Aircraft Electric Motors is a founding member of ARSA. Since 1984, AEM’s commitment has been visible through event sponsorship, advertisements, appearances in industry documentaries and constant support of the association’s work. Once again, the company’s investment provides congressional directories for Legislative Day participants and arsa.org/congress for members year round.

Coopesa is one of ARSA’s leading international members, providing global perspective to its Board of Directors and regularly represented at association events. This global company is helping its American colleagues engage with Congress by providing meals on Legislative Day.

First Aviation Services is always driving ARSA forward. The company is represented on the association’s board of directors, continually engages on industry matters and stands up for good government. This year, ARSA President Josh Krotec is helping keep the Symposium day going by providing for lunch on March 16. 

HAECO Americas supports air carriers around the world and has long been an outspoken voice on behalf of ARSA and the aviation maintenance industry, hosting government officials and training sessions while lending insight and experience to the association. HAECO’s commitment makes possible to engagement of Legislative Day, when its team will be well represented in advancing aviation policy on Capitol Hill.

Moog is a world leader in flight control systems and critical control products, with facilities across North America, Europe and Asia. The company boasts a former ARSA team member and reflects the association’s focus on good safety and good business. Executive to Executive Briefing participants on Tuesday, March 14 will be well fed and refreshed thanks to Moog’s commitment this year. 

MRO Holdings’ philosophy is to recruit, train and invest in the best people to provide airframe and engineering services. That philosophy has lead the company to its ARSA corporate enterprise membership: Investing in cost avoidance for its own business and the best leadership for the industry. This year, MRO Holdings will help participants relax after the Symposium portion of the event on March 16 by welcoming them into the “Club Lounge Happy Hour.”

Lufhansa Technik is one of the world’s leading suppliers of maintenance and modification services for civil aircraft and has been a corporate enterprise member of ARSA for more than 20 years. The company prices itself on its innovation, so naturally its 2023 investment will support the Conference’s “online experience,” including both the resource-heavy digital companion and the livestream available to online registrants and Conference Ambassadors. Willkommen zurück auf der Konferenz, wir haben Sie vermisst.

Wencor has been a trusted partner in aerospace and defense for more than 60 years. As one of ARSA’s newest corporate enterprise members, Wencor has brought its support of the global aviation community full circle by taking a leading role at the maintenance industry’s premier substantive event. This year, the company’s support will help foster new relationships and bolster existing ones during the Ice Breaker reception on Wednesday, March 15.

Sponsors | Registration | Information

Thank you to the 21 organizations that have committed to sponsor ARSA’s 2023 Annual Conference. From digital materials to evening refreshments to full days of content, these companies are dedicated to the Conference’s success.

Platinum

Gold

Silver

Supporter

Contributors

Sponsors | Registration | Information

In-Person

All substantive and social activities will be hosted at the Ritz-Carlton, Pentagon City in Arlington, Virginia. Specific room assignments can be found in the Digital Companion, a password-protected webpage for participants to access the agenda, speaker information and presentation resources (access information will be sent to attendees ahead of the event). In general, each day of the event will take place in the following rooms:

March 14 – Executive to Executive Briefings: Ambassador Room

March 15 – Legislative Day & the Evening Ice Breaker Reception: The Diplomat Room

March 16 – Annual Repair Symposium: The Grand Ballroom

March 17 – Annual Member Meeting: The Grand Ballroom (Salon III) 

Livestream

The majority of conference events will be available to livestream registrants and “Conference Ambassadors” (free online access given to a contact identified by in-person participants) via a Vimeo web-player embedded into a page on ARSA.org. (Access provided via Digital Companion, access information will be sent to attendees ahead of the event). In general, the schedule is:

March 14 – Executive to Executive Briefings: No Livestream

March 15 – Legislative Day & the Evening Ice Breaker Reception: All panels livestreamed from 8:00 a.m. to 1:00 p.m. No livestream for the Ice Breaker Reception.

March 16 – Annual Repair Symposium: All panels and speakers livestreamed from 8:00 a.m. to 5:00 p.m. No livestream for the Club Lounge Happy Hour.

