the FAA’s authority to examine it is no longer relevant.
Proposed § 147.9 would separate the AMTS air agency certificate from the operations specifications (opspecs), a provision that ARSA successfully challenged in the last 145 proposed revision. As it stated in its 2012 comments, the air agency’s opspecs are part of the certificate and can only be changed voluntarily by the holder, or through agency certificate action. The only reason opspecs exist is to clarify privileges or limitations; separating them from the certificate would essentially give the agency unilateral authority to change them.
Proposed § 147.10 provides in painstaking detail the procedures for amending, suspending and terminating operations specifications. The 32 paragraphs contained in that section are duplicative of the provision ARSA opposed in the 2012 145 NPRM. The creation of a bureaucratic process to solve a non-existent problem is untenable and unacceptable. The language was created in response to the Consistency in Regulatory Interpretation Rulemaking Advisory Committee’s request that the agency review its processes for issuing operation specification paragraphs. However, until the agency stops field office “regulating by opspecs” it must refrain from burdening another segment of the industry or itself by continually insisting on promulgation of an administrative nightmare.
It is disheartening to see regulatory language seemingly disgraced only for it to rise up again when the agency thinks no one is looking. This recent rulemaking illustrates how important it is for industry to ban together, be aware of the other’s issues, and support one another when faced with unsubstantiated and unreasonable regulatory proposals. A “repair station problem” will inevitable trickle up and/or down, and this new “AMTS problem” would no doubt do the same if it comes to fruition. There is power in numbers, and ARSA is always willing to yield its respective portion in the pursuance of good government; it therefore encourages the agency to use discretion when considering final language for the new part 147.
ARSA on the Hill
FAA Bill Highlights Need for ARSA Member Engagement
By Daniel Fisher, Vice President of Legislative Affairs
On Feb. 4, House Transportation & Infrastructure Committee Chairman Bill Shuster (R-Pa.) unveiled his long-awaited FAA reauthorization proposal, the Aviation Innovation, Reform, and Reauthorization Act (the AIRR Act, H.R. 4441).
The six-year authorization has garnered significant attention (and controversy) for spinning off air traffic control (ATC) from the FAA into a non-profit, independent corporation (“ATC Corporation”). The entity would be run by a board of directors (including representatives from U.S. air carriers, general aviation operators and the unions representing air traffic controllers and airline pilots), funded from unspecified fees levied on air carriers.
While the ATC Corporation is grabbing the headlines, buried in the 273 page proposal are provisions directly impacting the international aviation community. Here is the lowdown:
- Foreign Drug & Alcohol Testing. The AIRR Act reiterates the mandated rulemaking from the last FAA reauthorization bill (the FAA Modernization & Reform Act) requiring all part 145 repair station employees responsible for safety-sensitive maintenance functions on part 121 air carrier aircraft be subject to an alcohol and controlled substances testing program (consistent with the applicable laws of the country in which the repair station is located). However, the AIRR Act takes it a step further by requiring the agency to issue a notice of proposed rulemaking (NPRM) within 90 days of enactment and a final rule one year later.
- Mandated Background Checks. The proposal requires that all part 145 repair station employees performing a safety-sensitive functions on an air carrier aircraft undergo “a pre-employment background investigation sufficient to determine whether the individual presents a threat to aviation safety.” This is a significant expansion of current regulatory requirements.
- Safety Assessment System. The AIRR Act expands on the FAA Modernization & Reform Act’s safety assessment system for part 145 repair stations. Specifically, it would grant the agency access to information or data in the possession of a part 121 air carrier “related to the frequency and seriousness of any corrective actions” implemented on aircraft following “heavy maintenance work” at a foreign repair station. Heavy maintenance work is defined as “a C-check, a D check, or equivalent maintenance operation with respect to the airframe of a transport category aircraft” (view details on how the language fits into current law).
ARSA will be communicating its concerns about the provisions to lawmakers and the broader industry in the near future. Please contact me with any questions or comments about any of the AIRR Act’s provisions.
