2022 – Edition 7 – August 5

Table of Contents

Note: The order of material varies in hotline emails, but is always presented the same on this landing page. Readers scrolling through content on or printing this page will find it organized consistent with the table of contents.

The President’s Desk
ARSA Works
Legal Brief
ARSA on the Hill
Training
Membership
Resources
Industry Calendar

The President’s Desk

ARSA Assurance – What Don’t They Know?

By Terrell Siegfried, NORDAM Assistant General Counsel and Corporate Secretary & 2022 ARSA President

Regulatory compliance is a cornerstone of success. When it comes to understanding the rules governing maintenance, there’s no better source than ARSA. Encouraging your vendors to join the association can make them more effective business partners and help them avoid regulatory pitfalls. It also can reduce your dues while giving the association additional resources to represent all of us.

And allow me to debunk a common myth right here and now: A company does not need to hold a part 145 certificate to join ARSA and enjoy the benefits of a membership. Any business with an interest in aviation safety can benefit, particularly with some connection to maintenance, such as a production approval holder supplying parts to a repair station.

In short: If you work with a supplier or business partner, you should encourage ARSA membership.

It’s clear members appreciate and understand ARSA’s value: In our 2022 survey, the average satisfaction score was 4.6 out of 5. You also told us access to the association’s regulatory and legislative knowledge and its compliance support are the two most valuable benefits ARSA provides.

You know it, but do your vendors and other business partners? While most leading aviation maintenance companies are part of ARSA, some aren’t. Give our current member list a look to see if all of the businesses you regularly work with belong to the association.

Need another compelling reason to check? If a company is an ARSA member, you’re certain they have access to top-notch resources and care about compliance; if they’re not, you don’t know what they don’t know. They may not be abreast of regulatory changes, which may lead to problems for both of you.

A recent example is the uncertainty surrounding parts documentation requirements under U.S.-EU maintenance annex guidance. If they’re not an ARSA member, they may not know the Federal Aviation Administration – at the European Union Aviation Safety Agency’s insistence – now requires an 8130-3 with a left-side signature on every new part installed on an EASA-regulated product. And they may not be aware of how these developments affect the interface between repair stations and parts suppliers.

Of course, being an ARSA member doesn’t necessarily mean a company will do everything right, but it provides a level of assurance that a vendor has access to resources to make an effective partner. ARSA’s regulatory compliance resources don’t just explain what you must do to stay compliant, they also provide context, which will help improve understanding about why you’re requesting vendors to do something in a certain way.

Encouraging your vendors to become ARSA members is a win-win-win proposition.  Your vendors get access to top notch information and access to a large population of other potential customers. ARSA gets additional resources to enhance its advocacy and member services. Through ARSA’s members getting members program you get a one-time dues discount equal to 10% of dues revenue from new members you refer.

Here’s how to bring your business partners into the fold:

(1) Start with a simple email explaining why you value ARSA, and encouraging them to join.

(2) Encourage them to join during the audit process by asking where they get their compliance information and recommending the association.

(3) Enhance the association’s visibility and encourage membership at conferences and trade shows. To learn more about the “champion” initiative, contact ARSA’s Vice President of Membership Kimberly Dimmick.

Each of us has a role to play in making sure our association has the resources it needs to be successful. Thanks for your membership and your partnership as we grow ARSA.

Terrell Siegfried 2022 ARSA president | NORDAM assistant general counsel and corporate secretary

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ARSA Works

What ARSA Has Done Lately – Second Quarter 2022

Each quarter the board of directors receives reports on the association’s activities and fiscal health. Step into a board member’s shoes with this overview of the financial, operations, legislative and regulatory reports highlighting advocacy on behalf of aviation safety between April and June 2022.

Fiscal Health

Board and team are focused on growing non-dues revenue to build off the strong foundation provided by membership.

Membership

• ARSA team has fully implemented new member welcoming procedures.
• Q2 retention renewal rate was 91.1 percent.