March 17 – Annual Member Meeting: Member meeting livestreamed from 8:00 a.m. to 10:00 a.m. Online participants may join a breakout session via Microsoft Teams (details provided directly).

Sponsors | Registration | Information

Note: This agenda also highlights with a which elements of the Conference will be available via livestream.

Executive to Executive Briefings: Tuesday, March 14, 2023

Industry executives participate in meetings with senior executive branch officials organized by ARSA. Participation is limited to annual conference sponsors, with the number of slots available to each sponsoring organizations dependent on level of support.

8:45 a.m. | Coffee and Light Breakfast

9:00 a.m. | Introductory Briefing

10:00 a.m. | U.S. Department of Commerce

Scott Kennedy, Director, Office of Transportation & Machinery

10:45 a.m. | Break

11:00 a.m. | U.S. Department of State

Richard Yoneoka, Deputy Assistant Secretary for Transportation Affairs

12:00 p.m. | U.S. Department of Transportation (Invited)

Annie Petsonk, Assistant Secretary for Aviation & International Affairs (Invited)

12:45 p.m. | Lunch/Midday Break

2:00 p.m. | U.S. Department of Labor

Cierra Mitchell, Division Chief, Division of Industry Recognition, Analytics & Promotion

3:00 p.m. | Break

3:15 p.m. | Roundtable Wrap Up & Discussion

Legislative Day: Wednesday, March 15, 2023

After a morning of briefings and policy updates. Legislative Day participants meet with members of Congress as well as office and committee staffers to connect the impact of the maintenance community to each state and congressional district. The day will include ARSA’s release of its Annual Global Fleet & MRO Market Assessment, produced by Oliver Wyman, as well as the presentation of the association’s Legislative Leadership Award.

7:30 a.m. | Registration & Breakfast

8:00 a.m. | Welcome & Introductions

8:15 a.m. | It’s All About Your Industry and Your Company

Find out what’s at stake in Washington for your company and your industry, where things stand, and what you can do to impact the process.

9:00 a.m. | Engaging for Effect

Industry colleagues share insights and lessons learned from their companies’ engagement with government. 

Josh Krotec, Senior Vice President, First Aviation & 2023 ARSA President 

Etain Connor, Director, Community Affairs, FEAM Aero 

Bob Arnett, Vice President, Earp Aviation Repairs 

9:45 a.m. | Break

10:00 a.m. | Congressional Staff Panel

House and Senate Aviation Subcommittee staff discuss the 2023 FAA reauthorization process and substance.

11:00 a.m. | Advocating a Broader Agenda

There are general business groups advancing a broader agenda. Vehicle for engagement with elected officials via local Chambers, access to subject matter experts, support for broader business goals.

Katarina DeFilippo, Director of Legislative Affairs, Aerospace Industries Association

Jarrod Thompson, Vice President, Legislative & Regulatory Policy, Airlines for America

Sterling Wiggins, Senior Director, Transportation, Infrastructure, and Supply Chains, U.S. Chamber of Commerce

11:45 a.m. | Buffet Lunch Served

12:00 p.m. | Release of the 2023 Global Fleet & MRO Market Report, produced by Oliver Wyman

Livia Hayes, Director, Oliver Wyman CAVOK

Madeline Stelle, Technical Analyst, Oliver Wyman CAVOK

1:00 p.m. | Congressional Meetings Begin

Attendees schedule independent meetings with representatives, senators, and key staff.

Presentation of the 2023 ARSA Legislative Leadership Award to U.S. Senator Jerry Moran

Special invitation only

4:00 p.m. | Symposium Registration Opens (for non-Legislative Day attendees)

5:30 p.m. | Ice Breaker Reception

7:00 p.m. | Special Invitation Dinner

Annual Repair Symposium: Thursday, March 16, 2023

The centerpiece of Conference week, ARSA convenes a full day of substantive panel discussions covering key regulatory compliance and business issues.

8:00 a.m. | Welcome & Introductory Remarks

Find out how the association is advocating for your interests with legislators, regulators, and the media. Information on how you can help advance the industry’s collective interests.