Remember, the AIRR Act is only a piece of legislation at this point. There are a number of steps in the process and the bill will likely undergo a major alteration before it becomes law. Consequently, attending ARSA’s 2016 Legislative Day on March 16 is more important than ever. Come tell your elected officials – face to face – about how the proposal will impact your company and its ability to compete globally. (Registrants will receive free access to the March 9 online training session Repair Stations Go to Washington.)
As the FAA reauthorization process enters into full swing, be sure to stay tuned to www.ARSA.org for the latest updates, including detailed analysis of the legislation’s other key provisions.
Regulatory Outlook
New EEOC Rule Would Expand Reporting to Target Gender Pay Gap
By ARSA Regulatory Team
The Equal Employment Opportunity Commission (EEOC) is proposing to expand employer reporting requirements to target what the Obama administration calls a stubborn and persistent gender pay gap.
Current rules require federal contractors and first-tier subcontractors with more than 50 employees and all companies with more than 100 employees to annually report the number of individuals they employ by job category, race, ethnicity and gender. The new rules, unveiled by President Obama on Jan. 29 and published in the Federal Register on Feb. 1, would require these employers to also report the number of hours employees work and how much they are paid.
The administration says the new rule is necessary to help the EEOC enforce equal pay laws and “provide better insight” into the gender pay gap across industries and occupations. Critics charge that the new proposal is overly intrusive, will impose significant new paperwork burdens on businesses and subject employers to unnecessary and time consuming investigations.
More information on the EEOC proposal is located at: https://www.federalregister.gov/articles/2016/02/01/2016-01544/agency-information-collection-activities-revision-of-the-employer-information-report-eeo-1-and. Comments are due by April 1. The administration plans to roll out the final rule before the end of 2016 and require employers to start providing the additional data in the 2017 reporting cycle.
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
ARSA periodically invites lawmakers and other policy leaders to provide commentary in the hotline. The views expressed are those of the commentator, not necessarily ARSA.
Jobs Revolution Demands Congress Reform Skills Programs
By U.S. Senator Mike Enzi, R-Wyo.
Businesses across the country are struggling to find workers to fill skilled positions. There are going to be millions of new jobs created in America in the next few years and many of them will require skills and training beyond a high school diploma.
If we are going to maintain a leadership role in the global economy, our workers need the proper training and skills. The American workers need career and technical skills and professional capabilities to not only succeed, but to lead the way in tomorrow’s job market. We need to eliminate the stigma against hands-on-skills resulting from the emphasis on college degrees. Congress must ensure that education and training are connected to the needs and interests of workers now and in the future.
That is why I am working with Republicans, Democrats and Independents to reauthorize the Perkins Career and Technical Education Act. The act was created by Congress to help provide individuals with the career and technical skills needed to succeed. It hasn’t been reviewed in detail for almost eight years. If a business hadn’t reviewed a part of their business for eight years, they would probably be out of business!
If Congress is going to support learning opportunities for students to help them find and hold high skill and high wage jobs we need to review, revise and re-approve the Career and Technical Education Act. I am currently working with supporters to craft a bill that would make it easier for states and locals to run programs that serve all students who desire to gain access to career and technical education course work.
If we want to make sure that we are preparing students for the real world we also need to strengthen the connection of career and technical education programs to the needs of businesses so jobs are available upon completion of certification or graduation. If we are going to help fill the growing need for skilled workers, we need to ensure these programs coordinate their instruction with current practices in industry and with the needs of the workers.
And in order to stay competitive, we need to ensure the act will help support seamless transitions from education to the workforce including real-life skills and work ethic.
But the Career and Technical Education Act is just part of the solution to prepare workers for the changing job market. Last year Congress was able to re-do and approve the Workforce Investment Act to help transform the bureaucratic federal job training system into a streamlined program that can help many more people learn the skills they need to get meaningful jobs. The new changes are helping states better meet regional economic demands and provide training for jobs in which quality workers are in short supply.