Regulatory Advocacy

• Pressed FAA on its acceptance of ARSA’s E100 Form as means of compliance with parts documentation requirements under U.S./EU bilateral agreement.
• Delivered feedback from ARSA members (via “quick question”) to FAA on administration and use of Dynamic Regulatory System.
• Posted “workaround” instructions from FAA for access to WebOPPS after sunset of Internet Explorer.
• Commented on airworthiness directive issued against certain MARS A.S. emergency parachutes, challenging FAA authority to issue such an AD under part 39.
• Publicized CAAC (China) request for comments on guidance for 145 approval holders.
• Ongoing meetings regarding ARAC Part 145 Working Group AMC development.

Legislative and Lobbying

• Safe Aircraft Maintenance Standards Act (R. 7321)
  • Updated SAMSA Action Center.
  • Coordinated industry opposition to H.R. 7321 in lead up to June 15, 2022 markup.
  • Proposed amendments that resulted in significant improvements to bill.
• FAA Maintenance Workforce Grant Program (Sec. 625)
  • Lobbied congressional offices and coordinated coalition activity in support for full funding ($5 million) in FY 2023 appropriations process.
  • Vetted proposal by House Aviation Subcommittee Chairman Rick Larsen (D-Wash.) to quadruple Sec. 625 funding and create new manufacturing workforce grant program.
• National Center for Advancement of Aviation Act (R. 3482/S. 1752)—Participated in coalition to advance H.R. 3482 through House Transportation & Infrastructure (T&I) Committee.
• ARSA PAC
  • Received $1500 PAC contributions.
  • Made $1,000 PAC contribution to House Transportation & Infrastructure Committee Ranking Member Sam Graves (R-Mo.).
  • Began discussing joint contribution strategy with members and allies.

Communications and Surveys

ARSA in the News – Selected Industry Coverage

Aviation maintenance technician shortage may impact summer travel

June 3, 2022 | WCHS News 8 (West Virginia)

Experts behind the scenes are now in short supply and without an increase in aviation maintenance technicians, your travel plans make take a nosedive.

There aren’t enough airplane mechanics, either

May 19, 2022 | Crain’s Chicago

As carriers ramp up for the busiest summer since the coronavirus pandemic began, companies such as AAR in Rockford are scrambling to keep planes flying.

McHugh Brings New Perspective to ARSA Board

April 26, 2022 | AviationPros

“After months of searching, Alison presented herself as the perfect board candidate,” said ARSA Executive Vice President Christian A. Klein.

ARSA Flags Confusion Over New-part Validation Process

April 18, 2022 | Aviation Week

Some U.S.-based repair stations with EASA approvals are getting pushback from that agency and the FAA on an approved method of showing a new part is traceable to the manufacturer.

ARSA Industry Editorials

Surveys

• Reported results of 2022 member survey.
• Quick Questions—
  • Remote Connectivity (April) (14 responses)
  • The Dynamic Regulatory System (May) (60 responses)
  • Parts Documentation for Bilateral Compliance (June) (35 responses)

Events, Meetings and Training

Events

Planning 2022 Annual Board Meeting & Roundtable sessions with allies and regulators (Oct. 13 & 14)

