2024 – Edition 2 – March 1

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 2024 Annual Conference Preview
The President’s Desk
ARSA Works
Legal Brief
ARSA on the Hill
Aviation Life Calendar
Training & Career Development 
Membership
Resources
Industry Calendar

The 2024 Annual Conference Preview

March 12-15, 2024

Sponsors | Registration | Information

Arlington, Virginia and Washington, D.C. with Livestream Options for Conference Ambassadors

What began decades ago as ARSA’s Annual Repair Symposium has evolved into a week-long event including executive branch briefings, grassroots legislative advocacy and world-class regulatory compliance and business content. The event provides a regular venue for members and invited guests from around the world to network and discuss issues that matter to the repair station community.

The Sponsors
The Event
The Technology

Get Ready

If you’ve never been to an ARSA Conference (or it’s been a while), the time is now to see what you’ve been missing.

ARSA will make use of its well-honed tools for providing an engaging Conference; participants should prepare to make the most of the aviation maintenance industry’s premier substantive event.

Review this special section of the hotline and make sure you’re registered to participate.

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The Sponsors

The Strength of Platinum

Sponsors | Registration | Information

The list of Platinum Level sponsors for ARSA’s Annual Conference has become a “who’s who” of aviation maintenance industry leadership. ARSA thanks each of these eight companies for the strength of spirit they continue to demonstrate on behalf of the aviation world:

From periodical advertising to board leadership, Corporate Enterprise Member Chromalloy knows the impact of ARSA’s message. This year, the company will help spread that message by providing for the Conference Livestream.

HEICO regularly puts itself (and its people) out front on ARSA’s behalf. From documentary starring roles to government affairs leadership, the Corporate Enterprise member continues that leadership this year by making the advocacy of Legislative Day possible.

Lufhansa Technik celebrates its return to ARSA’s Board of Directors by providing hearty German welcome to Conference participants through this year’s IceBreaker reception on Wednesday, March 13.

Hearts of Gold

Sponsors | Registration | Information

Thank you to the six Gold Level Sponsors of the 2024 Annual Conference.

Click here to register and see the benefits of their investment.

AAR Corp 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.

AeroKool Aviation has served every corner of the aviation market since 1959 and been represented on ARSA’s board since 2022. The company continues its climb through the ranks of Conference sponsors.

First Aviation Services helps ARSA to lead from the front through its proactive legislative and regulatory engagement in support of key industry initiatives. That leadership is always on display at the Annual Conference.

NORDAM is a family-owned global aerospace firm and another one of ARSA’s original members. The company has long been represented on the association’s board of directors and is a mainstay at its events.

ST Engineering boasts facilities across the world and typifies in the international character of ARSA’s membership. The company joins the Conference sponsor list this year; be sure to thank them for Thursday’s lunch.

Turbine Controls has locations in Connecticut and Florida and has long had its logo on ARSA’s sponsor list (notably holding up each attendee’s name tag). For 2024, TCI increased its investment in the event and in the association’s good work.

Sponsoring Conference Success

Thank you to the 22 organizations that have committed (so far) to sponsor ARSA’s 2024 Annual Conference. There’s still time to join them…check the event page to see how.

Platinum

Gold

Silver

Contributors

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The Event

Attendance Experience

The Agenda

Sponsors | Registration | Information

If any in-person registrant wishes to opt out of in-person participation for any reason, they may switch to livestream access at any time. Access is available to all participants via the Digital Companion, a password-protected webpage for  accessing the agenda, speaker information and presentation resources.

The “Digital Companion”

Sponsors | Registration | Information

Since 2019, all participant materials and references related to the Annual Conference have been made available on a special page on ARSA.org.

How do participants access the Digital Companion?

A registrant prep email sent in advance of the Conference includes the web address and password to the Digital Companion. The address may be used in any web browser; when the page loads it will ask for the password and then allow access to the page, which is viewable on either desktop or mobile device.

What information is available on the Digital Companion?

