2023 – Edition 6 – June 30

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 Briefs
ARSA on the Hill
Conference Corner
Aviation Life Calendar
Training & Career Development 
Membership
Resources
Industry Calendar

The President’s Desk

Ad(d) Value

Last summer, the board of directors approved the “big takeover” of ARSA’s periodical distribution and advertising sales. By winter, the association had ended a decade-plus-long relationship with its business-to-business vendor and was in full command of its communications for the first time since 2008.

Members have already reaped several benefits from this transition, and the ARSA team has undone years’ worth of disruption to contact lists and database entries. It is time to expand those benefits by improving advertising value.

Advertising with ARSA is about more than just selling; it demonstrates belief in quality and safety, a commitment to commonsense compliance, and intelligent business acumen. When you see a company in the pages of a periodical like the hotline or on ARSA.org, you know more than just what they sell…you see who they are.

The current goal is to expand the ways quality-oriented companies can show themselves. For example, an advertiser can sponsor a training session or underwrite discounts for publications or event registration. These options provide long-standing placement as the association’s training sessions, publications, and events are viewed for years.

To best-serve customers, we need to establish commitments to good government, and good business. Joining and advertising in ARSA represents those principles in spades.

Even if you don’t think ARSA’s ads are right for your marketing goals, you can help the association by sharing your thoughts. Go to arsa.org/contact, select “something else” on the form (or “I’m interested in advertising with ARSA” if you’re daring) and explain what drives your advertising decisions. Is it just audience? Distribution numbers? Click throughs? How about other benefits like “bonus distributions” or complimentary training or event attendance?

This feedback will help ARSA expand your values into the future.

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

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ARSA Works

Rumor Has It

It has come to ARSA’s attention that repair stations have “issues to avoid” in maintaining an EASA approval held under the U.S.-EU Maintenance Annex Guidance (MAG). Several association members have sought assistance improving their practices to meet European expectations.

FAA inspectors are highlighting the following points:

(1) Human factors training. The MAG states that “recurrent human factors training must not be a simple repetition of initial training…[but] must be built upon errors/lessons learned and the experiences within the organization.” The guidance explains such training should help results of internal audits – which are useful sources of recurrent training topics – to staff attention. Repair stations using generic recurrent training without clear demonstration of relation to audit findings will likely have an EASA finding.

Several ARSA members are already using the association’s existing Human Factors training sessions as part of their compliance with EASA requirements. After providing initial training using ARSA’s overview sessions (e.g., “Human Factors in Context”), these companies then use audit findings and internal review to determine which of the 12 “Dirty Dozen in Depth” sessions are appropriate for further annual recurring training (accessing needed sessions is made easy through training subscriptions).

Since ARSA has rolled out new live training session – which remain available as on-demand recordings – members are encouraged to help develop new human factors training for such use by responding to this month’s “quick question.”

(2) Audits. The sample audit checklist in section B of the MAG is merely a basic example. It is incomplete and insufficiently detailed for use by a repair station. Each approval holder under the bilateral must have customized both (a) procedure and (b) product audits.

As explained in response to this month’s “a member asked,” ARSA has procedure and product audit templates in the forms included with its RSQM Compilation. These documents are available as a free “tool to members” – more information can be found at arsa.org/publications.

(3) Supplement. EASA requires the supplement showing compliance with change 8 of the MAG (published in January 2021) and it must be signed by the current Accountable Manager. EASA is particularly critical of supplements that are not customized to the repair station’s work.

ARSA finds this ironic considering the fight it has had with FAA inspectors to customize the EASA supplement; some government personnel insist the supplement be a nearly verbatim replication of that provided in the MAG (which is guidance).

Essentially, repair stations are caught in the middle of battle of wills between American and European regulators. Though the bilateral relationship is supposed to simplify international compliance by allowing organizations to maintain multiple approvals through interaction only with their “home” authority, EASA is particularly engaged in pressuring through the FAA (and has even issued findings directly as a result of Sampling Inspection System [SIS] audits, which are supposed to only consider the other agency’s oversight). Stay tuned as ARSA continues to engage both American and European regulators and be attuned to the association’s resources that assist with international compliance.

ARSA Flashes at FAA-EASA Conference

ARSA Executive Vice President Christian Klein was in Cologne, Germany the week of June 12 participating in the 2023 EASA-FAA International Aviation Safety Conference. The annual meeting gathers industry and regulators to discuss how innovation and broader trends impact regulatory oversight. This year’s conference focused on sustainability, digitization, and the impact of new technologies.