The Workforce Innovation and Opportunity Act also delivered long-overdue changes by eliminating 15 programs identified as ineffective or duplicative and 21 federal mandates on state and local workforce boards. It also provided stronger accountability for taxpayer dollars by applying common performance measures for all programs with a focus on employment outcomes and employer satisfaction with trained workers.
By strengthening the job training programs Congress also gave authority back to state governments to equip them with tools to help small businesses. It provided governors and state workforce directors what they told us they needed — flexibility to use money where it is most needed.
Employers are looking for the right people that can be part of a team where everyone succeeds. Some of that depends on what skills and training someone can bring to a job, but a desire to learn, to improve and to contribute to that success is something employers are looking for, too.
We need to ensure that students who have a drive to work hard and will to succeed also have the professional and technical knowledge to make success a reality from the day they graduate or are certified. By focusing on the skills and programs that are in demand by America’s economy today, we can have a strong economy tomorrow.
We are going to experience dramatic changes in the workforce over the next 10 to 15 years, and we need to start now if we are going to adapt federal education and training policy to meet the coming crisis of too few workers with too few skills.
Any business owner knows that success depends on the quality of their workers. No matter how much effort goes into the product or the plan, without the work of dedicated employees a business will struggle. But with skilled workers who have been given the training and preparation for jobs, the sky is the limit.
Currently serving his fourth term, Sen. Enzi is the Senior Senator from Wyoming. As member of the Committee on Health, Education, Labor and Pensions (HELP) he will be a key figure in congressional efforts to overhaul the American technical education system.
Training
Online Training: Major, Minor and More
By Brett Levanto, Vice President of Communications
Join ARSA’s regulatory and legislative teams for a series of sessions in February and March. Begin in your shop with major/minor determinations, travel the world with an introduction to international regulatory law and land on Capitol Hill with tips on effectively engaging lawmakers.
The price for each class is $75 for ARSA members ($150 for non-members). Individuals from organizations listed in the member directory must register using the coupon code “ARSAMEMBER” (entered on the checkout page).
Major Pain Over a Minor Issue
This session will review the regulations that govern the terms “major” and “minor” in the world of civil aviation repairs and alterations. Learn the regulatory facts and how to train your FAA inspector so this minor issue doesn’t become a major pain in the derrière.
Instructor: Sarah MacLeod
Date: Feb. 24, 2016
Time: 11:00 a.m. EST
Click here to register.
Going Global
This session summarizes the framework for international safety regulation, introduces ICAO’s mechanisms for allocating regulatory responsibilities among member states and addresses the important role bilateral agreements play in enhancing efficiency and facilitating international commerce.
Instructor: Marshall S. Filler
Date: March 4, 2016
Time: 11:00 a.m.
Click here to register.
Repair Stations Go to Washington
This session will overview basic strategies for communicating with key lawmakers and their staffs to become an effective advocate for aviation interests. Learn how to make the most of your constitutionally-protected right “to petition the government for a redress of grievances.”
Instructors: Christian A. Klein & Daniel B. Fisher
Date: March 9, 2016
Time: 11:00 a.m.
Click here to register.
Special Offer: Register now to attend ARSA’s Legislative Day on March 16 and receive free access to this session (event registrants will receive a special invite with instructions prior to the session).
Registration for each class includes:
- Attendance for the live, online class session on the scheduled date.
- Access to the on-demand recording available after the live session is complete.
- Digital copies of the presentation and all reference material with links to relevant resources and citations.
- A certificate upon completion of the class (including any test material).
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 see course availability, visit arsa.org/training.
Regulatory Training at Heli Expo
By ARSA Communications Team
Going to HAI HELI-EXPO 2016 in Louisville, Kentucky? ARSA’s great regulatory minds will be there, and a front-row seat in their classroom is waiting for you.
