FAA-EASA Conference Recap – The View from FL 400
The annual aviation safety conference sponsored by EASA and the FAA was held in Cologne, Germany from June 12-14. Those who regularly attend this event are, by now, used to the high-level agenda. EASA Executive Director Patrick Ky stated that the authorities are well aware of the complaint that the conference should include more working-level (i.e., day-to-day) issues. However, he defended the current model by noting that the higher-level topics are of greater interest to more attendees because, like Safety Management Systems (SMS), they apply to all segments of the industry. It is certainly a valid point but, in ARSA’s view, the sweet spot would result in a better balance. Nevertheless, the approximately 375 attendees from more than 40 countries were there primarily for the networking opportunities and there were many.
The agenda included sessions on Safety and the Role of Regulators in Innovation, the Challenges of Technology, Effective Oversight of SMS, State Safety Programs, Digital Transformation (i.e., use of “big data” and advanced analytic techniques), Interoperability of Aircraft Between Different Oversight Systems and Leveraging Synergies to Reduce Duplicative Certification Activities.
We all know SMS is coming; the degree will depend on how each local authority intends to implement (or not) the ICAO standard. Those entities that receive a pass from their own authorities will, in all likelihood, be required to implement an SMS as a condition for doing business internationally. (For the U.S. in particular, voluntary SMS implementation and recognition by the FAA will hopefully be adequate for international purposes.) Although it is way too soon to know how the international SMS component will play out, one thing is clear: The authorities are behind the curve in ensuring their inspector workforces have the skills required to transition from the surveillance model to a systems approach. It is widely recognized that this paradigm shift must take place for the effective implementation of SMS. Suffice it to say that we anticipate a lack of standardization in how SMS will be enforced domestically and internationally.
Although not surprising, it was disappointing that maintenance was again an afterthought. Sure, there was a panel devoted to the international collaboration efforts that produce the Maintenance Review Board Reports (MRBR), which become the basis for air operator maintenance programs. There is no direct regulatory underpinning to the MRB process although type certificate holders typically use the MRBR to show compliance with the scheduled maintenance requirements of the Instructions for Continued Airworthiness (ICA).
Apparently, the representatives from the authorities, operators and manufacturers who comprise the International MRB Policy Board (IMRBPB) see little need to include independent maintenance providers, even though more than 70 percent of air carrier maintenance is contracted and a part 145 approval is required to perform maintenance in Europe.
They believe the current “three-legged stool” includes maintenance providers since the operator and authority representatives have maintenance backgrounds. ARSA’s intrepid Executive Director asked whether a four-legged stool that includes independent aircraft maintenance providers (particularly those that work for multiple airlines) would be more stable. Wouldn’t their insights be valuable in developing the MRBR? Apparently, the fear is that this would slow down the process. However, since the policy board document is a standard developed by the Airlines for America (A4A), maintenance providers were invited to submit a request directly to that association.
One welcome development at the conference was the introduction of 15-minute flash talks strategically placed during each day to break up the monotony of the panel format. Modeled after the highly-successful TED talks, they covered Collaboration (from the perspective of the off-shore helicopter industry), the oddly-named Runway Safety, Main Killer in Aviation and Vision 2050, a peak into the Jetson’s-like future we all know is coming.
This year’s conference once again used the Slido app to field questions from attendees and tabulate responses to survey questions. The tool continues to improve yet, in our view, it should not be used exclusively since it does not allow for the same audience interaction as the “open mic.” For that reason, ARSA is not likely to use the Slido app at its annual conference (although we do worry who will fill the shoes of Howard Whyte and Werner Luehmann!).
Previously from ARSA...
June 26, 2018
The FAA and EASA held their annual safety conference from June-19-21 in Washington, D.C. While the agencies are the primary drivers of this event, other regulators including Transport Canada and ANAC of Brazil were also present as were other civil aviation authorities from Asia, Europe and South America. The conference covered a variety of safety topics and, after a year’s absence (see 7/19/17 update below), maintenance was back on the agenda.
As usual, the plenary sessions focused on high-level relationships and agreements among regulatory agencies. They highlighted continued progress made by the authorities toward accepting each other’s design, production and maintenance approvals to the extent allowed by law. Attendees discussed the need to establish and maintain confidence in each other’s regulatory systems and sustain trust in order to keep cross-border relationships robust.
Historically, aviation agreements have been bilateral and transactional. In other words, between two countries or regions and addressing specific kinds of approval. The key question is always whether all or some aspects of an exporting country’s approval can be accepted by the importing country.
A good example is repair data. EASA and the FAA have significantly different systems for determining which repair data requires approval, how the data should be classified (i.e., major or minor) and the methods of approval. During the last 15 years, the agencies transitioned from the point where all repair data had to be approved in accordance with the importing authority’s requirements to requiring it only for critical repairs to recently deciding to accept all repair data approved under the other’s system. Positive experience generated confidence in the agencies that the agreement could be expanded to full reciprocal acceptance.