Meetings

• Sarah participated in weekly meetings with the FAA Aviation Rulemaking Advisory Committee (ARAC) Part 145 Working Group and FAA AFS personnel.
• Brett and Sarah convened numerous meetings related to ARSA’s repair station manual compilation.
• Christian attended the ST Engineering Board reception (Apr 11).
• Sarah, Christian and Brett met with Robert Ireland and Kevin Berger of A4A (Apr 12).
• Christian had a meeting with Drew Jacoby Lemos of the Regional Airline Association regarding FAA reauthorization (Apr 18).
• Christian had a meeting with Scott Luth of the Florida West Economic Development Alliance regarding the MRO industry (Apr 21).
• Brett met with Sharon DeVivo of the Youth in Aviation Taskforce (YIATF) to review draft recommendations (May 9).
• Christian attended the quarterly Aviation Security Advisory Committee (ASAC) Insider Threat meeting at TSA HQ (May 10).
• Christian and Brett had a meeting with Oliver Wyman (May 11).
• Marshall, Sarah, Christian and Brett met with Ludovic Aron of EASA (May 11).
• Christian met with Katarina DeFlippo of AIA to discuss pending legislative issues (May 13).
• Sarah and Marshall attended the John Hickey Celebration of Life event (May 17)
• Christian had a meeting with the International Air Transportation Association’s (IATA) Aviation Skills Working Group (May 18).
• Sarah and Marshall visited Mingo Aerospace in Oklahoma (May 20).
• Sarah spoke with a reporter from the Wall Street Journal (May 25).
• Brett and Christian spoke with Derek Costanza of Oliver Wyman regarding the aviation technician shortage (May 25).
• Christian met with the Aviation Subcommittee minority staff regarding the De Fazio anti-repair station bill (May 27).
• Sarah, Christian and Brett had a discussion regarding Russian sanctions with Washington Post (Jun 3).
• Sarah participated in the 2022 Safety Conference Maintenance Panel 6th coordination meeting (Jun 7).
• Christian and Brett held a collaboration call with Oliver Wyman (Jun 8).
• Christian held a meeting with GAMA, GE, and A4A regarding the Safe Aircraft Maintenance Standards Act (H.R. 7321)(Jun 10).
• Christian had a meeting with ATEC, AAR, AMFA, Inhofe staff to discuss strategy on the National Center for Advancement of Aviation (NCAA) bill (Jun 13).
• Christian and Sarah attended the 2022 FAA/EASA International Aviation Safety Conference (Jun 14-17).
• Christian had a call with the Senate Finance Committee (Majority staff) re: the NCAA bill (Jun 16).

EASA Publishes SMS Guidance

The European Union Aviation Safety Agency (EASA) has published new resources to facilitate compliance with its recently adopted safety management systems (SMS) requirements for EASA Part 145 maintenance organizations. The new EU SMS requirements are not applicable to EASA approved repair stations in countries with bilaterals, such as the United States.

The FAA currently requires SMS for operators, airports, air traffic organizations and commercial space. Some U.S. repair stations are voluntarily adopting SMS to meet customer demands and/or in anticipation of future requirements. Runway Girl Network recently reported that the FAA’s upcoming SMS rulemaking for aircraft and engine manufacturers will seek comment on whether non-scheduled part 135 operators, part 91 tour companies and repair stations should also be required to adopt SMS. Since SMS is on the horizon for the entire industry, understanding EASA’s SMS requirements for its approved maintenance organizations will facilitate future compliance.

Pursuant to European Commission implementing Regulation (EU) 2021/196311, effective Dec. 2, 2022, EASA Part 145 organizations must implement SMS within a two-year transition period (through Dec. 2, 2024). The system must include, among other things, hazard identification, risk management and safety assurance processes, and the designation of a safety manager. To support SMS processes, the regulation also made changes to existing requirements related to an organization’s safety policy, internal occurrence reporting, competence of staff, and compliance monitoring.

EASA’s states in its new “Guide for Compliance with Part-145 As Amended by EU Regulation 2021/1963” that it recognizes “SMS is a concept that may need to mature over multiple years.” As such, the agency does not anticipate maintenance organizations will have “a fully operational and effective SMS in the first oversight cycle or at the end of the transition period.” It is the agency’s position that to retain its Part-145 certificate, an organization must show its system and procedures are ‘present’ and ‘suitable.’

The guide illustrates a typical process that a maintenance organization and its competent authority may follow to transition to the new requirements, describes a step-by-step approach for the transition, and provides guidance for competent authorities to use during the process. Appendix I explains the technical requirements EASA Part-145 organizations must meet; Appendix II applies to competent authorities.

EASA also issued a separate FAQ explaining references to “use of the organisation’s safety risk management process” in the requirement to assess non-mandatory modifications/inspections pursuant to CAMO.A.315(b)(4).

Working Group Instructs FAA on Handling Multiple Locations

Last month, the FAA’s Aviation Rulemaking Advisory Committee (ARAC) accepted a special report on the ability of a repair station to work from multiple locations under a single quality system. The report responded to a special request from the FAA’s Flight Standards Office seeking recommendations on the topic. It was presented by ARSA Executive Director Sarah MacLeod in her role as co-chair of ARAC’s Part 145 Working Group.