Sarah MacLeod, Executive Director, ARSA

8:30 a.m. | Keynote Address

After almost a year in his role as the agency’s administrator, Nolen returns to ARSA’s stage to update participants on his efforts to bring order to FAA management and make progress on key initiatives.

Billy Nolen, Acting Administrator, FAA

9:15 a.m | Opening Salvo – Conversations with the Regulators

International agencies will provide updates on the regulations, policies and procedures governing the maintenance industry.

Dan Elgas , Acting Deputy Director, Policy and Innovation Division Aircraft Certification Service, FAA

Robert Ruiz, Director, Office of Safety Standards, Flight Standards Service, FAA

Jeffrey Phipps, Chief, Operational Airworthiness (AARTN), Transport Canada Civil Aviation

Lawrence Josuá Fernandes Costa, Continuing Airworthiness Certification Manager, Department of Flight Standards, ANAC Brazil [Online]

Gustavo Lima Carneiro, Civil Aviation Regulation Specialist, Department of Flight Standards, ANAC Brazil [Online]

Ludovic Aron, Washington Representative, EASA

Karl Specht, Principal Coordinator Organisation Approvals, EASA [Online]

Neil Williams, Head of Airworthiness, Policy & Rulemaking, United Kingdom Civil Aviation Authority

12:30 p.m. | Lunch with Special Guest

An ally trade association leader shares thoughts on what true industry collaboration looks like and how the partnership between ARSA and HAI serves both memberships.

James Viola, President & CEO, Helicopter Association International

2:00 p.m. | Young at Heart

A discussion about various ways to tap into the interest of students and introduce aviation pathways, including non-aviation examples and points from the two congressionally mandated committees investigating career development.

Paul Lukas, Teen Program Executive, Connecticut Yankee Council, Boy Scouts of America

Alison McHugh, Vice President, Safety & Quality, FEAM Aero

Sean Torpey, Executive Director for National Engagement and Regional Administration, FAA

3:00 p.m. | ARSA Quiz Show

3:30 p.m. | Break

4:00 p.m. | Making the Old New Again

How can repair stations leverage new tools to repair legacy designs while keeping up with advancing needs of newer fleets? Using the plain language of parts 21 and 43 to manage pressures and make good on opportunities presented by “emerging” technology.

John Riggs, Director of Airworthiness, Chromalloy

Robert Roedts, Vice President of Aircraft Solutions, Columbia Helicopters

Sarah MacLeod, Executive Director, ARSA

5:00 p.m. | MRO Holdings Club Lounge Happy Hour

Member Day: Friday, March 17, 2023

ARSA’s leadership briefs members on the state of the association as well as goals and priorities for the coming year. The ARSA team then closes out the event by walking through a series of key initiatives and updates from the association’s work on behalf of the industry.

8:00 a.m. | Annual Membership Meeting & Breakfast

Call to Order
State of the Association
Questions
Adjournment

10:00 a.m. | Breakout Sessions

Online participants may join via Microsoft Teams.

Workforce Workshop – Open discussion and applied examples tying together career development policy, resources, the work of the Department of Transportation’s Youth Task Force and Women’s Advisory Board, and participant experiences with company programs.

Pragmatic SMS – Presentation from Aircraft Electronics Association on constructing and documenting SMS-style programs.

Ric Peri, Vice President of Industry & Government Affairs, Aircraft Electronics Association

12:00 p.m. | Conference Ends

Anti-Viral Measures

The President’s Desk

State of the Conference

On Friday, March 17, I will give the annual “State of the Association” address to members at the Annual Meeting on the final day of ARSA’s Annual Conference. It’s the moment of highest-visibility in each president’s year-long term: chronicling the association’s work and outlining its direction for its most-engaged members near the completion of its centerpiece event.

Considering the speech in that context can be nerve wracking – following in the entertaining footsteps of my predecessors certainly is – but there’s more to it. It’s a conversation, not just a standalone presentation. ARSA’s team, and especially Executive Director Sarah MacLeod, actively participate in discussion, soliciting questions, and driving home key points. Even though I will stand alone at the podium, the Annual Meeting is yet another illustration of how we’re never alone in compliance efforts with ARSA standing beside us.