Klein presented a “flash talk” on aviation workforce challenges, highlighting U.S. industry crisis communications and what the government and individual companies are doing to address technical shortages. He noted the industry’s workforce challenges threaten both business efficiency and the quality of regulatory oversight because manufacturers, operators, maintainers, and regulators all draw from the same talent pool.

Klein also participated in a panel addressing the “evolution of maintenance cooperation under the BASA.” He noted cooperation among and between authorities will become increasingly important as the global civil aviation fleet is set to increase by 33 percent over the next decade, much faster than regulator budgets will grow. Klein also encouraged more transparency and stakeholder engagement in the process of negotiating bilateral agreements and related guidance to avoid unforeseen impacts on industry and increase confidence in international collaboration.

The meeting is an excellent opportunity to network with regulators and industry professionals. The 2024 EASA-FAA conference will take place in Washington, D.C. the second week in June; ARSA will be there and encourages members to attend.

As part of the trip, Klein also participated in the June meeting of EASA’s Engineering & Maintenance Technical Committee, the agency’s primary maintenance-related stakeholder body.

For more on regulator bilateral relations, click here. For more on ARSA’s engagement with EASA, click here.

Levanto Shares ARSA’s Core Values in Miami

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On June 8, ARSA Vice President of Operations Brett Levanto spoke at the Greater Miami Aviation Association’s (GMAA) monthly luncheon at Miami Springs Country Club. Levanto’s specific charge was to cover policy issues at play in Congress’ effort to reauthorize the FAA, which he did while reinforcing key elements of ARSA’s industry leadership.

“There are central principles that guide all of the association’s work,” Levanto said. “Whether the [ARSA] team is advocating before Congress, engaging a civil aviation authority, or working through member questions, we always focus on enabling certificate holders to take advantage of the flexibilities inherent in the plain language of the rules.”

After making this point, Levanto reviewed the state of Congress following its successful negotiation with the White House to raise the debt ceiling and explained the need for U.S. lawmakers to authorize executive agencies to operate. He then reviewed the priorities advanced by ARSA on the Hill as the current authorization of the FAA heads towards its September expiration.

Considering high level goals while noting the on-the-ground needs of aviation professionals dealing with their government, Levanto also walked through FAA leadership and management challenges resulting from the absence of permanent leadership. On the same day that President Biden designated Polly Trottenberg as the next acting administrator of the FAA, GMAA members discussed how the lack of a permanent organizational leader cascades down through agency management and hinders its ability to serve certificate holders and the public.

GMAA’s mission is to improve business and career development opportunities for aviation professions in South Florida. Each year, the association awards tens of thousands of dollars in scholarships to students pursuing aerospace futures. Considering this focus, Levanto spent considerable time speaking about ARSA’s leadership on workforce development for the industry.

“We’ve got to change our thinking,” Levanto told the group, referencing an article in the previous day’s Daily Intelligence newsletter sent to ARSA primary contacts. “I see a headline proclaiming ‘non-traditional paths to recruit technicians’ and then the story is about AMT school students. That’s not ‘non-traditional’, it’s actually exactly traditional. I’m impressed by the students chronicled in the piece but would much rather focus our excitement on building every possibly pathway into and through an aviation career.”

[Learn about all of those pathways through ARSA’s effort to help the FAA “illustrate the aviation maintenance career.”]

Responding to that point about “non-traditional” recruitment, an attendee explained recently hiring a pastry chef whose cake icing skills made them excellent at applying sealant during a production process.

After taking questions, Levanto closed by returning to the point about protecting flexibility for certificate holders to show compliance. He encouraged attendees to help illustrate this core value by engaging directly with their elected officials, especially through facility visits or other community events, and focusing on long-term professional relationships with the government.

During the trip, Levanto visited the nearby headquarters of FEAM AERO. In 2022, FEAM Vice President of Safety and Quality Alison McHugh joined ARSA’s Board of Directors. The company has since become a leading member of the association, a Conference sponsor, and a proactive developer of programs to develop new aviation careers (even, as noted during the luncheon, earning an FAA workforce development grant in the agency’s most-recent round of awards.

The visit to Miami was made possible by ARSA Corporate Enterprise Member AAR Corp., which sponsored the luncheon and provided Levanto as speaker. AAR is one of the association’s longest tenured member companies, regularly investing time, expertise and resources in furthering the industry’s interests through ARSA’s leadership and its personnel are outspoken in advocating on Capitol Hill.