The working group reviewed scenarios in which repair stations choose either to (1) operate multiple locations under a single certificate and quality system or (2) request satellite repair station certificates for each location. The report instructs the FAA to adjust its documentation to better associate additional locations (removing the word “fixed”) or satellites with the repair station holding managerial control.

The special report introduces the Acceptable Means of Compliance (AMC) document under development by the working group. The AMC provides a section-by-section review of the repair station rule, divided in five segments for each section:

Scope explains the requirements associated with the plain language of the section or paragraph.

Acceptable Means of Compliance provides guidance to applicants and the FAA on what is expected to establish compliance.

Guidance Material contains information necessary for the agency to process the application or request

Related Regulations lists the sections of the 14 CFR parts 43, 65, and 145 that related directly to the section being reviewed.

Additional Information explains the expectation of international aviation authorities, quality assurance and air carrier customer requirements, and the advantages of best practices (provided for reference, but a federal agency cannot demand certificate holders go beyond the plain language of a regulation).

The working group provides AMC content for §§ 145.51(a) and 145.53(a) for reference by the FAA on adjusting current guidance to accommodate applicants and certificate holders.

To review the complete special report, click here.

To review previous updates related to the working group, including a list of organizations represented, review the content on arsa.org/145-task.

FAA Moving ADs to Dynamic Regulatory System

The FAA is continuing to decommission systems and migrate documents to its Dynamic Regulatory System (DRS). On Aug. 16, the agency will retire the following databases within the Regulatory Guidance Library (RGL):

• Emergency Airworthiness Directives (EAD)
• Airworthiness Directives (AD)
• Airworthiness Directives: Biweekly (AD Biweekly)

These AD documents will only be available on the DRS, but users may still receive notifications about published ADs and EADs. New notification subscriptions may be made via the FAA GovDelivery Service and selecting any applicable categories; existing subscriptions will continue without any needed action. Other notifications and distributions of Emergency ADs will also remain unaffected.

The FAA will continue to provide mailed copies of the AD Biweekly, which is a paid subscription of all ADs issued in the Federal Register over the previous 2-week period. The AD Biweekly is printed and mailed by the Government Printing Office (GPO).

For assistance using new features of the DRS, the FAA provides the following resources:

(1) General DRS Help & Training (click here).
(2) EAD Search Guide PDF (click here).
(3) AD Search Guide PDF (click here).
(4) AD Biweekly Search Guide PDF (click here).

UK CAA and FAA to Continue of MIP beyond 2022

The existing procedures were agreed between the UK and the USA in January 2021, which allowed for the continuation of maintenance organisation approvals between the UK and the USA post-EU Exit until 31 December 2022. These will now be extended beyond the end of the year.

The industry does not need to take any action prior to 31 December 2022 as there will be an implementation period for the new procedures.

Click here to see the source release from the UK CAA’s Skywise communications system.

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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Legal Brief

Editor’s note: 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.

Layman Lawyer – Being Entitled

By Brett Levanto, Vice President of Operations

I’ll admit that “entitlement” can be a tricky word. In Washington, D.C. politics, it describes often-contentious government spending programs like Social Security and Medicare. In general culture and especially on some annoying corners of social media, the word describes the attitude and behaviors of people seeking special treatment or attention.

In aviation safety, there’s a very important and positive use of the term. In fact, this layman lawyer encourages his counterparts in the industry to remember just how “entitled” they are.

In January and again last month, this space provided a “layman lawyer” overview of the FAA’s Compliance Program. So far, this series has covered agency guidance to illustrate how inspectors and other officials are supposed to understand their responsibility to use critical thinking in assessing deviations for corrective action under that program. It’s useful to know how the agency instructs its people, but certificate holders must focus on the plain language of 14 CFR.

When working with companies seeking repair station certificates – particularly users of ARSA’s RSQM Compilation – ARSA Executive Director Sarah MacLeod often reminds them of an important statement in § 145.53(a), which says that with few exceptions “a person who meets the requirements of [part 145] is entitled to a repair station certificate with appropriate ratings prescribing such operations specifications and limitations as are necessary in the interest of safety.” (Emphasis added.)