(1) The event agenda, including session information, time and location for all events.

(2) Speaker names with links to online bios (where available).

(3) Presentation resources and materials (uploaded after sessions are complete).

(4) General information and resources (ARSA action resources, team member contacts, etc.)

(5) Access to the Conference livestream (For registrants and Conference Ambassadors).

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The Technology

ARSA’s Partners and Platforms

ARSA has tapped into its broad network of online content providers – contacts developed from years of providing online training and participating in remotely-produced event content – to provide the 2022 Annual Conference. These tools allow the association to mesh a return to in-person participation with ongoing opportunity for viewing from a distance.

ARSA.org – Participant Resources & Access

Conference participants will be able to access all event-related information via specially-designed pages on the ARSA website. Both the “Digital Companion” (which will contain agenda and sponsor information as well as event materials) and the embedded livestream will be available on ARSA.org. What could make these resources better? Tell ARSA.

Microsoft Teams – Speaker Coordination

Presenters and panelists will interact and engage their material using Microsoft Teams, which has become the association’s go-to online meeting platform. 

Vimeo – Live Stream

The discussions captured by Teams  will be live streamed for event participants via a Vimeo player embedded on an ARSA.org webpage. Once online attendees and Conference Ambassadors have accessed the page, they can save the location on their favorite browser for repeated access. Every portion of the event will play on the same stream.

Hothouse Media – Onsite Production

The filming team that captured great moments and interviews at the 2019 and 2020 Annual Conferences and made the 2021 online event a great success has returned. On site with the ARSA team at the Ritz-Carlton, Pentagon City, Hothouse’s professionals will oversee all production on site to ensure the best audio, video and entertainment possible for livestream participants and provide recorded versions of sessions for access after the event.

See how all of these pieces fit together during the Conference from March 12-15. 

Participant Support

ARSA’s team worked hard to prevent issues before they occur. Still, things happen.

If any attendee needs assistance during the event, they should refer to the ARSA team contact information in the Digital Companion. If you cannot or do not know how to access that resource, use the general contact information on the team member directory or arsa.org/contact. Team members may not be immediately attentive to all communications, but will be monitoring and prioritizing Conference-related communications.

The After Party

Session recordings will be made available to registrants after the event is over (please allow time for production). Also, ARSA’s team will work with its technology partners to create special content based on activities during the Conference, so stay tuned to future web updates and periodicals.

The President’s Desk

The Difference is Substance

The aviation event calendar is packed. From major conventions to government meetings, the pandemic interruption is just a memory: Aviation professionals will spend days and weeks traveling to support business through face to face interactions.

On one hand, I’m grateful for those that include ARSA’s Annual Conference in the calendar. With all the options and every demand at the shop or office, it’s a demonstration of a commitment to the association and business success.

On the other hand, thriving in the aviation industry without attending the Conference is  problematic. The ARSA conference is “the aviation maintenance industry’s premier substantive event.” While there can be great sales value or network building in any industry gathering – and some great sightseeing – there is no better place in the aviation world to access the information required to survive under the business and regulatory realities that each of us faces every day.

Substance is the difference. There are bigger events, but there is none more heavily invested in the knowledge and competency for compliance on which aviation safety and our businesses depend. As final preparations for the Conference are conducted, I encourage all members to take advantage of ARSA’s knowledge (and your own) by:

(1) Preparing for the Conference. If you’re going to the nation’s capital, make sure you know the schedule and are prepared to actively participate (in particular, Legislative Day attendees should ensure they’ve scheduled meetings on Capitol Hill).

(2) Expanding access. Registrants should name a “Conference Ambassador” to receive livestream access to the event at your facility. Have the Ambassador set up the stream in a Conference room – put out some coffee and perhaps a pastry – and encourage your people to view sessions of interest.

(3) Planning for next year. Those who will be with us are sure to come back. If you’re not registered for 2024 (there’s still time!), but if you can’t come this year go to your calendar right now and block March 18-21, 2025.