During the conference, the leaders of both agencies spoke about transitioning to a systems approach for evaluating each other’s technical competence. While this will happen incrementally and therefore slowly, it shows that the regulators recognize industry spends far too much on obtaining redundant regulatory approvals that provide little, if any, safety value. There is no doubt this practice diverts scarce resources away from more important safety initiatives. While almost everyone recognizes the legal and nationalistic realities, there is widespread agreement that the 75-year old international regulatory structure overseen by ICAO creates some undesirable outcomes.
Bilateral agreements are still the main vehicle for achieving international safety objectives; however, the authorities have recognized the value in working multilaterally. The Certification Management Team (CMT) and Maintenance Management Team (MMT) consist of representatives from the FAA, EASA, TCCA and ANAC. The bodies meet twice each year – at least once in person. During the latter event, which lasts most of the week, industry is given an opportunity to discuss issues of particular interest. The next CMT meeting is in September in Washington, D.C. followed by the MMT in Brasilia in November.
Marshall S. Filler, ARSA’s managing director & general counsel, moderated an industry-regulator maintenance panel entitled “Maintenance in the Digital Era.” Panelists included Tim Shaver (FAA), Ralf Erckmann (EASA), David Van den Langenbergh (Luxaviation), Gilles Garrouste (Dassault Aviation) and Marc Olson (FedEx).
Many of the activities discussed during Filler’s panel have been in use for some time, including electronic records, manuals and signatures. However, some of the more recent technological advances such as remote connectivity (i.e., performing inspections remotely using live video streaming or similar methods) and aircraft health monitoring systems generated a lot of interest. There was consensus that technology could provide useful tools and information to operators and maintenance providers as long as robust processes were in place to control it. ARSA expects the regulators will issue guidance on these topics in the not-too-distant future.
Another topic worth noting was the session on New Parts Documentation moderated by Jason Dickstein of the Modification and Replacement Parts Association (MARPA). There are several outstanding issues remaining from Changes 5 and 6 to the FAA-EASA Maintenance Annex Guidance which required an Authorized Release Certificate to accompany all new parts installed during maintenance subject to a dual release. Some pesky issues remain including the fact that commercial-off-the-shelf parts are confined to a “no man’s land” since those that have an Authorized Release Certificate (or are even eligible for one) are few and far between.
EASA continues its rulemaking efforts to create a 4-tier new part criticality classification system for maintenance with only a small number of parts requiring a Form 1. ARSA remains skeptical that the EU design approval holders will voluntarily do this on their own in which case nothing will change. As ARSA has stated previously, this issue would benefit greatly from a systems approach where each authority would agree to accept the other’s parts documentation system since they produce equivalent safety outcomes.
Unfortunately, the international aviation community has a long way to go before the systems approach is universally applied.
May 24, 2018
Marshall S. Filler, ARSA managing director and general counsel, will moderate a panel on “aviation maintenance in the digital era” during the 2018 FAA-EASA International Safety Conference in Washington, D.C. Registration is open for the event, which will run from June 19-21.
Filler’s panel will be held on Wednesday, June 20 at 10:45 a.m. as one of two sessions focused on “Global Collaboration.” The general topic was identified by event organizers – with input from ARSA and its allies – as a strategic focus area for the aviation community. Filler will lead panelists through discussion outlined in the abstract:
A range of new approaches to maintenance is under development or already in commercial use such as electronic logbooks/maintenance records; aircraft inspections using drones; remote inspections using video; and big-data driven maintenance decision-making. In this panel session, industry will present innovative maintenance solutions, discuss potential issues with paperless maintenance records (including input from leasing companies), and propose possible regulatory approaches to related issues, such as addressing duplicative MRO oversight.
Through the annual event, the agencies and the aviation community share information and work toward harmonized safety standards, policy and procedures. That purpose – though noble – only becomes reality through active participation by the industry, and maintenance must be well represented for there to be a true “systems approach” to international regulatory oversight.
To see the agenda, click here.
To register, click here.
To learn how to make the most of the event and its setting in the nation’s capital, read “2018 FAA-EASA Conference – Attend, Assist, Advocate” below.
April 26, 2018
Registration is officially open for the 2018 FAA-EASA International Safety Conference. The aviation maintenance community – ARSA members in particular – should plan now to come to Washington, D.C. from June 19-21.