It’s also helpful that the “State of the Association” fits in with the rest of the Conference’s presentations and content. By the time attendees gather for my remarks, they will have possibly experienced 16 different sessions showcasing more than 30 presenters representing governments from three different continents, member companies, private industry, and non-profit organizations. They will have benefitted from the commitment of 21 sponsoring organizations and engaged alongside the most attendees we’ve had onsite at the Ritz-Carlton since before the pandemic.

In short, while the Friday address is a big part of the president’s year, it’s a small piece of the week’s activity. While it’s an important communication of who we are and where we’re going, it is just a snapshot of everything being done on our behalf by the ARSA team.

In addition to the usual editorial content and monthly updates, this edition of the hotline will serve as your Conference preview. It celebrates sponsors, provides basic logistics and agenda updates (registrants will receive specific instructions and resources ahead of the event), and offers a final chance to register for either in-person or livestream attendance.

Come or connect and participate…and look forward to seeing my report in your inbox next Month.

Josh Krotec 2023 ARSA president | First Aviation Services, Inc. senior vice president

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ARSA Works

Listen Up for Better Regulatory Participation

ARSA encourages members to participate in the rulemaking process and it appears the government is trying to ensure public understanding and involvement. The Office of Information and Regulatory Affairs (OIRA) within the Office of Management and Budget (OMB) is a watchdog of sorts for the executive branch agencies. It will host a public Listening Session on “Public Participation in the Regulatory Process” on March 7, 2023 from 3:00 to 4:30 p.m. EST.

OIRA Administrator, Richard Revesz, will offer opening remarks and several agencies, including the U.S. Department of Labor and the Environmental Protection Agency, will share their current efforts to expand public engagement in the regulatory process. OIRA will open the floor to participants to share ideas and feedback on how federal agencies can better engage the public in all stages of drafting and implementing regulations.

OIRA is collecting ideas and feedback on its recommendations and “learnings” produced in previous listening sessions. To review and provide input, visit www.whitehouse.gov/omb/information-regulatory-affairs/broadening-public-engagement-in-the-federal-regulatory-process. To review ARSA’s engagement in the effort last November, see arsa.org/open-government.

Even if you can’t listen in on the March 7th session, you may provide feedback on the Summary of Learnings and Recommendations by reviewing them and providing information on the following questions:

• Which of the recommendations would most effectively broaden public engagement in the Federal regulatory process, especially from members of underserved communities and those who do not typically participate in the regulatory process? Are there recommendations that are not helpful?
• Are there obstacles or barriers to greater public participation, especially for underserved communities, that are not addressed by these recommendations? If so, are there other recommendations that we should consider?
• Are there existing materials, such as guides or tools, that would be especially effective in revising and potentially implementing these recommendations? What new tools or guidance are needed?
• How can intermediaries—such as trade associations or coalitions—be helpful in reaching individuals and small organizations or businesses, where have they been successful in doing so, and where might they be insufficient?

Interested members of the public can submit their feedback to publicparticipation@omb.eop.govas written feedback or recorded audio and video submissions. OIRA will be actively reviewing any submissions received through 5:00 p.m. EST March 10, 2023.

“Moving Letter” Added to Tools for Members

ARSA has added a new document to the “tools” it makes available free to members: a “moving letter.”

The new template attempts to outline the information a company should provide to the FAA about its plans for moving to a new facility. It defines procedures related to transferring equipment and personnel, managing activity at both locations during the moving period, and assures the agency that work will continue to be accomplished in accordance with part 43 and the repair station manual and quality system.

The letter was developed in support of specific association members. As it often does, ARSA turned that real-world experience into a generic resource for use by all repair stations.

For a basic overview of the regulatory requirements impacting a facility move, review the “member asked” shared in the January 2023 “hotline highlight” at arsa.org/hotline-highlight.

Learn more about all of ARSA’s publications (including the “tools for members”) by following the links below or going to arsa.org/publications.

Click the logo to go to the publications page.