Contact Resources – AFS Office Guide (June 2023 Update)

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 updated its “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 June 15, click here.

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.

Click here to access a PDF copy of the list.

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Legal Briefs

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 – Back to the International Beginning

By Brett Levanto, Vice President of Operations

This layman lawyer spends time studying laws and regulations beyond the United States. ARSA’s work to clear up the FAA and EASA’s administration of their bilateral agreement and the association’s representation of the international maintenance market reflect the need for all aviation lay people to “think globally.”

Beginning in February with questioning the value of bilateral agreements, we’ve gone backwards through the process of how those deals are negotiated and reviewed the history of our European bilateral partner. Continuing the exploration this month means going all the way back to the beginning…at least in an international oversight sense. When did the global aviation community first “connect” and how does the form of that connection impact our existence today?

After the Wright Brothers’ first successful heavier-than-air flight in Kitty Hawk, things moved quickly. Eleven years later, the first scheduled airline carried passengers across Tampa Bay – 1,204 people over three months of operation – cutting 11 hours off the railway trip around the bay. Five years after that, as the world was cleaning up from its “Great War” in 1919, the Paris Convention established the International Commission for Air Navigation. Creating a now-familiar model, ICAN’s powers and duties were exercised through annexes that formed the technical regulations agreed to by the parties to the convention.

A 1935 article in The Journal of Air Law chronicled the origins of ICAN:

The Commission held its first working session on March 17, 1919, and undertook the study of the fundamental principles which were to be controlling in air navigation: state sovereignty over supervening air space… the admission of aircraft of the contracting states, equality of treatment, nationality principle, regulations adapted to safety in the conduct of international flights, special treatment for government aircraft, the principle of the right of transit, rights connected with landing, reparation for injuries inflicted, the necessity of a permanent international commission, the binding character of the Convention, and the effect of a state of war upon the Convention.

The same article considered a fundamental question of ICAN’s – or any similar international body’s – authority: How did signatory support for such an international convention compare to the rights of states to commit to each other through direct (or in some cases, multinational) treaties? Debating such requirements remains common in international aviation oversight, but ICAN had “recognized that the first step in the direction of uniformity was the abolishment, for the purposes of international flight, of as many separate sets of municipal codes covering aviation as there were, or might come to be, members signing or adhering to that treaty, and to substitute these codes, for treaty purposes, by a single code [the Convention].” (Emphasis in original. See, Clement L. Bouve, Regulation of International Air Navigation under the Paris Convention, 6 J. AIR L. & COM. 299 (1935)).

This early demonstration of practical internationalism didn’t mean the global aerospace market was anywhere near mature. At the time of the Paris Convention, not even the United States had dedicated a federal body to air commerce or safety oversight: The Air Commerce Act of 1926 assigned the Department of Commerce primary responsibility for issuing and enforcing traffic rules, licensing airmen, certifying aircraft, and performing many actions recognizable in the modern regulatory context.

It was the next great war that birthed a new international body. Translating the advances pushed by military mobilization into civilian routes demanded a renewal of global collaboration. In 1944, the U.S. government invited representatives from 55 states to attend an International Civil Aviation Conference in Chicago in 1944. Fifty-four of those countries were represented – wartime travel was harrowing, and axis powers occupied several invited lands – in developing the Convention on International Civil Aviation.

After the lengthy ratification process of the Chicago Convention, the new International Civil Aviation Organization (ICAO) met for its inaugural assembly in Montreal in May 1947. In the work done by ICAO’s representatives since, the Convention’s Annexes have swollen to include more than 12,000 standards and recommended practices (SARPs) agreed to by the 193 current member states.

Those states, including the United States and the 31 countries represented by EASA (the European agency has an official Working Arrangement with ICAO to exchange safety information and participate in collaborative initiatives), must adopt their own rules to comply with SARPs. There is no official enforcement mechanism for ICAO standards, i.e., the FAA won’t face loss of its right to oversee aviation safety for violating one, but member states may enforce penalties on persons from non-compliant countries.

Most importantly, those Annexes set the international standards for responsibility related to airworthiness. The states of design, manufacture, operator and registry bear obligations related to the development and safe operation of aircraft. In particular, the state of registry must ensure continued airworthiness regardless of where the aircraft is operated. It is this fundamental responsibility driving the need for civil aviation authorities to provide oversight of operations outside their borders; the resulting demand on resources and attention – not to mention the burden placed on certificate/approval holders needing to meet disparate standards – that makes bilateralism attractive. By allowing for a “local” authority to carry the oversight burden for work performed on international aircraft, the process should be simplified for both regulator and regulated (that theory falls short of reality, as explored in our question about the value of bilateralism).