The word “entitled” is not defined in 14 CFR. The common definition in the Merriam-Webster Dictionary is “having a right to certain benefits or privileges.” While an aviation safety inspector’s attitude may make it seem that certification is a blessing bestowed by the government, it is a right earned by persons demonstrating compliance with the plain language of the applicable rules. It is based on this simple principle that the association stands up to the government in showing compliance.

The submitter of this month’s “A Member Asked” showed the basics of this understanding. An inspector challenged the repair station’s manual revision process, citing a paragraph in Order 8900.1. “This is his guidance material, but to us it is not regulatory,” the member said.

Starting and ending with that awareness is essential to getting and maintaining a certificate and dealing with the government along the way. A certificate holder’s compliance responsibility is the minimum standards of the rules. When the FAA challenges you, show how your systems and procedures meet those standards and not the guidance provided to the aviation safety inspector.

By meeting the requirements of the rule, you are entitled to have and hold a certificate and its associated privileges. You earn this entitlement.

Help continue this discussion. Submit your “layman lawyer” experiences or questions via arsa.org/contact.

Before Enforcement

By Sarah MacLeod, Executive Director

While showing compliance with the rules, repair stations often find themselves at odds with the government. Inspectors try to enforce their own preference or tribal knowledge or hew to internal guidance at odds with the plain language of the rules. The association encourages – and helps – its members in these situations to stand firm and professionally push back.

The resulting dialogue can clear up confusion and find compromise (think carefully whenever you give ground without a regulatory requirement!). Sometimes it’s not enough, and the matter results in a “legal enforcement” action.

The precursor to the agency taking legal action for an alleged violation is a letter of investigation (LOI). That letter will contain a number usually starting with the year followed by other numbers and letters. The issuance of that “enforcement investigatory report” (EIR) number indicates that “evidence” is being collected.

The EIR will contain the name of the alleged violator, a description of the incident, witnesses, a summary of the incident including specific regulatory non-compliance, all items of proof, and the inspector’s analysis and recommendations.

In other words, everything you say, have said, show, have shown, do, have done or provide or have provided will be used against you. If you have not already instituted a practice of documenting every substantive contact with a representative from the FAA, after the LOI is received may be too late. Making a record of every substantive contact with an FAA representative by date, time, who was present, what was said, done, promised, exchanged will be a key to successful resolution of any issues (before and) after an LOI is issued or civil penalty or certificate action (legal actions) is taken.

The EIR is reviewed first by the local office, which can determine either that no violation took place or that remedial action is the best way to handle the matter. Certificate holders need to understand that even after the EIR is initiated, there is still time to provide evidence of compliance to avoid legal action. While there is a pervasive insistence that once a certificate holder is “under investigation”,,” resolution is in the hands of the lawyers— – the facts belie the myth. The local office can determine any time before (and even after) sending the matter to the region for review that the allegations do not warrant legal action.

If the local office does not clear the matter, it will be reviewed by the regional office which can determine that:

(1) Legal action is warranted and refer the matter to the Office of Chief Counsel for civil penalty or certificate action or to request a reexamination.

(2) The matter warrants review by or referral to authorities for criminal action.

(3) Administrative action is warranted. Administrative action would result in referral back to the location office for the issuance of a warning notice or a letter of correction.

(a) A warning notice recites available facts and information about the incident or condition and indicates that it may have been a violation.

(b) A letter of correction confirms the FAA decision in the matter and states the necessary corrective action the alleged violator has taken or agrees to take. If the agreed corrective action is not fully completed, legal enforcement action may still be taken.

(c) Once the local and regional offices have determined legal action is warranted, the matter is turned over to the Office of Chief Counsel.

Next month’s “Legal Brief” will cover the process by which the agency pursues civil penalties and/or certificate actions. In preparing your mind, you should familiarize yourself with these ARSA online training sessions:

(1) Preparing For, Responding To, and Receiving an LOI or NCPC

(2) Overview of the FAA’s Investigation & Enforcement Powers

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ARSA on the Hill

Your Town’s Politics

Engaged citizens are vital to a functioning democracy; active participation at all levels of government drives good policy in the political process.

Many politicians or their supporters host town hall or other local community events. These meetings are a chance to initiate meaningful dialogue.