Tools for ARSA Members| RSQM Compilation| Order Form|FAQ

Contact Resources – AFS Office Guide

ARSA team members constantly search for resources, guides and tools that might be useful for member compliance activities. This installment was delivered to the association by the FAA Office of Safety Standards:

The office has produced a new “Services and Contacts” directory, which is available as a downloadable PDF. The document includes names, contact emails, and office numbers for management and support personnel in each AFS office. It also provides a bulleted list describing each office’s areas of responsibility (e.g., it can be used to determine where to call/email before sending the message) and includes a link to the overall stakeholder feedback form.

The tool is particularly important since the FAA took down its searchable employee directory several years ago, meaning this document is now the primary public tool for finding AFS personnel. Association members are encouraged to bookmark the page hosting the document. The FAA intends to update it regularly, so the industry should routinely return to the source for new versions.

To access the page, click here.

To download a copy of the directory as made available on Feb. 27, click here.

To see previous distributions of “resources” – this was the first in a while – at arsa.org/resources and click here for various links and sources to assist in your aviation compliance activities.

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 Non-bilateral

By Brett Levanto, Vice President of Operations

The industry has chased international harmony in the aviation safety rules for years. Bilateralism – our common shorthand for oversight performed under political collaboration between civil aviation authorities – feels like an accepted goal.

Should it be? Is it time to declare ourselves non-bilateral?

When advancing the bilateral cause, ARSA often cites a decade old study about the cost savings of certification under a bilateral aviation safety agreement. The 2011 report found it could require up to two and half times more investment for a U.S. repair station to become an approved maintenance organization under non-U.S. rules in the absence of a BASA.

That’s not the entire cost of approval. Dollar and cents payments for certification and oversight visits may be less under a bilateral agreement, but repair stations pay in the form of limited privileges and increased uncertainty. The many BASAs bearing American signatures do little for the maintenance community. Overarching agreement is great for the appearance of cooperation, but without robust maintenance implementation procedures (MIP), there is little of value to repair stations seeking to manage international responsibilities. For those few U.S. agreements that contain any consideration for maintenance operations, only Canada’s is truly reciprocal; our northern neighbors do not require the issuance of an additional certificate, saving the associated costs of applying for and maintaining it.

Despite hopes the contrary, WAR (world aviation regulations) is not on the verge of breaking out. In absence of such unity, certificate holders are left in the middle of international squabbles, dependent on their “home” authority to stand up for its rules in order to minimize additional hurdles to global compliance. The ongoing drama regarding documentation requirements for new parts used in work subject to the U.S./EU Maintenance Annex Guidance is a case in point. The authorities have misinterpreted their own joint definition of “export.” Rather than recognizing it is maintenance that is being exported – based on the standards of the Technical Implementation Procedures – the MAG’s requirement for an FAA Form 8130-3 traceable to the production approval holder treats the individual articles as exports themselves.

The misunderstanding was mitigated in 2016 by ARSA’s development of a process for inspecting new parts missing the supposedly required documentation. That “peace” fell apart last year when EASA inspectors pushed back on the FAA’s acceptance of the procedure, which was compliant with the U.S. aviation safety rules. When the most recent squabble broke out, repair stations using the procedure were caught in the middle. Inspectors performing Safety Inspection System audits – which are meant to surveil regulatory details, not assess the performance of approval holders – issued findings against the repair stations themselves for using a procedure deemed acceptable by their own government. Those certificate holders ended up fighting to demonstrate their own compliance with a system that eventually collapsed when the FAA refused to stand up for its own rules.

How is this better, financial costs aside, than independently getting EASA approval? Doing so would provide more privileges, less uncertainty, and no languishing while the authorities hash out their own differences.

ARSA continues to push for U.S. policy that will improve international cooperation. Its legislative priorities include regulatory reform that would make legitimate mutual acceptance of repair station certificates possible. That possibility still couldn’t become a reality unless the FAA used the resulting flexibility to give Canadian-style reciprocity to other authorities.

Before that happens, U.S. repair stations should consider the alternative: Coming out as non-bilateral.

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ARSA on the Hill

Setting Priorities

On Feb. 28, ARSA delivered a letter to the chairs and ranking members of the House and Senate committees and subcommittees with jurisdiction over aviation. The document presents the repair station community’s priorities for this Congress’ next reauthorization of the FAA.