This international history, truncated as it is for the sake of this publication, laid a century-long foundation for the challenges facing international aviation bodies. In 1919, the Paris Convention delegates recognized that global commerce and safety required commitment to oversight vested beyond the individual state’s authority. The modern politics of regulatory interaction have made it difficult to create value from that realization. Making good on the possibility, or having the courage to turn away from it, depends on understanding how this past produced our present and what it means for the future.

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.

78 Years and Counting

By Christian A. Klein, Executive Vice President 

This month’s “Layman Lawyer” overviews the antecedents and creation of the International Civil Aviation Organization (ICAO). This “legal Brief” picks up the story by examining the Convention on International Civil Aviation adopted in Chicago on Dec. 7, 1944 (hence, “the Chicago Convention”). The action established ICAO and set the path for regulatory harmonization and mutual recognition.

While the Chicago Convention’s text is widely available, the original version is most interesting. The signatures create a personal connection to the visionaries negotiating the treaty almost 80 years ago.

With the Chicago Convention being signed just six months after D-Day it is no surprise the preamble states that, “the future development of international civil aviation can greatly help to create and preserve friendship and understanding among the nations and peoples of the world, yet its abuse can become a threat to general security.”

The Chicago Convention’s stated purpose is to “avoid friction and to promote that cooperation between nations and peoples upon which the peace of the world depends.” It established “principles and arrangements in order that international civil aviation may be developed in a safe and orderly manner and that international air transport services may be established on the basis of equality of opportunity and operated soundly and economically.”

The 96 articles following the preamble (divided into parts and chapters), created the time-tested legal framework for today’s common air navigation and safety rules. The following are just some of the enshrined principles of Part I (“Air Navigation”):

• The convention applies only to civil (i.e., not state) aircraft.
• States have “complete and exclusive” sovereignty over their air space.
• Aircraft have the nationality of the state in which they are registered, must bear a nationality and registration mark, and cannot be validly registered in two states simultaneously.
• Each contracting state agrees to adopt rules of the air applicable “without distinction to nationality” to aircraft operating in that state’s airspace and applicable to aircraft registered in that state when operating outside its territory.
• To the extent practicable, states will establish facilities to enable international air navigation (e.g., airports, radio services) and adopt common practices and rules.
• States must provide a certificate of airworthiness for aircraft engaged in international navigation.
• Pilots and other crew members operating in international navigation must be provided with certificates of competency or licenses issued or validated by the aircraft’s state of registry.
• Aircraft of a contracting state engaged in international navigation must carry the following documents:
  • Certificate of registration.
  • Certificate of airworthiness.
  • The appropriate license for each crew member.
  • A journey log book.
  • If equipped with a radio, the aircraft radio license.
  • If carrying passengers, a passenger manifest showing names, places of embarkation, and destination.
  • If carrying cargo, a manifest and detailed declarations of the cargo.

Harmonization and mutual recognition are core principles. The treaty directs that certificates of airworthiness and flight crew licenses from one contracting state must be recognized as valid by others if the standards on which those certificates are based are equal to or above the minimum standards established by ICAO. Further, each contracting state agrees to collaborate to secure:

the highest practicable degree of uniformity in regulations, standards, procedures, and organization in relation to aircraft, personnel, airways and auxiliary services in all matters in which such uniformity will facilitate and improve air navigation.

ICAO is directed to adopt and amend as necessary “international standards and recommended practices and procedures” addressing:

• Communications systems and air navigation aids, including ground marking.
• Characteristics of airports and landing areas.
• Rules of the air and air traffic control practices.
• Licensing of operating and mechanical personnel.
• Airworthiness of aircraft.
• Registration and identification of aircraft.
• Collection and exchange of meteorological information.
• Log books.
• Aeronautical maps and charts.
• Customs and immigration procedures.
• Aircraft in distress and investigation of accidents.
• Other such matters concerned with the safety, regularity, and efficiency of air navigation as may from time to time appear appropriate.

The drafters were realists and recognized member states will not always agree. It therefore requires a state that finds it “impracticable to comply in all respects” with ICAO standards or procedures or bring its own regulations into full accord, to notify ICAO of the differences between the ICAO standards and its own. ICAO must then notify all other members states of those differences.