(4) Accessing all ARSA substance. Everything the association does is rooted in the same regulatory compliance experience that is showcased at the Conference. Members should particularly make good use of the association’s training program and the “Ask ARSA first!” portal, both of which turn the team’s expertise into your value.

The association makes its tools available all year, but you can hone your implements especially well by spending four days in March with us. See you there.

Gary Fortner 2024 ARSA president | Fortner Engineering & Manufacturing, Inc. vice president of engineering

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ARSA Works

Template for Requesting CAAC Special Approval

In December, the Civil Aviation Administration of China (CAAC) issued a notice to U.S. repair stations that it would no longer consider Special Approval applications for certificate extension. Pending new on-site audits for repair station approvals in 2024, repair stations were provided two avenues to continue work for Chinese customers:

(1) File a request before the end of December 2023 to continue work already under contract. ARSA has heard from multiple members that followed the procedures provided by the CAAC to file this request that certification extensions were provided for the related work; these extensions are valid through 2024 or until full certification is restored after audits are complete.

(2) Have Chinese operators apply for special approval for use of the repair station as an “unlicensed repair unit,” which would allow for work to be performed on items not already covered under a special exemption, i.e., for new work under contract. ARSA has produced a template letter for use by members – to complete and route through the appropriate maintenance-related office of a Chinese operator for submission to the CAAC – and delivered it to regulators for review.

The template letter includes instructions for use and is formatted as a letter for inclusion under the Forms Manual of ARSA’s RSQM Compilation. As explained in the instructions, it’s purpose is to provide the format and information necessary for a Chinese operator with approval under CCAR-121 or CCAR-135 to request Special Approval from CAAC to use the repair station as an unlicensed repair unit (i.e., non-certificated contract maintenance provider under the Chinese regulations) following the temporary expiration of the repair station’s CAAC maintenance organization certificate (MOC) pending renewal. This letter must be approved and submitted to the CAAC by the operator, signed by its maintenance management, e.g., Maintenance Department Vice President (CCAR-121) or Supervisor (CCAR-135). The repair station may prepare it for delivery to assist its customers in requesting Special Approval allowing continuation of work.

Interested members may download the template letter, which is now included in the association’s “tools for members,” by completing the form below. ARSA will provide updates based on feedback or policy guidance from the CAAC. Repair stations with questions or comments based on CAAC certification should contact the association.

After submission of the form, a download of the .docx file will initiate.

FAA Proposes Removing Repair Station “Current” Data Requirement

On Jan. 31, the Federal Register published a notice of proposed rulemaking from the FAA that would amend § 145.109(d) to remove the requirement for repair stations to keep an extensive list of documents “current and accessible” even when those methods, techniques, and practices were not used.

The NPRM would remove the struck-through language below from the paragraph:

§ 145.109 Equipment, materials, and data requirements.

* * *

(d) A certificated repair station must maintain, in a format acceptable to the FAA, the documents and data required for the performance of maintenance, preventive maintenance, or alterations under its repair station certificate and operations specifications in accordance with part 43. The following documents and data must be current and accessible when the relevant work is being done:

(1) Airworthiness directives,

(2) Instructions for continued airworthiness,

(3) Maintenance manuals,

(4) Overhaul manuals,

(5) Standard practice manuals,

(6) Service bulletins, and

(7) Other applicable data acceptable to or approved by the FAA.

A 2019 ARSA petition for rulemaking requested the FAA perform the exact same action. In that petition, the association noted that the requirement to maintain “current” maintenance data was unique to repair stations (an unnecessary cost burden on many small to medium sized businesses), inconsistent with the performance rules of § 43.13, and incompatible with multiple sections in part 145 subpart E.

The NPRM specifically requests feedback from the public to “address any concerns” associated with the proposal. ARSA will reinforce the points made in its 2019 petition, most of which are already included in the NRPM. The regulations for all maintenance activities are the same, even for air carriers and their maintenance providers that must meet the “highest standards of safety” in performing work; none needs the “current” versions of data when other methods, techniques, or practices must also return the article to at least its original or properly altered condition.