The aviation agency’s current authorization expires in October. That law, passed in 2018 with considerable input from ARSA and its members, refocused the FAA’s attention on workforce and career development issues, and forced the government to make progress on key matters to the industry. From technician grant programs to repairman certificate exploration to studies of agency management, the last reauthorization process illustrated how driving discussion on Capitol Hill can produce tangible results in the regulatory and business environment.

There is a lot left to do, and the association’s letter outlined its next round of requests to lawmakers as they consider the FAA’s mission and operations. Reading the priorities is a must for anyone attending Legislative Day on March 15 – .

Regulatory Recommendations

(1) Aviation rulemaking and exemption due process.

(2) Timely resolution of investigations.

(3) Voluntary surrender of repair station certificates.

(4) Enhancing international cooperation.

(5) Enhancing access to maintenance data.

(6) Ending misapplication of FAA guidance.

(7) Limiting reversal of previous agency decisions.

(8) Clarifying STC requirements.

(9) Maintaining current foreign repair station oversight.

Workforce & Career Development Recommendations

(1) Expanding and enhancing workforce grant programs.

(2) Improving military transitions to civil aviation.

(3) Creating a National Center for the Advancement of Aviation.

(4) Improving interagency coordination and data collection.

(5) Reducing barriers to career entry.

To see the details related to each of these areas, click here to read the full letter.

For a basic overview of the legislative process, visit arsa.org/legislative.

Taking the Hill

On March 15, Legislative Day attendees will show members of Congress how important aviation maintenance is to home districts or states, the United States as a whole, and the world market. Whether an ongoing engagement or the beginning of one, these meetings put a face on the industry for elected officials and underscore the economic and political impact of the repair station community.

ARSA members can use this guide for running congressional meetings. The details will help when in the nation’s capital and can drive engagement back at home.

Purpose of Legislative Day

• Build industry visibility on Capitol Hill—in DC and in home states and districts.
• Advance policy objectives—of individual companies and the industry.
• Inform industry executives about what’s happening on the Hill.
• Build an engagement culture for the aviation maintenance industry.

Planning Tips for Congressional Meetings

• Schedule meetings with every office where you and your company are connected. Both senators (each state has two) and the representatives in the House for your home district, the facility’s district, the districts from which your employees come, and districts housing any other company offices or operations.
• Meetings can be requested at any time, it’s never too late; if nobody is available to meet, swing by and leave a business card, company information, and/or industry literature.
• Virtual and local meetings are very effective if you can’t get to Capitol Hill (or aren’t in D.C.).
• Coordinate with the office you’re visiting regarding access and security restrictions.
• Tell ARSA with whom you met and what you discussed.

Engagement is an ongoing process: follow up the meeting, keep in touch, invite members and staff for facility visits, and otherwise maintain continual connection with the office(s).

Talking Points and Discussions for Congressional Meetings

• Assume staff/lawmakers don’t know anything about your company or the industry. Remember that you know A LOT more than they do.
• Don’t use jargon (they don’t even know what part 145 is) … pretend you’re explaining to your grandmother.
• Prioritize: Don’t cover more than three issues and pick those most important to your business.
• Use economic data (2023 Global Fleet & MRO Market Report will be released on Legislative Day) to put industry in context, especially state-level employment, and revenue data.
• Tell the story of the past few years: pandemic impacts, government program support (Did you receive benefits? Why or why not?), supply chain disruptions, etc.
• Use ARSA legislative priorities to drive high-level points but make the details about your own professional experience.
• Don’t be afraid to say, “I don’t know … I’ll get back to you.”
• Don’t discuss campaign contributions.

Building the Grassroots

• Objectives:
  • Raise company and industry visibility.
  • Develop relationships between policymakers and industry leaders.
  • Make your company a trust source of info re: policy impacts.
  • Mint next generation of congressional advocates.
• Tactics:
  • Facility visits.
  • Attending fundraisers.
  • Town hall meetings.
  • Reach out periodically during the year.

On March 15, Legislative Day participants will focus their energy on advancing the industry’s interests before U.S. elected officials. However, this work should be done all the time and ARSA leads the way for its members year-round.

