Hotline Highlight – Being Entitled
The hotline – ARSA’s premier member newsletter – contains news, editorial content, analysis and resources for the aviation maintenance community. All members should ensure they receive their edition the first week of each month. Not getting yours? Click here for direct access.
In this edition…
From basic compliance to dealing with the government to relying on your own business network, this edition of the hotline re-enforces the value of knowledge.
From the “Legal Briefs”…
Editor’s note: This material is provided as a service to association members for educational and informational purposes only. It does not constitute legal or professional advice and is not privileged or confidential.
Layman Lawyer – Being Entitled
By Brett Levanto, Vice President of Operations
I’ll admit that “entitlement” can be a tricky word. In Washington, D.C. politics, it describes often-contentious government spending programs like Social Security and Medicare. In general culture and especially on some annoying corners of social media, the word describes the attitude and behaviors of people seeking special treatment or attention.
In aviation safety, there’s a very important and positive use of the term. In fact, this layman lawyer encourages his counterparts in the industry to remember just how “entitled” they are.
In January and again last month, this space provided a “layman lawyer” overview of the FAA’s Compliance Program. So far, this series has covered agency guidance to illustrate how inspectors and other officials are supposed to understand their responsibility to use critical thinking in assessing deviations for corrective action under that program. It’s useful to know how the agency instructs its people, but certificate holders must focus on the plain language of 14 CFR.
When working with companies seeking repair station certificates – particularly users of ARSA’s RSQM Compilation – ARSA Executive Director Sarah MacLeod often reminds them of an important statement in § 145.53(a), which says that with few exceptions “a person who meets the requirements of [part 145] is entitled to a repair station certificate with appropriate ratings prescribing such operations specifications and limitations as are necessary in the interest of safety.” (Emphasis added.)
The word “entitled” is not defined in 14 CFR. The common definition in the Merriam-Webster Dictionary is “having a right to certain benefits or privileges.” While an aviation safety inspector’s attitude may make it seem that certification is a blessing bestowed by the government, it is a right earned by persons demonstrating compliance with the plain language of the applicable rules. It is based on this simple principle that the association stands up to the government in showing compliance.
The submitter of this month’s “A Member Asked” showed the basics of this understanding. An inspector challenged the repair station’s manual revision process, citing a paragraph in Order 8900.1. “This is his guidance material, but to us it is not regulatory,” the member said.
Starting and ending with that awareness is essential to getting and maintaining a certificate and dealing with the government along the way. A certificate holder’s compliance responsibility is the minimum standards of the rules. When the FAA challenges you, show how your systems and procedures meet those standards and not the guidance provided to the aviation safety inspector.
By meeting the requirements of the rule, you are entitled to have and hold a certificate and its associated privileges. You earn this entitlement.
Help continue this discussion. Submit your “layman lawyer” experiences or questions via arsa.org/contact.
Previous Hotline Highlights
In this edition…
Poetry in Motion
From musicals to Shakespeare to jazz standards, this edition of the hotline only hints at the full beauty of the association’s constant work to improve the aviation maintenance world.
From the “Quality Time” section…
Editor’s note: The views and opinions expressed by contributing authors do not state or reflect those of ARSA and shall not be used for endorsement purposes.
Georgia on My Career-development Mind
By Vance Zeumer, Manager – PMA Engineering, Chromalloy
Chromalloy – ARSA Corporate Enterprise Member – is an active participant in the Georgia Rural Collaborative Coalition. Meetings include representatives from a wide cross section of education professionals, state and county government, outside consultants, education auditing boards as well as the Air Force, Army, and Civil Air Patrol.
The coalition’s focus is on select rural counties in Georgia, but its principles can be applied to any county or school system and offer guidance for the broader technical skills development community. Mentors and industry partners are being cultivated near target counties, but participation in the coalition comes from across the entire state. Progress reports from action committees focus on military and aviation industry mentorship. The committees are building programs targeting students with relevant interests in aviation, including piloting, maintenance, engineering, manufacturing, computer science, and advancing technologies for electric aviation and advanced air mobility. Students can be connected to opportunities in a Georgia Charter and Career Academy (CCA) or an industry partner.