Through the annual event, the agencies and the aviation community come together to share information and work toward harmonized safety standards, policy and procedures. That purpose – though noble – only becomes reality through active participation by the industry, and maintenance must be well represented for there to be a true “systems approach” to international regulatory oversight. So, ARSA urges its members to consider taking advantage of the conference in a number of ways:
Attend and Participate
Register to come to D.C. and participate in the conference, which will be held at the Mayflower Hotel. The $695 fee entitles the registrant to all workshops, presentations and panel discussions in addition to breakfast, lunch and coffee breaks during the meeting as well as a dinner cruise on the Potomac River and a Wednesday evening dinner reception. Getting into the rooms and at the events surrounding the conference is key to ensuring international regulators understand and address matters of importance to maintenance providers.
Assist Through Sponsorship
The FAA and EASA are administering the 2018 conference in partnership with industry. The Aerospace Industries Association and the General Aviation Manufacturers Association – both ARSA allies – have taken the coordination lead and have opened the door to support through sponsorships. By sponsoring, aviation businesses commit to the facilitation of good government and reasonable oversight. A limited number of options are available, all of which include at least one complimentary registration. For information, contact Bry Spinella, AIA manager of corporate events (email@example.com):
Advocate for the Your Industry
In conjunction with participation in EASA/FAA meeting, ARSA’s Legislative team encourages its members to spend time on Capitol Hill meeting with congressional offices that represent any company facilities. The FAA bill will be front and center in June and ARSA is working hard to include regulatory and workforce development provisions that will benefit the entire industry. Executive Vice President Christian A. Klein (firstname.lastname@example.org) is available to work with members in setting up and preparing for congressional meetings, as well as planning to host representatives or senators on visits to facilities back home.
Make time to attend the 2018 International Safety Conference and make the most of the trip by representing the aviation maintenance industry.
To access the event page, click here.
July 19, 2017
ARSA Managing Director and General Counsel Marshall Filler attended the EASA-FAA International Aviation Safety Conference in Brussels, Belgium from June 14-16. He also represented the association in the industry pre-meeting held on June 14 to discuss the agenda and the activities of various government-industry working groups dealing with Aircraft Certification (AIR) and Flight Standards (AFS) issues. According to Patrick Ky, EASA’s Executive Director, approximately 300 people attended the conference representing 51 countries, 22 Civil Aviation Authorities, 26 trade associations and 82 individual companies.
The conference focused on building trust and the need for early communication and collaboration between government and industry, whether it be rulemaking, guidance development or certificating new products. There were panels dealing with performance-based rulemaking (a trend that will undoubtedly continue), such as the new FAA part 23 and EASA CS-23 (which become effective in August of this year), the use of big data in identifying potential operational safety issues at an early stage, recent activities in regulating unmanned aircraft systems, challenges and opportunities in aircraft and engine certification and certificating products with emerging technologies.
Conspicuous by its absence and for the first time in recent memory: There was no panel devoted to maintenance on this year’s agenda, in spite of ARSA having suggested topics for discussion when the agenda was first being developed. Filler commented on that during the industry pre-meeting and again during the audience participation phase of the first plenary session, stating that he hoped this was the last such conference he would attend where maintenance was omitted from the planned discussion. While Filler was assured privately by FAA and EASA officials that it was unintentional, the omission reinforces a longstanding and unfortunate issue with perception of a very important link in the safety chain. Several attendees from the maintenance industry echoed those concerns. Judging by the regrets expressed privately by American and European officials the association is hopeful the omission was an outlier.
For most attendees, networking opportunities with both regulators and industry colleagues are the greatest value in attending this annual safety conference. While that is true, recent budget reductions have reduced the number of agency people that attend from both sides of the Atlantic. Most of the government attendees were high-level people (i.e., FAA service directors and a few others in non-technical, policy making roles). None of the “working-level” AFS or AIR division managers were present, nor were their EASA counterparts. In the association’s view, this diminishes the value of the conference especially considering the costs associated with long-distance travel. Nevertheless, that reality is not likely to change and fortunately, the conference alternates annually between Europe and the United States
As expected, next year’s conference will be held in the Washington, D.C. metropolitan area, according to FAA Flight Standards Director John Duncan who made the announcement at the close of the June 15th session. Stay tuned to ARSA and the agencies to see when exactly the June, 2018 event will be.
June 21, 2016
On June 14-16, the international aviation safety community landed In Washington, D.C., for the 2016 International Safety Conference, co-hosted by the FAA and EASA. On stage and behind the scenes, ARSA continued building its global network.
The conference’s plenary sessions began on June 14 with a panel considering a key question for international aviation: “How do we achieve the true benefits of a bilateral?” Marshall S. Filler, ARSA’s managing director and general counsel, participated alongside agency officials and industry executives, including EASA’s Executive Director Patrick Ky.
The association is committed to pursuing bilateral and multilateral agreements; a 2011 ARSA-commissioned study found repair stations enjoy considerable cost savings when working among nations with bilateral agreements. Through reciprocal acceptance, civil aviation authorities maximize the safety benefits of international oversight while minimizing compliance burdens. Such reciprocity is rare, but Filler’s participation in the panel is integral to pursuing better international agreements.
