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ARSA’s Filler at EASA STeB: Rulemaking, Personnel Moves and “Hard Law”

On May 9, Marshall S. Filler, ARSA’s managing director & general counsel attended the EASA Engineering & Maintenance Stakeholder Technical Body (E&M STeB) in Cologne, Germany.

The meeting was chaired by Juan Anton, maintenance regulations section manager of the Flight Standards Directorate with the assistance of several of his colleagues. They covered a lot of ground, including the status of several EASA Opinions that were now subject to review by the European Commission (EC) because they involve changes to “hard law,” meaning amendments to the Basic Regulation or Implementing Rules under the EC’s jurisdiction. These included:

(1) Control of maintenance suppliers.
(2) Changes to Part-66 B2L and L licenses.
(3) Basic examinations by Part-147 schools.
(4) Part-ML and Part-CAO.
(5) SMS for CAMOs.
(6) Technical records.
(7) Maintenance check flights.

EASA staff also presented a compilation of the survey responses submitted regarding the proposed changes to Parts-147 and 66. ARSA and the Aviation Technician Education Council (ATEC) had submitted a joint response to the survey in February of this year (click here to read the associations’ response).

Of particular note is that EASA has prepared draft Terms of Reference (ToR) for a new SMS rulemaking affecting Part-145 maintenance organizations and Part-21 design and production organizations. The pertinent STeB members are reviewing that document as part of their consultative responsibilities. The ToR precedes the issuance of a Notice of Proposed Amendment (NPA) which is similar to an FAA Notice of Proposed Rulemaking (NPRM).

A copy of the complete May 9 STeB agenda may be found here.

Mr. Anton announced that, effective July 1, he will move to a Cybersecurity position in EASA’s Strategy and Safety Management Directorate. He will be replaced by Ms. Eugenia Díaz Alcázar, senior regulations officer for continuing airworthiness. Mr. Anton will retain his position as chair of the ICAO Airworthiness Panel which is improving Annex 8 (Airworthiness) and related guidance to support a greater degree of mutual acceptance of certification and surveillance findings by civil aviation authorities regarding approved maintenance organizations.

Previously from ARSA...

12/6/16 - ARSA Finds New but Familiar Territory at EASA Stakeholder Meetings

December 6, 2016

On Nov. 29 and 30, ARSA’s Managing Director and General Counsel Marshall S. Filler and Executive Director Sarah MacLeod participated in two EASA-hosted maintenance industry stakeholder meetings.

The pair was in Cologne, Germany primarily for the November 30th meeting of the Engineering and Maintenance Stakeholder Technical Committee (E&M STeB). The association had announced during its Strategic Leadership Conference in October that it had been invited by EASA to join this body.

Composed of industry groups and other interested parties, the STeBs’ role is to provide strategic advice and guidance to EASA and its Stakeholders’ Advisory Committee (SAB) on a wide range of issues including regulatory standardization, risk management and safety assurance. ARSA’s membership further formalizes the association’s growing role in transatlantic regulatory compliance, which was previously demonstrated by its year-long leadership of efforts to deal with parts documentation issues in the U.S.-EU Maintenance Annex Guidance (MAG).

The E&M STeB meeting provided further details on EASA’s new structure for its stakeholder advisory groups, the status of ICAO’s efforts to encourage the mutual recognition of approved maintenance organizations and a recently-initiated survey (similar to an Advance Notice of Proposed Rulemaking in the FAA system) to review and revise EASA-Parts 66 and 147. The survey is seeking industry input in advance of EASA issuing a Notice of Proposed Amendment. The STeB attendees also received a briefing on cyber security issues and additive manufacturing (i.e., 3D printing), the latter focused the committee’s attention on the importance of adopting performance-based regulations since they are better suited to accommodate regulatory oversight of “new” technologies.

Filler and MacLeod made the most of their European travels by also attending EASA’s Maintenance and Production meeting on Nov. 29th at EASA headquarters. Agenda items included updates on EASA’s bilateral agreements, recently-adopted rulemaking on critical maintenance tasks, EASA’s new regulatory structure for managing continuing airworthiness issues and its plans for implementing regulations requiring Safety Management Systems (SMS) for holders of design and production approvals, maintenance organization approvals and maintenance training organizations. EASA reiterated its commitment to expediting Rulemaking Task 0018 dealing with parts documentation. There appears to be a consensus building among the robust regulatory authorities that the Form 1, Form 8130-3 and similar certificates are not needed in the vast majority of cases. ARSA is hopeful these changes will reduce the regulatory burdens associated with the installation of airworthy parts during the performance of maintenance subject to one or more bilateral agreements.

Of particular note, Julian Hall, EASA’s Head of Maintenance and Production (in the Flight Standards Directorate) will become the Deputy Certification Director, effective Jan. 1, 2017. On that date, Ralf Erckmann, currently Acting Deputy Certification Director, will replace Hall as Head of Maintenance and Production. These personnel changes are significant because they are intended, in part, to help EASA improve its communications between its Certification and Flight Standards Directorates (sound familiar?). This isn’t the first time that managers have made the switch between the two directorates but it is a welcome development for those, like this association, that prefer to view the regulations as a system rather than a series stand-alone requirements.

For Filler and MacLeod, it was a familiar experience – grappling with the universal challenges in implementation and consistency of aviation safety regulations. Just as the FAA struggles to enforce its rules across a vast network of regional and district offices in the United States, EASA must operate through and navigate around the pressures of member states spread across a continent.

As the only association dedicated to maintenance organizations, ARSA’s expanding global presence is key to its service of repair stations doing business in a worldwide market. Members should not only stay tuned for more updates as association executives travel the world on their behalf, but also be prepared to support efforts that expand ARSA’s work.

10/6/16 - At Its International Conference, ARSA Announces New Global Engagement

October 6, 2016

On Oct. 6, during its annual Strategic Leadership Conference (SLC), ARSA announced it would be nominating a representative to the Engineering and Maintenance Stakeholder Technical Body (E&M STeB) overseen by EASA’s Management Board.

The STeB’s role is to provide strategic advice and guidance to the management board on a wide range of topics. Focus areas include implementation/standardization issues, risk management and rulemaking impact assessment. EASA is developing similar boards to support aviation safety oversight and gather input from stakeholders across the aviation community. Each board, composed of industry groups and other interested parties, operates in support of EASA’s newly-established Stakeholder Advisory Board (SAB).

Through membership on the E&M STeB, ARSA will further formalize its growing role in transatlantic regulatory compliance. Since September 2015, the association has led an industry-wide effort to address issues stemming from new parts documentation requirements in the U.S.-EU Maintenance Annex Guidance (MAG).

“ARSA is very pleased to receive this invitation and looks forward to further collaborations with EASA and other members of the E&M STeB,” said Marshall S. Filler, the association’s managing director and general counsel. “ARSA will continue its advocacy role on behalf of the global maintenance industry and appreciates the opportunity to participate in this important advisory body.”

The SLC was the perfect platform for ARSA to highlight its expanding global impact. The annual roundtable-style meeting provides senior maintenance executives from around the world an open forum with representatives from the International Air Transport Association (IATA), the International Civil Aviation Organization (ICAO), the FAA, EASA and other aviation community stakeholders.

Having received a formal invitation to join the STeB, ARSA’s focus turns to selecting its nominees, determining logistical needs and rallying support for its participation.

To see what else happened in Montreal, visit arsa.org/slc-2016.



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