Marshall S. Filler and Sarah MacLeod, the association’s foremost experts in regulatory compliance (and managing members of the firm of Obadal, Filler, MacLeod and Klein, PLC) will be leading professional education courses at HAI HELI-EXPO. Register now to make the most of your time in Kentucky and get to the head of class.
Mr. Filler and Ms. MacLeod’s training sessions are listed under the “Maintenance Management” track, but are in fact substantially valuable to any aviation professional.
All three classes are approved for IA renewal credit:
Regulations 101 – Law for the Aviation Professional
Feb. 28, 2016 – 8:00 a.m. to 5:00 p.m.
Marshall S. Filler and Sarah MacLeod
This one-day course will cover the basic FAA requirements associated with making day-to-day decisions on purchasing, designing, manufacturing, operating, maintaining, or selling civil aviation products and parts.
Audit Activism
Feb. 29, 2016 – 8:00 a.m. to Noon
Sarah MacLeod
Attendees will learn a proactive approach to audits. The session will start by covering the differences between regulatory and business requirements and how to create appropriate interfaces among the certificate holders, governments and customers who must work together toward compliance. Finally, attendees will walk through managing an audit process that ensures appropriate, timely and effective responses.
Public Aircraft
Feb. 29, 2016 – 1:00 p.m. to 5:00 p.m.
Marshall S. Filler
This course covers the basic requirements for an aircraft to be operated as a public aircraft on behalf of federal, state, and local governments, including the difference between government-owned and government-leased aircraft, what constitutes an eligible governmental function, and the practical implications of using the same aircraft to conduct both civil and public operations.
Can’t make it to Kentucky? The association provides plenty of opportunity for you to learn from its experts. See more at arsa.org/training.
From the FAA – Failure to Follow Procedures
By Brett Levanto, Vice President of Communications
Why do policies, procedures, instructions, rules, regulations and best practices exist? What makes them the “safety net” for aviation maintenance safety? Deviation from these critical resources creates unacceptable and unsafe conditions.
The course introduces five of the most common “rationalizations” that mechanics use to justify when they intentionally deviate from procedure. Through video, it presents a specific example – a nose gear collapse – to illustrate when and how a mechanic might use one of these rationalizations…to tragic effect.
The course provides alternatives through which you can fight the urge to deviate from procedure. Keep your hangar in compliance: https://www.faasafety.gov/gslac/ALC/course_content.aspx?pf=1&preview=true&cID=445.
Regulatory Compliance Training
Test your knowledge of 145.221 – Service Difficulty Reports.
Membership
Member Spotlight: Barfield, Inc.
By Sarah Hartley, Communications Coordinator
Founded in 1945, Barfield is an FAA and EASA certificated repair station offering maintenance services to major passenger, cargo and regional airlines mainly located in North, South and Central America and the Caribbean. They operate out of three facilities in Miami, Phoenix and Louisville and with the support of 220 employees, offer three primary services: Adaptive services, Distribution and Ground Support Test Equipment (GSTE).
Together with its sister company Aero Maintenance Group, Barfield is part of the AFI KLM E&M network, a major MRO provider. With a workforce of 14,000, AFI KLM E&M offers technical support for airlines, ranging from airframe maintenance to engine overhaul and repair and supply of components.
Through its airline programs division, Barfield supplies complete customized support programs for Airbus, Boeing, Regional jet and Turboprop aircraft, as well as helicopter operators. These programs support operators in need of inventory, logistics solutions, repair management programs, engineering fleet support and component reliability management.
Barfield is a great supporter of ARSA and has already signed on as a sponsor of this year’s Annual Repair Symposium. Learn more at www.barfieldinc.com.
Have you Seen this Person? U.S. Senator Mike Enzi, Wyoming
By Sarah Hartley, Communications Coordinator
Senator Mike Enzi of Wyoming became a member of Congress in 1997. He is an advocate for workforce development issues and is working to reauthorize the Perkins Career and Technical Education Act (see this edition’s Quality Time).