Contract Maintenance Approval Clarification

The NPRM, which includes numerous updates related to various maintenance and inspection program requirements in parts 91, 125, 135, and 137 in addition to 145, also proposes to amend §§ 145.201 and 145. 217 to clarify when a repair station must obtain FAA approval to contract work.

If the proposed amendments are made, the affected parts of each section would be (links go to the current version of the CFR; normal text is original and will remain, struck-through text will be removed, bolded text is new to be added):

§ 145.201 Privileges and limitations of certificate.

(a) A certificated repair station may—

* * *

(2) Arrange for another person to perform the maintenance, preventive maintenance, or alterations of any article for which the certificated repair station is rated. If that person is not certificated under part 145, the certificated repair station must ensure that the noncertificated person follows a quality control system equivalent to the system followed by the certificated repair station. The certificated repair station may approve an article for return to service following the maintenance, preventive maintenance, or alterations performed on the article by the other person if—

(i) The certificated repair station is rated to perform maintenance, preventive maintenance, or alterations on the article; and

(ii) The requirements for contract maintenance in § 145.217 have been met.

§ 145.217 Contract maintenance.

(a) A certificated repair station may contract a maintenance function pertaining to an article to an outside source provided may approve an article for return to service following the maintenance, preventive maintenance, or alterations performed on an article by an outside source under contract or other arrangement, in accordance with § 145.201(a)(2), provided all the following conditions are met:

(1) The FAA approves the maintenance function to be contracted to the outside source; and.

(2) The repair station maintains and makes available to its responsible Flight Standards office, in a format acceptable to the FAA, the following information:

(i) The maintenance functions contracted to each outside facility; and

(ii) The name of each outside facility to whom the repair station contracts maintenance functions and the type of certificate and ratings, if any, held by each facility.

(3) The certificated repair station verifies, by test and/or inspection, that the work has been performed satisfactorily by the other person and that the article is airworthy before approving it for return to service.

(b) A certificated repair station may contract a maintenance function pertaining to an article to a noncertificated person provided—

(1) The noncertificated person follows a quality control system equivalent to the system followed by the certificated repair station; and

(2) The certificated repair station remains directly in charge of the work performed by the noncertificated person.

(3) The certificated repair station verifies, by test and/or inspection, that the work has been performed satisfactorily by the noncertificated person and that the article is airworthy before approving it for return to service.

(c) A certificated repair station may not provide only approval for return to service of a complete type-certificated product following contract maintenance, preventive maintenance, or alterations.

According to the rulemaking preamble, the edits to §§ 145.201 and 145.217 are to address confusion in the existing rule. The FAA reports that repair stations have misunderstood whether approval was needed to contract work to another 145 certificate holder when the contractor will issue the approval for return to service related to the contracted work.

“We believe the confusion surrounding the approval requirement is part of a broader misunderstanding of contract maintenance regulations,” the preamble said. “Section 145.217 applies when a certificated repair station contracts a maintenance function to an outside source with the intent of then assuming regulatory responsibility for the maintenance work performed by the outside source, regardless of whether that outside source is certificated under part 145.”

Stay tuned for updates as ARSA continues to review the proposal and prepare its response. Send questions or analysis to the association via the “Ask ARSA” portal.

To view the NPRM, 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 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 – Standing Up via Rulemaking Comments

By Brett Levanto, Vice President of Operations

The government continuously provides important opportunities for the industry to flex its muscle through comments on rulemaking activities. ARSA is currently working – and coordinating with industry partners – on three FAA proposals:

(1) Drug and Alcohol Testing of Certificated Repair Station Employees Located Outside of the United States

(2) Inspection Programs for Single-Engine Turbine-Powered Airplanes and Unmanned Aircraft; and Miscellaneous Maintenance-Related Updates

(3) Falsification, Reproduction, Alteration, Omission, or Incorrect Statements

Just because the association leads on these issues, doesn’t mean members shouldn’t engage in the rulemaking process. It’s an important way to shape regulations and create the record necessary to challenging any final rule. In the April 2022 edition of the hotline, the “Legal Brief” (the real lawyer’s input on the subject) covered the Supreme Court’s interpretation of the Administrative Procedure Act (APA).