The Chicago Convention’s diplomats recognized the need for common standards to govern a growing, but still maturing, global aviation industry. Seventy-eight years later, only two countries are not ICAO members (the Holy See (aka, the Vatican) and Liechtenstein). Progress has been made toward the vision of mutual recognition and harmonization. However, aviation regulators, policy makers, and industry professionals need to read (and reread) the treaty’s basic principles to achieve its worthy objectives more rapidly.

Next month’s Legal Brief will review Part II of the Chicago Convention, which established ICAO and defines how the organization operates.

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ARSA on the Hill

FAA Reauthorization Advances

By Christian A. Klein, Executive Vice President 

June was busy for aviation on Capitol Hill. The House Transportation & Infrastructure (T&I) Committee released and unanimously passed its bipartisan FAA reauthorization bill that was received enthusiastically by much of the aerospace community.

The “Securing Growth and Robust Leadership in American Aviation Act” establishes a five-year budget blueprint for the FAA while addressing agency management and staffing challenges, inconsistent oversight and enforcement, and industry workforce development. It includes many of the association’s regulatory and workforce recommendations:

• 516 requires the FAA administrator to task the Aviation Rulemaking Advisory Committee (ARAC) to identify ways to improve access to instructions for continued airworthiness (ICA). This provision marks the first time in two decades Congress has addressed the association’s backbone issue.
• 252 directs the U.S. Department of Transportation’s Inspector General to audit the Flight Standards and Certification Services regarding the consistency and application of guidance and regulations, a persistent industry concern.
• 253 directs the FAA administrator to ensure consistency in oversight through audits, more frequent updates to guidance and rules, and better documentation of findings and decisions.
• 122 creates the new position of FAA assistant administrator for rulemaking and regulatory improvement, who is charged with, among other things, improving transparency and responsiveness relating to the agency’s handling of petitions for rulemaking and exemptions.
• 517 requires the agency to issue or update guidance to clarify the conditions under which a major alteration requires a supplemental type certificate. This idea was first proposed by an ARSA member and adopted by the association in its own recommendations.
• 208 requires FAA investigations to be completed within two years of issuance of a letter of investigation (LOI). This is to address the problem of FAA investigations that are never closed and continue to hang over the heads of certificate holders.
• 502 encourages the agency to pursue cooperation more aggressively with other civil aviation authorities.
• 301 reauthorizes, triples funding for, and improves the aviation workforce grant programs created by ARSA’s toil in 2018 (and creates a similar new grant program for the aviation manufacturing workforce).
• 303 creates a new National Center for the Advancement of Aerospace to coordinate workforce development activities among industry, academia, and other stakeholders.
• 311 establishes an interagency working group to improve transition from military to aviation technician careers.
• 312 establishes a working group to examine airman knowledge testing to create new opportunities for high school graduates in the maintenance industry.

While ARSA is pleased the T&I Committee adopted so many of the association’s recommendations, Sec. 505 incorporates language that passed the House in a standalone bill last fall targeting foreign repair stations. The legislation is less disruptive than last spring. However, with the maintenance industry’s outstanding safety record and the scrutiny foreign repair stations already receive from their own and other CAAs, including the FAA, airline customers, and third-party auditors, ARSA knows the foreign repair station language is a solution in search of a problem.

Given the bill’s strong, bipartisan support, it will likely get taken up by the full House in July and is expected to pass by a wide margin.

The leaders of the Senate Commerce, Science, and Transportation (“Commerce”) Committee also released a bipartisan FAA bill. With the political situation in the Senate the bill failed to advance out of committee due to disagreement over key provisions relating to pilot training. Without bipartisan consensus, it’s unclear when the committee will mark up the bill as the clock continues to tick down to the expiration of FAA’s authorization on Sept. 30.

As to what’s in the Senate bill, many of the provisions mirror the House legislation.

Sec. 333, like Sec. 516 in the House, directs the Administrator to assign an ICA task to FAA’s ARAC. The fact that ICA language is in both bills is significant as it is more likely the provision will be enacted.

Sec. 501 would double funding for the Sec. 625 workforce grant programs and create a new program for aviation manufacturing.

Sec. 503 directs the Comptroller General (i.e., the Government Accountability Office) to study ways to improve the pipeline of high school students into the maintenance industry.

Sec. 504 directs the FAA to create a military mechanic written competency test and pursue other opportunities to make it easier for technicians in the armed services to transition to civilian maintenance industry careers.

