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ARSA Leads “Can do” Panel, EASA Shares SMS Compliance Date

From June 11-13, ARSA’s leadership team participated in the 2024 FAA-EASA International Aviation Safety Conference in Washington, DC. The annual event alternates between Cologne and the American capital city as a venue for international regulators to interface directly with industry representatives.

The 2024 event’s theme “Preparing for the Decade Ahead” produced three days heavy with “new” challenges and opportunities but allowing time for current concerns. The final agenda included regulatory changes, standards development, and technological implementation but was bookended by the AOG Technics parts documentation scandal and new requirements for Safety Management Systems (SMS) implementation.

Though the FAA excluded repair stations from its expansion of SMS requirements in part 5, EASA has been clear a mandate for U.S. part 145 air agencies holding European approval under the bilateral agreement will be added to the two jurisdictions’ Maintenance Annex Guidance. Those awaiting the official change to the MAG can pencil in an expected SMS compliance deadline of December 31, 2025: By that date all affected repair stations must have verified their compliance with the FAA’s voluntary program to continue their European approval.

NOTE: On June 20, 2024, the FAA published an InFO advising certificate holders of the Dec. 31, 2025 deadline.

ARSA’s Levanto (Left) stands with “Can Do” panelists (from right), Martin Ricklin, Lufthansa Group; Chris Parfitt, FAA; John Mathis, Delta Air Lines, and Eugenia Diaz Alcazar, EASA.

ARSA Vice President of Operations Brett Levanto moderated a June 12 panel on “Evolving Technologies for Maintenance and Inspection Functions,” including representatives from both regulators as well as Lufthansa and Delta Air Lines (both of which are connected to Corporate Enterprise Memberships through their maintenance organizations). On this “can-do panel,” Levanto highlighted the flexibility available to certificate holders under performance-based regulations. Acting FAA Aircraft Maintenance Division Manager Chris Parfitt punctuated the key point by sharing ARSA’s oft-repeated guidance that “if it’s not prohibited, it’s allowed.”

ARSA’s team also used the gathering for a meeting with new EASA Executive Director Florian Guillermet and his flight standards and certification team. The association regularly connects with regulators at all levels, getting to work with technical managers while maintaining relationships with top executives.

The event page, managed by the Aerospace Industries Association, still includes details for those curious about format and structure. To read the joint cooperation “pledge” made by the FAA and EASA at the close of the Conference, click here.

The 2025 event will return to Cologne from June 10-12.

Safety Management Systems Program

To see coverage a previous International Aviation Safety Conferences, review the content below.

Previously from ARSA...

6/21/23 - ARSA Flashes at FAA-EASA Conference

June 21, 2023

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 together 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 to show how U.S. industry has communicated about the crisis and what the government and individual companies are doing to address it. He noted the industry’s workforce challenges threaten both business efficiency and the quality of regulatory oversight because in many cases manufacturers, operators, maintainers, and regulators are drawing from the same talent pool.

Klein also participated in a panel addressing the “evolution of maintenance cooperation under the BASA.” He noted cooperation 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 once again be there and encourages members to plan 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.

To see the event page, hosted by EASA, click here. To view the full agenda, click here.

6/22/2022 - FAA-EASA Conference – New Tech, Digitization, Workforce

June 22, 2022

Aviation safety professionals from around the world gathered in Washington, D.C. June 14-16 for the 2022 FAA-EASA International Aviation Safety Conference. ARSA was represented by Executive Director Sarah MacLeod and Executive Vice President Christian Klein. Representatives from leading aviation authorities, trade associations and companies discussed a range of topics, including digitization, alternative propulsion systems and workforce challenges.

ARSA Executive Director Sarah MacLeod pops up from behind her fellow “Evolution of Aircraft Maintenance” panelists at the FAA-EASA International Safety Conference.

MacLeod participated in a June 15 panel on the “Evolution of Aircraft Maintenance” along with Aircraft Electronics Association Vice President of Government and Industry Affairs Ric Peri (who moderated), FAA Aircraft Maintenance Division Manager Jackie Black, EASA Aircraft Maintenance Manager Raffaele Iovinella, Lufthansa Technik Senior Director of Engineering Services Ringo Schmelzer and Wisk Aero Policy Manager David Oord.

MacLeod and her colleagues discussed recent developments and innovative approaches to aircraft maintenance, with a focus on looming challenges associated with new practices and supporting novel/innovative aeronautical products. They agreed the data generated by modern aircraft systems will make maintenance even more effective, but noted challenges associated with managing and using vast quantities of information. Panelists discussed the need for regulators, operators, maintainers and manufacturers to share data to provide the broadest benefit.

ICAO SG Puts AMO Approval Front and Center

ARSA members are apparently not the only ones frustrated by redundancy in oversight of the maintenance sector. In his June 14 conference keynote address, International Civil Aviation Organization (ICAO) Secretary General Juan Carlos Salazar said that streamlining the certification of aircraft maintenance organizations (AMOs) is among his top priorities.

“[A]ircraft maintenance is still not considered ‘exportable’, and so States are required to apply their own approval requirements,” Salazar said.  “A consequence of this framework is that AMOs performing maintenance on an international basis now face a multitude of procedures, manuals, quality assurance systems and personnel requirements. And they’re further confronted by the obligation to undergo multiple inspections from the various States whose operators make use of their services.”

“Not only is this practice inefficient, and a significant burden to both airlines and AMOs, but it also falls short of establishing a stable platform for the standardization of maintenance practices,” Salazar said. “Past ICAO Safety Conferences have recognized this burden on industry, in addition to the importance of facilitating a globally harmonized approach to AMO approval and acceptance.”

Salazar said that as a step towards facilitating mutual acceptance, ICAO has developed a series of standards and guidance materials to promote the uniformity of AMO regulatory requirements. He said he hopes these will reduce the economic burden imposed on the industry by unnecessary certification and surveillance activities and encouraged regulators and industry to embrace them.

As with so many conferences, the networking opportunities provided during breaks, meals and receptions are as valuable as the presentation content. After two years of relative isolation, attendees at this year’s FAA-EASA meeting had the opportunity to rekindle old friendships and meet those who’ve recently joined an agency or the industry. Next year’s conference will take place in Cologne in June. ARSA members are encouraged to participate to ensure maintenance issues receive the attention they deserve.

6/24/19 - FAA-EASA Conference Recap – The View from FL 400

June 24, 2019

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!).

6/26/18 - Pursuing the 'Systems Approach'

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.

5/24/18 - ARSA’s Filler to Lead Panel at FAA-EASA Conference

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.

ARSA members are encouraged to attend, click here to register.

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.

6/21/16 - ARSA Works: On Stage and Behind the Scenes at FAA-EASA Conference

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.”

6/15/15 - Filler Moderates at FAA-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.

6/19/14 - ARSA’s Filler Speaks on International Compliance

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.

 



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