With the 2022 editorial as background (a very dry one), we can focus on the mechanics of submitting comments:

Content

ARSA provides general guidance for submitting supporting comments, which entails providing substantive support for the association’s position. Similarly, businesses should provide information on the specific costs, complications, impacts, or other real-world results of the proposed action. This type of imformation demonstrates your “standing” by making clear how the proposal would impact you (or your company, its employees, etc.) directly or indirectly.

Process

Rulemaking dockets explain how comments may be submitted, providing options for snail mail and electronic submission. If you choose to use the web-based process, it is best to create your comments as a stand-alone document on company letterhead. After submitting comments electronically through regulations.gov, send a courtesy copy via email – with read receipts requested – to the agency contact provided in the document.

Timing

While it is important to submit comments prior to the deadline specified in the docket, late comments can and will be considered if received before the rulemaking team has compiled its “Final Decision Document.” The timeline for production of this document varies, so do not delay in compiling and submitting your comments…but don’t give up if you’re behind schedule.

Follow Through

Ensure you are tracking the rulemaking docket to catch the publication of further rulemaking activities. Notices of proposed rulemaking may be supplemented with further proposals, withdrawn, or become a final rule – all of which deserve additional attention. Also, use the “Ask ARSA First!” portal to ensure the association’s team is aware of your comment and its substance.

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ARSA on the Hill

One Step Forward

By Christian A. Klein, Executive Vice President

ARSA on the Hill: One Step Forward

After months of inactivity, the Senate Commerce, Science and Transportation Committee passed an FAA reauthorization bill on Feb. 8.

The House approved its version of the multi-year FAA budget and policy blueprint last June. Disagreements over pilot training and additional slots at Reagan National Airport delayed Senate action.

It is unclear when and whether the full Senate will consider the FAA bill, but having bipartisan consensus on a bill has allowed staff from both chambers to begin informally discussing final legislation. A compromise bill could be taken up by the House and sent to the Senate for a final vote, avoiding a floor debate on the Senate’s current bill. However, that would make it more difficult for senators not on the Commerce Committee to add amendments and would undermine the Senate’s negotiating power during the “preconference” discussions.

The most recent FAA law, enacted in 2018, expired last October. The agency has been operating under a series of short-term extensions ever since. The most recent expires on March 8, meaning Congress will have to pass at least one more, likely through early May, to buy lawmakers more time to negotiate (and, possibly, for the Senate to follow regular order and vote on its version of the bill).

The Senate bill contains several provisions proposed by ARSA. In addition to increasing funding for the technician workforce grant program created during the last reauthorization, the bill also directs FAA to address access to instructions for continued airworthiness (maintenance manuals). However, like the House bill, the Senate version also contains foreign repair station legislation ARSA opposes. The Senate bill also does not include other ARSA provisions in the House bill, including language to better align guidance and regulations, end open-ended investigations, and clarify the conditions under which a major alteration requires a supplemental type certificate.

The Senate bill text is here.

A summary of amendments added during the recent markup is here.

The House bill text is here.

With the reauthorization process finally showing signs of life, ARSA and its members are intensifying their lobbying. FAA reauthorization will be the focus of ARSA’s Legislative Day on Wednesday, March 13, when members from around the country will descend on Capitol Hill to advance the maintenance industry’s priorities. Legislative Day will also feature briefings by the ARSA team, association members, congressional staff, and industry allies and the presentation of ARSA’s 2024 Legislative Leadership Award . to House Aviation Subcommittee Chairman Garret Graves (R-La.). For more information about Legislative Day and to register, click here.

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Aviation Life Calendar

February Through May

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.