ARSA will keep up the pressure on both chambers of Congress to pass and enact an FAA reauthorization bill that addresses the oversight and workforce challenges ARSA members are encountering.

Support positive policy by hosting a member of Congress at your facility this summer. It will  educate them on the industry and the citizen’s reauthorization priorities. ARSA makes hosting a visit easy. Send us a note to get the process started.

The Summer Calendar

Last month, ARSA President Josh Krotec reminded members the summer is time for engaging with lawmakers their home states and districts, it’s important to know how to find your member of Congress. While specifics can be gathered from official websites or by calling the district or state office (using arsa.org/congress, thanks to generous support from ARSA member Aircraft Electric Motors), businesses can plan longer term by looking at the House and Senate calendars.

These plans show when each chamber expects to be in session. While emergencies may require additional time in the capital, Americans can focus on planned recess periods for opportunities to meet their lawmaker (or host them for a facility visit). According to the calendars, these are the weeks designated for homework for the remainder of 2023:

Note: The dates below capture workdays and do not include weeks where only one or two days has been identified for district/state work. For specifics, refer to the House and Senate calendars.

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Conference Corner

Opening Your Budget

The Annual Conference is a place for members to connect and get work done. While next year’s event is still nine months away, companies should budget now to ensure they will be able to generate the value of Conference engagement (both through attendance and sponsorship). You should schedule to attend the entire week, but definitely make sure to attend the centerpiece discussion of regulators from around the world during the “Opening Salvo” on Thursday. Representatives from the FAA, EASA, TCCA, ANAC Brazil, and CAAC (China) are regulars to the stage; get an example of (or relive) last year’s presentation from the FAA:

Thursday, March 16, 2023 | 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.

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

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]

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

Ludovic Aron, Washington Representative, EASA

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

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

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

See you at next year’s Conference: March 12-15, 2024

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Aviation Life Calendar

July Through October

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 & Career Development

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.

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 OFMK’s online training portal, visit potomaclaw.inreachce.com. To learn more about the association’s training program and see course availability, visit arsa.org/training.

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

Part 43 “In Depth” Training Series Begins on July 12 & 13

ARSA Vice President of Operations Brett Levanto (with support from Executive Director Sarah MacLeod) will build on ARSA’s existing training covering 14 CFR part 43, starting an “in depth” series exploring specific elements of the maintenance rule. The first two 15 minute sessions in the series will be hosted online on July 12 and 13.

Click here to see bundled pricing options for the currently available sessions covering part 43 (tiered savings up to 50% off the total registration cost for all sessions).

Part 43 In Depth: Applicability (15 Minutes)

July 12, 2023 @ 11:00 a.m. EDT

This session focuses on the applicability of 14 CFR part 43, Maintenance, Preventive Maintenance, Rebuilding and Alteration. It reviews each paragraph of § 43.1 and highlights the related regulations and definitions impacting its meaning.

Click here for more information and to register.

Part 43 In Depth: Performance Rules (15 Minutes)

July 13, 2023 @ 11:00 a.m.

This session focuses on the performance rules of 14 CFR part 43, Maintenance, Preventive Maintenance, Rebuilding and Alteration. It reviews each paragraph of § 43.13 and describes the reading process maintenance providers should follow when meeting the minimum standards of the rule.

Click here for more information and to register.

Part 43 In Depth: Non-applicability (§ 43.1(b)) (15 Minutes)

August 15, 2023 @ 11:00 a.m.

This session focuses on the applicability of 14 CFR part 43, Maintenance, Preventive Maintenance, Rebuilding and Alteration. It highlights the points of “non-applicability” explained in § 43.1(b).

Click here for more information and to register.

Part 43 In Depth: Life Limited Parts (§§ 43.1(c) & 43.10)

August 16, 2023 @ 11:00 a.m.

This session focuses on the applicability of 14 CFR part 43, Maintenance, Preventive Maintenance, Rebuilding and Alteration. It highlights the responsibilities related to life limited parts created by § 43.1(c).

Click here for more information and to register.

ARSA will continue its series exploring elements related to part 43, including both 15 minute and hour-long sessions and varying levels of instruction. Stay tuned for additional sessions.

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.

On Demand – Part 43 for Repair Stations

On June 14, ARSA Vice President of Operations Brett Levanto lead an online training session covering 14 CFR part 43 that highlights the interplay between the maintenance rule and the standards for repair stations in part 145. The on-demand recording made during that live session is now available.