Here are some ways to make the most of any local political meeting:

• Be Prepared to Speak Up. Be ready to ask thoughtful, concise questions. Have data to support your concerns and positions. This will ensure you are remembered by the representative and staff.
• Make it Personal. It is important to establish yourself not just as a constituent but as a representative of other voters. Talk about your company – the type of work it does and number of employees. Know how a policy will affect you or your family, business or community and provide firsthand accounts of that impact.
• Talk to Staff. Members usually bring several members of their staff to meetings. Be sure to interact with them, particularly if you are unable to interact with the boss. In all cases, obtain their business cards or write down names, titles, and contact information.
• Leave Paper. Provide literature about your business. If you don’t have brochures or information cards available, you can use ARSA’s basic company profile template. Share any documents that support your position or concerns, including ARSA’s legislative priorities brochure, with the elected official or staff member.
• Follow Up. Be politely persistent by following up with your representative after an in-person event. Creating a dialogue is the first step, maintaining that dialogue is key issue to recognition and resolution.
• Attend Multiple Events. Have other people from your company attend meetings, so that the representative can hear about the issue from multiple voices with the same concerns.

The more often you are seen and heard, the more likely the politician will heed your concerns. Local political meetings or events are a good way to stay in touch and keep yourself updated local, state, or federal government actions.

To find your current federal lawmakers, go to arsa.org/congress. scroll towards the bottom of the page to “Find Officials”, enter your address when indicated, and click the forward arrow button. On the next page, you’ll see a list of all your federal officials (president, vice president, senators, and representative).

Information on events scheduled or occurring in your area are available from the staff at district offices. You may also learn of an event through your local paper, newscast or congressional office’s newsletter or website.

As always, keep ARSA in the loop on your efforts. The legislative team will help take your personal engagement to an industry-wide level.

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Training

Make ARSA Training Work

ARSA’s online training program represents its most-valuable benefit to the aviation industry: knowledge gained through training and experience. The association’s team has turned its decades of work on behalf of aviation maintenance into more than 80 hours of on-demand content.

While sessions are available for registration at any time – ARSA member discounts available – companies can also incorporate the association’s training into their regular programs:

(1) Subscription. Make up-front, bulk purchases of training hours. The details of each subscription can be customized, including focus on specific subject areas (e.g., human factors) or options for specially-priced session access after the initial hours have been used.

(2) “Championing” a session. Guarantee a certain number of attendees for training in a particular topic that will also be made available for general registration. Variations include open registration for a live session (i.e., company personnel participate at the same time as general registrants) or a company-specific live event for which a recorded version (not including any company-specific information) is made available for on-demand registration.

(3) Tailored training. Contract ARSA’s management firm Obadal, Filler, MacLeod & Klein, P.L.C. to produce or modify training specific to your organization. The team can then re-record it (or offer it as a separate live session) for ARSA’s training program. Tailored programs are priced differently from ARSA’s hourly rate and are administered by OFM&K, which allows for a client engagement and related attorney-client privilege for all discussion.

To review sample syllabi of training session options from the firm – many of which have similar sessions available generically through ARSA training – click here to download a combined PDF. The syllabi include “Regulatory Comprehension for Maintenance,” “Public Aircraft,” “AD Compliance” and more. 

Click here to go directly to the training platform (operated by ARSA’s management firm) and begin reviewing available sessions.

For more information about ARSA’s training program, review the menus below. If you have questions or would like to learn more about ways to integrate ARSA training into your own program, contact Vice President of Operations Brett Levanto (brett.levanto@arsa.org).

The association’s training program is provided 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. To learn more about the association’s training program and see course availability, visit arsa.org/training.

What training do you need? Contact ARSA to let the association know and help get it developed.

Handling Investigation & Enforcement

After the Audit and Before the LOI

This session reviews the regulations, policies and procedures that generate letters of investigation and the best methods for responding to governmental questions.

Instructors: Sarah MacLeod, Christian A. Klein & Brett Levanto

Click here to register and get access for 90 days.

Receiving & Responding to an LOI

This session reviews the regulations, policies and procedures that generate letters of investigation and provides some best practices for developing and delivering responses.

Instructors: Sarah MacLeod, Christian A. Klein & Brett Levanto

Click here to register and get access for 90 days.