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Aviation Life Calendar

Something exciting happens every day in an aviation career.

If you want to keep aviation in the forefront of career choices, celebrate success every day with these resources. Every one provides a positive view of the industry’s ability to make the impossible an everyday event by individuals from every walk of life, socio-economic level, race, creed, color, religion, orientation, and physical capability.

Check back regularly for updates.

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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.

Contract Maintenance – Functions and Vendors

This session provides information on obtaining approval of maintenance functions and selecting and categorizing maintenance function vendors properly under 14 CFR part 145.

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.

Recordkeeping

Proper maintenance demands proper documentation. Review the association’s recordkeeping sessions – led by Sarah MacLeod and Marshall S. Filler – and learn how to “finish the job with proper paperwork.”

Recordkeeping for Mechanics
This session defines the regulatory responsibilities of the operator versus the maintenance provider in creating and maintaining maintenance records, including how obligations can be shifted by contract, but not under aviation safety regulations. It also covers maintenance recordkeeping regulations; the documents essential to making airworthiness determinations.
Click here to register and get access for 90 days.

Recordkeeping for Repair Stations
This session delineates the differences between operator maintenance records and those required to be created, maintained and provided by repair stations.
Click here to register and get access for 90 days.

Recordkeeping for Airlines
Air carriers have unique recordkeeping requirements under parts 121 and 135 that do not match the requirements for transferring an aircraft under part 91 or obtaining maintenance records from individual mechanics or repair stations under part 43. This session differentiates among and between the varying requirements so regulatory and contractual obligations can be clearly delineated.
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 §§ 11.91 & 11.101, comments on petitions for exemption.

Click here to download the training sheet.

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Membership

Member Survey Reminder

In February, each member primary contact was sent an invitation to complete ARSA’s 2023 Member Survey. Please ensure your company is represented in this year’s data by submitting a response (or ensuring one is submitted). If you don’t know who the primary contact is, we can help.

Each year, the association gathers intelligence on issues facing the international aviation maintenance community and its economic outlook. Responses improve ARSA’s services and provide data to support advocacy on behalf of the global aviation industry.

Direct any questions to brett.levanto@arsa.org.

See the report on last year’s member survey at arsa.org/survey2022.

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 February:

New Members
L2 Consulting, Inc. dba L2 Aviation, R04
Liebert Aviation, LLC dba Performance Flight, R02
Tommy Vining, EDU

Renewed Members
Aero Hydraulics, Inc., R01, 2021
AeroParts Manufacturing & Repair, Inc., R04, 2016
AeroRepair Corp., R03, 2012
AerSale Component Solutions, R03, 2013
AerSale Roswell Aircraft MRO Operations Center, R05, 2011
Airborne Maintenance & Engineering Services dba PEMCO World Air Services, R06, 2022
Alpha Aircraft Services of America, Inc., R01, 2012
Answers Aerospace Engineering LLC, R01, 2021
ATP USA, Inc, R01, 2017
Avgroup, Inc., Ro1, 2022
Aviation Avionics & Instruments, Inc., R03, 2012
Barfield, Inc., R05, 1995
Barfield Precision Electronics, LLC, R04, 1996
Cadorath Aerospace Lafayette, LLC, R03, 2005
Chromalloy, Corp, 1993
Colorado Northwestern Community College, EDU, 2021
Compressed Gas Systems, LLC, R03, 2012
Helimax Aviation, Inc., R03, 2019
INAir Aviation Services Company, R02, 2003
Mingo Aerospace, L.L.C, R03, 2005
Precision Airparts Support Services, Inc. , R02, 2021
Prime Turbines, LLC , R03, 2021
Rapco, Inc., Assoc., 1990
S3 AeroDefense, LLC, R02, 2010
Sky Aircraft Maintenance, LLC, R01, 2021
Tailwind Inspection, Inc., R01, 2006
TSA Rewinds Florida, Inc. dba Aircraft Armature Inc. , R02, 2019
Turbine Aircraft Logistics, LLC, R01, 2021
Western Aero Repair, Inc., R03, 2011
Windsor Airmotive West Chester Division-Barnes Aerospace, R04, 1995

A Member Asked…When to shred?