Live From the Conference – Regulations for Supervisors & Inspectors

The 2024 ARSA Annual Conference will close on March 15 with a special training session. Executive Director Sarah MacLeod, with assistance from Vice President of Operations Brett Levanto, will lead a two-hour session overviewing the regulatory knowledge necessary for repair station accountable managers, supervisors, and inspectors (and pretty darn important for everyone else).

The session will be presented live following the Annual Member Meeting and livestreamed to Conference Ambassadors. It is also available for separate registration through ARSA’s online training program for individuals not otherwise registered to attend or view the conference.

To see the full Conference agenda and register for the event, click here.

To register for just the broadcast of the training session, click here.

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 § 21.5, Airplane or Rotorcraft Flight Manual.

Click here to download the training sheet.

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Membership

Good Relationships

By Kimberly Dimmick, Vice President of Membership

In ARSA’s youth, membership information was managed and stored in flat files – basically a big spreadsheet with little organization or function. As membership and benefits grew, this cumbersome data management system was replaced with a relational database. It’s better and more functional, but still lacks the export, import, and report capabilities ARSA needs to efficiently manage its members and benefits (for the vice president of membership, managing data is the foundation of member relations).

ARSA is migrating member data into its in-house designed database. The new management system will allow the export, import and report functions necessary to efficiently relate to and with its members.

Keeping information current is a daunting task and remains largely in the hands of members. So, when you receive an updated member certificate and the organizational profile, take the time to review, update, and return the profile.

You don’t have to wait for the annual profile, keep our relationship current and healthy – contact me at kimberly.dimmck@arsa.org whenever changes to your people or organization take place.

Advertising – The Clicks Add Up

Last summer, ARSA set up basic tracking for each of its advertiser links on either ARSA.org or distributed through newsletters.

Don’t panic! This tracking doesn’t place anything on your computer or mobile device – ARSA is not following you to another site or newsletter – nor does it retain information about your specific machine or anything else about your web surfing habits. The “bit.ly” links just tally each visit.

The tally provides the scope and scale of attention created by ARSA in helping connect readers to its advertisers. It shows which messages attract the most attention and where readers are more likely to click; essential information for advertisement placement.

The data shows that ARSA ads have produced nearly 14,000 “engagements” (that’s fancy internet speak for a click) since July of 2023. That’s a lot of attention from a very specific and important segment of the aviation audience. Thank you for doing your part – keep those clicks coming!

ARSA advertisers sell services and products, build careers through job announcements, and show their commitment to quality through the association. Learn how to join them at arsa.org/advertising.

Quick Question – Foreign Drug and Alcohol Testing

The FAA has followed a congressional mandate to issue a proposed rule requiring safety sensitive employees in foreign repair stations to be tested for drug and alcohol use under the United States regulations. While ARSA coordinates with its industry association allies to comment on the proposal, member companies can help by providing data through 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/d_and_a_nprm.

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

Welcome Back – 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 renewed in February:

Returning Members
AeroParts Manufacturing & Repair, Inc., R04, 2016
AeroRepair Corp., R03, 2012
Aerotech Engineering Consultants, Affil, 2016
AerSale Roswell Aircraft MRO Operations Center, R05, 2011
Air-Cert, LLC, R01, 1990
Aircraft Component Repair, Inc., R03, 1987
AvidAir Helicopter Supply, Inc., R01, 2011
Barfield, Inc., R05, 1995
Cadorath Aerospace Lafayette, LLC, R03, 2005
Columbus Aero Service LLC, R01, 2021
Compressed Gas Systems, LLC, R03, 2012
Continental Aircraft Support, Inc., R03, 2004
Erickson Incorporated dba Erickson Air-Crane, R05, 1997
Flight Power Repair Group, LLC , R03, 2021
Helimax Aviation, Inc., R03, 2019
IHI Corporation, R06, 2019
Master Air Parts, Inc., R01, 2013
Mingo Aerospace, L.L.C, R03, 2005
Ohlinger Industries, Inc., R04, 2006
Precision Airparts Support Services, Inc. , R02, 2021
Rapco, Inc., Assoc, 1990
S3 AeroDefense, LLC, R02, 2010
S.E.A.L. Aviation  LLC, R03, 2014
Skytech Aviation, Inc., R01, 2013
ST Engineering North America, Inc, Corp, 2006
TAIGLOBAL Group, LLC, Assoc, 2023
Team J.A.S., Inc., R02, 2004
Toddcoe Aviation dba Alpha Aircraft Services of America, Inc., R01, 2012
Thales Avionics, Inc., R04, 2006
TSA Rewinds Florida, Inc. dba Aircraft Armature Inc. , R02, 2019
Turbine Aircraft Logistics, LLC, R01, 2021
Valcor Engineering Corporation, R01, 2004
Western Aero Repair, Inc., R03, 2011
WGI, Inc. dba Westfield Gage Company Overhaul and Repair, R03, 2018
Windsor Airmotive West Chester Division-Barnes Aerospace, R04, 1995

A Member Asked…

Q: Can you help me define “management” as it relates to § 145.161. The rule requires “A roster of management and supervisory personnel that includes the names of the repair station officials who are responsible for its management and the names of its supervisors who oversee maintenance functions.”

Does that mean that management that do not oversee maintenance functions must be listed? We have a variety of management positions, i.e., purchasing, shipping, accounting, facilities, sales, should they all be included?

A: The answer was clear in the earlier versions of the regulation but has gotten lost as company organizations and agency expectations have changed. Here is the best guidance ARSA can provide.

Management personnel include the accountable manager and others that make the decisions necessary to establish the policies and procedures for the certificate holder that require implementation to comply with parts 43 and 145. So, managers are those with the duties, responsibility, and authority to establish and approve policies and procedures associated with 14 CFR compliance—those required to be contained in the repair station and quality manual and forms.

Supervisors are those implementing the policy and procedures associated with the methods, techniques, and practices (maintenance or alteration) performed and approved for return to service by the certificate holder under 14 CFR part 145. Supervisors are generally those with the duties, responsibility, and authority to implement the policies and procedures contained in the repair station and quality manual(s) and forms associated with directing work and overseeing personnel unfamiliar with the tasks assigned.

Hopefully the italics in this answer help focus you on the key details for answering your question.

Have questions about aviation regulatory compliance or legislative policy? Ask ARSA first!

ARSA Survey Invite Sent

The association encourages its members to respond to two important questionnaires gathering data about the industry:

ARSA Annual Member Survey

On Feb. 20, an invitation to complete ARSA’s member survey was sent to the email address of every primary contact. The message was subjected “Complete ARSA’s Member Survey” and was sent by Vice President of Operations Brett Levanto. Ensure the invitation makes it to your primary contact and gets the attention it deserves.

The association’s annual member survey gathers intelligence on issues facing the international maintenance community. Responses improve ARSA’s services and provide data to support advocacy on behalf of the global aviation industry. Please help by submitting…or stimulating your primary contact to submit on your company’s behalf. (If you don’t know who the primary contact is, or don’t think the invitation got through, we can help.)

Oliver Wyman’s MRO Survey

The global consulting firm’s partnership with ARSA produces the association’s annual market assessment. It’s survey team relies on the association to help produce broad response to its annual survey. It should take no more than 15 minutes and can be accessed from your mobile device or computer.

Responses are confidential and all information provided by participants will be reported in aggregate only. Participants are entitled to a summary of results and key findings. Questions about the survey may be directed to the research team at: MROsurvey@oliverwyman.com.

To complete Oliver Wyman’s MRO Survey, please visit https://oliverwyman.co1.qualtrics.com/jfe/form/SV_6lhjEbvDJEFIAAu.

The 2024 Global Fleet & MRO Market Assessment, prepared by Oliver Wyman, will be unveiled in March during ARSA’s Annual Conference. Click here to register now.

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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