Receiving & Responding to an NPCP

This session reviews the regulations, policies and procedures that generate notices of proposed civil penalties and provides some best practices for developing and delivering responses.

Instructors: Sarah MacLeod, Christian A. Klein & Brett Levanto

Click to register and get access for 90 days.

Investigation & Enforcement Under Part 13

This session reviews 14 CFR part 13, which defines the FAA’s powers of investigation and enforcement. It walks through the rule in order to explain its organization and define the procedures and authority contained within each of the nine subparts. To support this general overview, the session highlights key sections and phrases within each subpart.

Instructors: Sarah MacLeod & Brett Levanto

Click here to register and get access for 90 days.

Registration for an ARSA-provided training session includes:

• Access to the on-demand, recorded version of the webinar to be made available after the live session is complete (or at time of purchase, for on-demand classes).
• A copy of the presentation and all reference material with links to relevant resources and citations.
• Upon completion of the class as well as any test material, a completion certificate.

The association’s training program is provided 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. To learn more about the association’s training program and see course availability, visit arsa.org/training.

The Rulemaking Process – Effective Comments

This session provides methods for submitting effective comments on FAA rulemaking proposals and on other documents that are posted for feedback from stakeholders.

Instructor: Sarah MacLeod

Click here to register and get access for 90 days.

Registration for an ARSA-provided training session includes:

• Access to the on-demand, recorded version of the webinar to be made available after the live session is complete (or at time of purchase, for on-demand classes).
• A copy of the presentation and all reference material with links to relevant resources and citations.
• Upon completion of the class as well as any test material, a completion certificate.

The association’s training program is provided 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. To learn more about the association’s training program and see course availability, visit arsa.org/training.

Regulatory Compliance Training

Test your knowledge of 14 CFR §§ 11.61 & 11.63, how to submit written comments.

Click here to download the training sheet.

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Membership

Members Getting Members

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. It really is that easy.

Program details:

• For each paid membership referral, the referring member will receive a credit of 10% of the applicant’s dues on its forthcoming membership renewal. For example, if you refer a $1,800 member, you will receive a credit of $180 towards your next membership renewal.
• The maximum benefit is 100% of the referring member’s annual membership dues.
• The applicant must clearly indicate on its application the name of the member company that referred it for membership.

Click here to download a draft message you can use to begin recruiting new ARSA members.

Become a Champion

A great way to recruit members is to promote the association actively at industry meetings and trade shows. Champions display ARSA-provided materials at their company exhibit booths.

Interested? Contact ARSA.

Quick Question – Event Selection

Why do you go to an industry meeting or event?

It’s a good time to start planning to attend ARSA’s 2023 Annual Conference (and schedule out your annual travel itinerary for industry events). You can prepare yourself and help the association’s team by sharing what you value most about the experience.

What is it that you look for in attending an industry event?

Note: The question is displayed in its own, embedded window. If the “Submit” button is not visible on the screen, you must scroll within the survey window in order to submit your response.

If the embedded survey does not appear/load, open the survey independently by visiting: https://www.surveymonkey.com/r/qq-event-selection.

Click here to see what questions have been asked and answered…and keep a lookout for more.

Welcome & Welcome Back – New & Renewing Members

ARSA’s members give the association life – its work on behalf of the maintenance community depends on the commitment of these organizations. Here’s to the companies that joined or renewed in July:

New Members
Atlantic Cape Community College, Edu
Aereos Defense, LLC, Assoc
Airbus Americas, Inc., Assoc
GA Telesis Component Repair Group Southeast, LLC, R04
Vanguard Aerospace, LLC, R01