Off stage, ARSA senior staff met with Ky and EASA’s Flight Standards Director Ricardo Génova Galván. Executive Vice President Christian A. Klein and Vice President of Legislative Affairs Daniel B. Fisher joined Filler to brief the agency’s leadership on the association’s work.
ARSA representatives often join international gatherings as the maintenance community’s sole voice. For the association, this role – in the lead on behalf of the men and women who keep the world in flight – is natural. While it cultivates a growing web of allies, advocates and contacts around the world, ARSA encourages its members to seek out such events, build their own connections and add more voices to the maintenance “chorus.”
May 13, 2016
From June 14-16, the international aviation safety community will converge on Washington, D.C.’s Mayflower Hotel for the 2016 Aviation Safety Conference. This event, co-chaired by the FAA and EASA, will focus on the theme of “Global Partnerships: The Keystone for Safety.”
The conference will provide attendees an open forum to discuss international cooperation while considering emerging safety challenges. In addition to guest speakers and plenary sessions addressing aviation’s most critical needs, participants may use the venue to create and strengthen professional partnerships.
The plenary sessions begin on June 14 with an investigation of bilateral agreements. Marshall S. Filler, ARSA’s managing director and general counsel, will join EASA Executive Director Patrick Ky and representatives from Textron and Airbus for the panel discussion on international cooperation, moderated by officials from the FAA:
Plenary Session A – Panel Information
How Do We Achieve the True Benefits of the Bilateral?
This discussion will address the public/private aspects of bilateral agreements. The public (government) aspect will focus on mutual recognition of authority competency, risk-based application of international resources, harmonization of efforts between civil aviation authorities. The private (industry) aspect will focus on the multilateral concept, reduction of redundant activities from bilateral agreements resulting in industry burden (certification & oversight) and the financial impact of changes to the bilateral.
Filler’s participation in the conference has become an annual tradition (see below); it is part of the association’s commitment to international regulatory cooperation.
The conference registration deadline is June 3 (individuals from outside of the Washington area should reserve hotel accommodations before May 22). For more information, visit www.regonline.com/2016FAA-EASA-Conference.
June 15, 2015
On June 11, ARSA’s Managing Director and General Counsel Marshall S. Filler moderated the maintenance panel at the 2015 FAA-EASA Conference in Brussels, Belgium. Joined by regulators and industry representatives, the discussion addressed interim and long-range mechanisms to reduce redundant requirements and surveillance activities for Approved Maintenance Organizations (AMOs).
In addition to Filler, the panelists were:
- Juan Anton, Maintenance Regulations Section Manager, EASA
- Steve Douglas, Manager Aircraft Maintenance Division, FAA
- Flavio Izzo, EAQG MRO Relationship Growth Str. Leader, International Aerospace Quality Group (IAQG)
- Todd Duncan, Chairman, Duncan Aviation
- Rainer Lindau, VP Quality Management, Lufthansa Technik
Though the group’s suggestions covered a broad range of strategies, many focused on involvement by the International Civil Aviation Organization (ICAO) or some other body that could play the role as single oversight authority. Specific proposals included development of guidance, creation of oversight networks and establishment of more international agreements for joint certification and surveillance.
June 19, 2014
Marshall Filler, ARSA managing director and general counsel, joined with other international aviation representatives this past Wednesday, June 18, at the 2014 FAA-EASA International Aviation Safety Conference. Filler and fellow stakeholders focused on various aspects of the U.S. and EU Safety Agreement along with its Technical Implementation Procedures (TIP) and Maintenance Annex Guidance (MAG).
Filler spoke on a panel entitled “Annex 2 of the US/EU Safety Agreement: Updates to the Maintenance Annex Guidance and What to Expect in Sampling Inspections.” The panel also included representatives from the FAA, EASA and MTU Maintenance Hannover.
FAA and EASA representatives updated participants on the changes that have been made to the MAG based on lessons learned since its implementation. They also briefed attendees on the Sampling Inspection System (SIS). The SIS is an effort by the two agencies to consult and share information on quality assurance and standardization activities. Its objective is to ensure that each authority can be confident in the surveillance conducted by the other. Consistent implementation of this system, combined with dependable education addressing MAG procedures and changes, are essential if we are to move forward in today’s international landscape.
ARSA focused on issues and compliance challenges that have not yet been resolved—specifically part tagging requirements, acceptance of a common release certificate and the need to heighten the awareness of the U.S. air carrier industry about the mutual acceptance of most repair data. MTU, while citing its own frustrations with U.S. operators on the repair data issue, echoed a common theme among industry representatives attending the conference: inconsistent regulatory standards and their application do not promote safety and efficiency in the aerospace industry.
ARSA’s leaders work tirelessly to engage with government and industry representatives through public events and engagement. For more information, please visit our industry events page.