Q: We have applied for A025 Ops Specs for digital manuals and recordkeeping. We have been saving all part 145 records and manuals to an electronic file for the last three years.

If we are approved for A025 operations specifications paragraph, can we shred all the paper files of the past two years? We are mainly concerned with training records and maintenance documentation.

A: The answer is both simple and complicated (what a surprise). It ends with a challenge to your basic premise…but we’ll get to that.

First, all companies should have general business record retention. The best place to start is with the government agency that requires the longest duration of record retention. Supposing this is the U.S. Internal Revenue Service, tax returns rely on some of the same records that support the maintenance operations: materials consumed, and time expended to accomplish the invoiced service.

When it comes to 14 CFR records, let’s start with—

Section 145.219, which requires §§ 43.9, 43.10, and 43.11 records to be kept for at least two years after the work is approved for return to service. Link that retention period not only to the business records for material and labor (for the names of the persons, including maintenance function contractors, performing the work, see, 43.9(a)(3)) but to any required by the customer in its contract. If the customer is covered by section 145.205, the retention period must be that dictated by the general maintenance manual of the operator.

Next, let’s look at any section of part 145 that dictates length of retention other than the maintenance and inspection records. What has the company described or provided in the forms and instructions required by § 145.211(c)(3)? The RSQM and/or the form instructions should explain compliance with § 145.219, referenced above.

Training records must be kept for two years after the training has been completed, or as required by the procedures in the RSQM or Training Program Manual (see, 145.163(c)).

If you keep a capability list, the self-evaluation has to be retained as long as the article is on the list, see, section 145.215(c).

Now, let’s go to the repair station and quality manual contents to determine how the “description of the required records and the recordkeeping system used to obtain, store, and retrieve the required records” required by section 145.209(i) impacts the record retention requirements for your company.

Other records that a repair station may obtain, store, and retrieve are historical—

(1) Repair station and quality manuals: to show what procedures were applicable if questioned later.

(2) Rosters: to show continued compliance with § 145.161, particularly paragraph (b).

(3) Calibration records: if you wish to extend calibration intervals or need to establish viability of an important piece of equipment.

(3) Audits/corrective actions: to determine effectiveness of past corrective actions and make sure you don’t return to a practice that caused a CAR in the past.

(4) Technical data used to perform maintenance (e.g., CMMs, drawings, DER repair substantiations) some of which may be explained in the RSQM—old manuals are great when the manufacturer pulls a repair or makes one “proprietary.”

In other words, do a thorough review of the varying timeframes you need to consider when deciding what you can “shred” and when.

Now the basic premise of your question: It is ironic that you believe you must “apply for” the operations specifications paragraph…have you found a regulation that dictates how you keep records?

This was important during the 1999 part 145 rulemaking. The 2001 final rule makes clear the repair station can obtain, store, and retrieve records in any “acceptable media.” Electronic records were specifically discussed as being acceptable. How does that translate into “requiring” an operations specifications paragraph when such paragraphs are only supposed to contain “limitations as are necessary in the interest of safety” on the rating issued to the repair station?

ARSA is fighting hard to eliminate the “need” for the paragraph altogether. In the meantime, please ask yourself what regulation you have supposedly been violating by keeping records in an electronic media?

At any rate, if you don’t have an answer to your question after you have run through the “evaluation” and set your corporate recordkeeping “policy” that includes those required by all agencies, including the FAA, contact ARSA.

Make ARSA’s Voice Your Own: Advertise

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 arsa.org/advertise.

Stand Up for ARSA

In order to provide world-class resources for its members, the association depends on the commitment of the aviation community. By sponsoring events and activities, supporters can help ARSA’s work on behalf of repair stations to endure.

Need a place to start? For information about opportunities, contact Vice President of Operations Brett Levanto (brett.levanto@arsa.org).

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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.

Careers in Aviation Maintenance

How do you share the industry’s story with the people who could be its future? Teach them about the great work done every day to keep the world in flight. (Even if we can’t recruit somebody, we sure can make them thankful for our work.) 

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 Calendar