Renewed Members
Aero Design Services, Inc., Affil, 2000
Aero-Mark MRO, LLC-dba Certified Aviation Services, R02, 2015
Aerotron AirPower, Inc. dba Fokker Services Americas, R04, 1990
Arista Aviation Services, LLC, R04, 2018
Bemidji Aviation Services, Inc., R03, 2017
Cosgrove Aircraft Services, Inc., R01, 2021
Dan Brauhn-Indian Hills Community College, Edu, 2015
IBM Flight Services, Assoc, 1997
EXTEX Engineered Products, Inc., Assoc, 2002
Florida Jet Center, Inc., R02, 2013
General MRO Aerospace, Inc., R03, 2015
Lynden Air Cargo, LLC, Assoc, 2000
Metro Aviation, Inc., Assoc, 2003
Nampa Valley Helicopters, Inc., R02, 1993
Pacific Aero Tech, LLC, R03, 1994
REB Technologies Inc., dba REBTECH, R02, 2003
Regional Avionics Repair, LLC, R03, 2006
Rotorcraft Repair & Manufacturing, LLC, R01, 2019
Texas Air Services, Inc., R02, 2003
Twin Manufacturing Co., dba TWIN MRO, R04, 1993
Unipak Aviation, LLC, R02, 2003

A Member Asked…

Q: As required by § 145.211(c)(3) our Quality Control Manual references a separate “forms manual.” We have and maintain this forms manual at our repair station, and it is available for review by our FAA.

Our new FAA PMI is stating that our “Forms Manual” must be officially accepted by the FAA and if we add or change any forms it must go to our PMI to be accepted every time it is revised.

We disagree and do not believe the “forms manual” for our repair station must be “officially accepted” by our PMI before implementation. We believe the regulation only requires us to have and maintain this forms manual and have it available for review by the FAA.

Our PMI is referencing the 8900.1, Ch. 9 Section 11 paragraph 6-1843, this is his guidance material, but to us it is not regulatory.

Your input and or any information regarding this would be greatly appreciated.

A: The only manual that needs approval (or any positive response from the FAA) is the training program manual.

The repair station manual (required by 14 CFR §§ 145.207 and 145.209) and quality manual (required under § 145.211) need to be acceptable to the FAA. Those words do not require any action by the agency, only action by the certificate holder to ensure the elements in those sections are in the manual(s).

The samples of inspection and maintenance forms, and their instructions for use may be in a forms manual that is separate from the quality manual as stated in § 145.211(c)(3). Although there are no revision requirements for the sample forms and instructions, the requirement is tied to the quality manual elements, so a revision process should be developed, including how often the certificate holding district office is notified of changes.

The plain language of the applicable regulations did not stop the FAA from putting a “requirement” for its inspectors to “accept” the repair station, quality and/or forms manuals. You’re absolutely right the requirement for the aviation safety inspector to “accept” the manual is an internal not external “requirement”. In other words, with or without the “acceptance by” the agency, the manual(s) can be changed in the manner dictated by the certificate holder in its manual(s).

So, the applicant/certificate holder (you) must provide a manual that is “acceptable to” the FAA (which means it must have the elements required by 14 CFR §§ 145.207, 145.209 and 145.211). There is NO regulatory requirement that the applicant/certificate holder await “acceptance by” the agency to implement any changes or actions. NOTE: Unless the applicant/certificate holder said that it would await “acceptance by” the FAA in its §§ 145.209(j) or 145.211(c)(4) or (d)) procedures for “revising the [repair station or] quality control manual required under this section and notifying the responsible Flight Standards office of the revisions, including how often the responsible Flight Standards office will be notified of revisions.”

Therefore, unless you have written procedures in your own manual(s) under section 145.209(j) for the repair station manual, or the quality control manual under section 145.211(c)(4) or (d) “requiring” the FAA to review and accept changes, there is no mandate in the regulations that those manuals or the forms manual be “accepted by” the agency before use or implementation.

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Resources

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.

About ARSA PAC

ARSA’s Political Action Committee helps elect congressional candidates who share ARSA’s commitment to better regulation and a strong aviation maintenance sector.  But ARSA is prohibited from sending PAC information to members who haven’t opted in to receive it.

U.S./EU Maintenance Annex Guidance

See all of the association’s public updates since 2012 on the Maintenance Annex Guidance between the United States and European Union. The page focuses in particular on matters related to parts documentation issues arising since MAG Change 5 was issued in 2015.

The FAA Enforcement Process

There are several reasons the agency may open an enforcement investigative report (EIR). Complaints from former or current employees, routine surveillance of your operations or a problem from a customer are all examples of how an “investigation” starts.

Industry News Roundup

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Industry Calendar

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