Description: This session provides an overview of 14 CFR part 43, Maintenance, Preventive Maintenance, Rebuilding and Alteration, from the perspective of a repair station certificated under part 145. It places the work performed on U.S. civil aircraft in the context of the “aviation safety regulatory chain” [the lifecycle of airworthiness], explains general definitions and requirements, and the standards that impact these activities.

Objectives: Upon completion of this session, participants will have the tools to understand:

• The scope and breadth of part 43.
• The authorities it grants to and requirements it places on air agency certificate holders.
• The quality standard applicable to all work performed on civil aviation aircraft.
• The connection between the requirements of part 43 and compliance with part 145.

Click here for more information and to register.

Note: Individuals who registered for the live session will have access to the recording 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.

Part 91 Series – Comp. or Hire, then Subpart Walkthrough

Part 91 – Compensation or Hire

This session explores the details of the general operating rules in 14 CFR part 91 impacting operations performed for compensation or hire. It highlights the elements of the rule governing such operations and identifies relevant other areas in 14 CFR.

Click here for more information and to register.

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 § 21.1, Applicability & Definitions related to Certification Procedures for Products and Articles.

Click here to download the training sheet.

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Membership

SMS for ARSA Members

ARSA’s newest member benefit is available: Access to the Safety Management System (SMS) program managed by the Aircraft Electronics Association (AEA).

The two associations are longtime allies. From jointly commenting on rulemaking actions to co-chairing an FAA working group reconciling U.S. repair station regulations with associated guidance to sharing Conference presentations, ARSA and AEA collaborate closely to serve maintenance interests. That collaboration was bolstered through an agreement signed just before ARSA’s 2023 Annual Conference, during which AEA Vice President of Government & Industry Affairs Ric Peri led a breakout session on SMS programs.

Under that agreement, ARSA members in good standing may access the AEA-managed SMS program for an annual flat fee of $350. The program helps small-to-medium sized aviation maintenance organizations meet the international and business requirements for adopting an SMS. AEA provides online administrative tools through its password-protected website to support the company designated safety representative, or on-site SMS coordinator. The administrative tool and program are constructed around the principles created by the International Civil Aviation Organization (ICAO) for adoption by the civil aviation authorities.

Since signing the agreement, ARSA and AEA have worked out procedures to support cross-member access (including certain training benefits and other privileged access for association staff and team members). To obtain access to the AEA-managed SMS Program under ARSA’s partnership complete the request form at arsa.org/sms-program. The page includes other information about the AEA-managed SMS program and how to obtain more details.

Advertising Beyond the Ordinary

Marketing to and by repair stations can find no better connection to core values in aviation than ARSA advertising. With the association in full control of its communications, options available to advertisers stretch beyond placement in periodicals or on the website.

Sponsorships

Sponsorships for the association’s Annual Conference and online training programs are available and create long-standing presence.

How it Works

Sponsoring a training or Annual Conference session provides immediate access to the learning experience for the sponsor, and its advertisement will be presented during both the live and on-demand versions of the session. The “seats” available to the advertiser can be utilized for its personnel or can be offered as a benefit to others as “scholarships to support industry knowledge.”

ARSA’s training program and Annual Conference sessions are not a home-shopping channel for regulatory compliance, it’s a way to demonstrate commitment to quality in aviation safety. Training sponsors bring value to the aviation maintenance industry and their name is attached to the final product for the duration of its time in the association’s catalogue. ARSA will produce the training, and Conference material, and retain rights to content.

Ready to see your company in ARSA’s communications and training? Visit arsa.org/news-media/advertising and arsa.org/training-resources for more information.

Not interested in advertising? Don’t forget to send your news releases and other media information to arsa@arsa.org.

Quick Question – Human Factors Findings

Approved maintenance organizations that have an EASA, TCCA, or ANAC approval must include human factors topics in their training programs. In November 2019, change 7 of the FAA-EASA Maintenance Annex Guidance (MAG) clarified that recurrent training must be based on lessons learned from discrepancies and corrective actions:

NOTE: The recurrent human factors training must not be a simple repetition of the initial training. Instead, it must be built upon errors/lessons learned and the experiences within the organization (or group of organizations). This should help ensure that the results of internal quality audits and occurrence reports are brought to the attention of all staff. (See Section B, Appendix 1)

While some members have already integrated ARSA’s existing human factors training sessions into their compliance with the requirement, the association can expand its offerings as part of its new rollout of live training (which remain in the training catalogue as on-demand recordings). To help select topics for those classes, respond to this month’s “quick question.”