Raised in Wyoming, Enzi earned a B.A. in accounting from George Washington University and a M.A. in retail marketing from the University of Denver. After expanding his father’s small business, he served for seven years in the Wyoming Air National Guard and was then elected mayor of Gillette, Wyoming in 1974. Enzi also worked in the United States Department of the Interior, served as a state legislator in the Wyoming House of Representatives and was as an accountant and executive director in the energy industry.
Enzi won a tight primary for election to the U.S. Senate in 1996 and was re-elected by large margins in 2002 and 2008. He is the Chairman of the Senate Budget Committee. In addition to his interest in the technical workforce, he is a proponent for small business, energy independence, states’ rights and a balanced budget.
To learn more about Sen. Enzi, visit www.enzi.senate.gov.
Take Advantage of ARSA’s Members Getting Members Program, Get 10% Off on Membership DuesThe 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 SymposiumAs 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/
A Member Asked…Cannibalized Parts
Q: Under FAA and EASA regulations, when can a repair station use the seemingly popular industry practice of “cannibalizing” parts? Specifically, we want to remove a gear from one generator and install it in another that will be issued a dual release certificate.
A: The EASA and FAA regulatory requirements pertaining to the use of parts that can be continued in service without further maintenance (“cannibalized”, “robbed”, “recovered”, deemed “serviceable as removed”, etc.) differ slightly:
(1) FAA perspective: The privileges and limitations of repair stations, under Title 14 Code of Federal Regulations (14 CFR) sections 43.3(e), 43.7(c) and 145.201, allow for the performance of maintenance on all articles for which they are rated. Accordingly, appropriately rated repair stations may review, visually inspect, check or test sub-articles in compliance with part 43 to determine if they are “serviceable as removed” from a top assembly. Once this assessment is made, the part can be used in any assembly undergoing maintenance, or placed into stock for future use. For more details, see FAA’s response to ARSA’s inquiry on the subject.
(2) EASA perspective: EASA regulations allow the performance of maintenance and installation of recovered parts without issuing return to service documentation so long as the repair station has the appropriate procedures in place. Specifically, 145.A.50(d) (Certification of maintenance) provides that—
“A certificate of release to service shall be issued at the completion of any maintenance on a component whilst off the aircraft. The authorised release certificate “EASA Form 1” referred to in Appendix II of Annex I (Part-M) constitutes the component certificate of release to service except if otherwise specified in point M.A.502(b) or M.A.502(e). When an organisation maintains a component for its own use, an EASA Form 1 may not be necessary depending upon the organisation’s internal release procedures defined in the exposition.” (Emphasis added.)
ARSA’s perspective is that if the part meets the requirements of both agencies, it can be issued a dual release. So, for example, if there is a major repair on the FAA-used part, one must make sure it meets the EASA requirements (e.g., if the part is critical there must be a link to the EASA TC/STC holder or EASA must have otherwise approved the repair design before it can be used in a dual release top assembly).
So, if you are appropriately rated to work on the generator and comply with the above requirements, you can inspect a gear from that unit, determine that it can be continued in service by referencing the CMM or other appropriate maintenance data, and install the gear in another generator or place the gear in stock for later use.
There is no specific guidance on “continuing parts in service” from one jurisdiction to the other but logically, it should be allowed as long as the “used” part meets both jurisdictions’ requirements (the domestic regulations plus any special conditions in the MAG) before installation.
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 Middle East – Dubai, UAE – February 3-4
Singapore Air Show – Singapore – February 16-21
HAI Heli-Expo – Louisville, Kentucky – Februrary 29-March 3
ARSA Legislative Day & Annual Repair Symposium – Arlington, Virginia – March 16-18
Gorham PMA Parts/DER Repairs Conference – San Diego, California – March 21-23
Major Pain Over a Minor Issue – February 24
Going Global – March 4
Repair Stations Go to Washington – March 9
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| SPONSORED CONTENT |
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