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 to submit your response.

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

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 June:

New Members
Air Spray U.S.A, Inc. dba AirSpray Airtankers, R03
Lone Star Aviators dba LSA Aviation Services, LLC, R02
Nico Leppe, EDU

Renewed Members
Aviation Communication & Surveillance Systems, LLC, R02, 2002
Eastern Airlines Technic Co., Ltd., R04, 2017
Florida Jet Center, Inc., R02, 2013
Lynden Air Cargo, LLC, Assoc, 2000
Marvel-Schebler Aircraft Carburetors, LLC, R02, 2011
Metro Aviation, Inc., Assoc, 2003
MT Texas, LLC, R03, 1990
MTU Maintenance Hannover GmbH, R06, 2007
NAASCO Northeast Corporation, R02, 2002
National Flight Services, Inc., R04, 1991
Pacific Aerospace, LLC, R01, 2005
Performance Repair Group, LLC, R02, 2013
SAI Flight Support Company, R01, 2016
S & T Aircraft Accessories, Inc., R02, 2003
Turbine Weld Industries, LLC, R03, 2020
Twin Manufacturing Co., dba TWIN MRO, R04, 1993
Unicorp Systems, Inc., R03, 2003

A Member Asked…Audits for EASA?

Q: Our new PMI wants us to delete the EASA Supplement matrix and replace it with a Product Audit Checklist. I offered a generic checklist that I pulled off another website, but he wants significantly more detail. For example, he wants us to verify the authority of the person signing a work order (our small shop only has 3 people authorized to sign) and verify capability before opening a work order (we have class ratings).

Does ARSA have a template for such a checklist that we could wave at him? How often should the checklist be completed?

Did EASA change their guidance to completely eliminate the matrix that’s been their standard for several years? Our inspector literally warned us that if the checklist in the EASA supplement guidance is used, the company would end up with a “significant finding.”

Thanks for your help, as always.

A: Let’s deal with the easiest questions first—the EASA is finding inadequacies in the use of the “suggested” supplement and “checklists.” The expectation is that the “samples” are to be customized to the U.S. repair station’s operations. The use of the “sample” audits and supplement without tailoring them to the repair station’s procedures is resulting in negative feedback from EASA auditors. So, the MAG supplements and guidance are not “eliminated,” but being scrutinized during the audits.

EASA has always made a distinction between a “procedures or process” audit (Do your procedures follow the regulations and other legal requirements?) and a “product” audit (Do you follow the procedures when performing work?).

It can be hard to understand the difference, because the two are so closely related. Basically, after assuring the procedures comply with the regulatory standards (part 145 and 43 and the Special Conditions) a “product” is walked through the system while holding the procedure in one hand to ensure it is followable and is being followed.

ARSA has templates that can be customized for both product and procedure/process audits. The templates are included in the association’s RSQM Compilation and available in the free “Tool for ARSA Members” (click here for to learn how to request publications).

More broadly, there has been a rash of recent reports about issues resulting from EASA audits of the FAA’s oversight of U.S. repair stations or because of EASA-FAA tension and pressure.

To help ensure members can meet EASA expectations, please complete this month’s “quick question,” which is collecting information regarding audit results that can drive future Human Factors training.

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/advertising.

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.

Industry Calendar

the hotline is the monthly publication of the Aeronautical Repair Station Association (ARSA), the not-for-profit international trade association for certificated repair stations. It is for the exclusive use of ARSA members and federal employees on the ARSA mailing list. For a membership application, please call 703.739.9543 or visit arsa.org/membership/join. For information about previous editions, submit a request through arsa.org/contact. This material is provided for educational and informational purposes only. It does not constitute legal, consulting, tax or any other type of professional advice. Law, regulations, guidance and government policies change frequently. While ARSA updates this material, we do not guarantee its accuracy. In addition, the application of this material to a particular situation is always dependent on the facts and circumstances involved. The use of this material is therefore at your own risk. All content in the hotline, except where indicated otherwise, is the property of ARSA. This content may not be reproduced, distributed or displayed, nor may derivatives or presentations be created from it in whole or in part, in any manner without the prior written consent of ARSA. ARSA grants its members a non-exclusive license to reproduce the content of the hotline. Employees of member organizations are the only parties authorized to receive a duplicate of the hotline. ARSA reserves all remaining rights and will use any means necessary to protect its intellectual property.

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