The initial goal is to help high school students pursue CCA training opportunities. Ideally, training would lead to an industry recognized certificate. Chromalloy has recognized that active participation in the Georgia effort (or seeking similar state-wide opportunities elsewhere) places maintenance providers at the forefront of hiring these students.
To encourage other ARSA members participation in this and other coalitions, I am pleased to provide an opportunity for input to Georgia’s CCA curriculum so proper skills are developed for the maintenance community in this state, which can lead to mentorship and guidance to candidate students by employers in other states.
The August meeting is scheduled for Aug. 31 in Eatonton, Georgia on Aug. 31; it is open to any Georgia employer. Even if you are not from Georgia, though, the efforts being made, and the resources being created can be helpful to any employer in the aviation industry.
Please contact me at email@example.com for ways to get involved.
McKinsey & Company articles
- Defining the skills citizens will need in the future world of work
- The future of work in America: People and places, today and tomorrow
- Thomas L. Friedman and James Manyika: The world’s gone from flat, to fast, to deep
Southern Regional Education Board (SREB)
June 7, 2022
In this edition…
Hitting the Trail
The U.S. midterm elections are rapidly approaching. This edition of the hotline covers political engagement in a way that’s less about campaigning for office and more about advocating for your industry.
From the “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.
Giving Campaign Contributions
By Christian A. Klein, Executive Vice President
There’s a lot at stake in this year’s mid-term congressional elections. Republicans smell blood in the water and are bullish about their chances of retaking both the House and Senate. Democrats aren’t going to give up control of Congress without a fight and the leaked Supreme Court decision has activated the party’s liberal base.
The outcome is uncertain, but this year’s elections will certainly be among the most expensive. At some point in the next few months, it’s likely you’ll be asked by a congressional candidate or a political action committee (PAC) for a campaign contribution. Making campaign contributions is a way to make your voice heard in the process. Talking to candidates when they’re “dialing for dollars,” attending fundraisers, or meeting to deliver a check is an excellent way to build visibility and an opportunity to discuss important issues.
A candidate won’t do what you ask just because you give them a check (that’s called bribery and is a crime); but it’ll put you, your company, your industry, and your issues on their radar screen. Because ARSA wants its members to be politically active and exercise their rights, this month’s “Legal Brief” provides some basic guidelines for providing campaign-related financial support.
The Federal Election Campaign Act (FECA), which is administered by the Federal Election Commission (FEC), establishes limits and prohibitions on who can get involved in campaigns. Corporations (including nonprofits), banks, and labor unions are prohibited from using general treasury money to make direct contributions to candidates (independent expenditures by these entities – advertising in support or opposition to a candidate – are beyond the scope of this article). Partnerships and limited liability companies (LLC) can make contributions if it is attributed as income for tax purposes to one or more of the partners or owners.
The primary sources of congressional campaign funds are individuals and PACs. A PAC is a separate segregated fund set up by a corporation, bank, or union to receive contributions from individuals. The PAC can then use those resources to make bigger contributions to candidates. (By law, trade association PACs can’t ask you for a contribution unless you’ve consented to be contacted, so be sure to provide ARSA PAC with prior approval.)
Even though all contributions (directly to candidates or indirectly via PACs) must come from individuals, not all individuals are eligible to contribute. By law, foreign nationals are not allowed to make contributions in conjunction with U.S. elections; the contributor must be a U.S. citizen or permanent resident (green card holder). Federal contractors are also prohibited from making contributions; however, the ban applies to “persons” who have entered or who are bidding on a federal contract. In most cases, the contractor is likely to be a corporation (which is already prohibited from contributing); however, contributions from partnerships and limited liability companies with federal contracts are also banned, as are contributions from individuals under contract to the federal government and sole proprietors of businesses with federal contracts.
In addition to sources of campaign funds, the FECA also puts limits on how much individuals and PACs can contribute to candidates for each election. Keep in mind that in a normal cycle, a congressional candidate will have two elections: the primary (where the party chooses its candidates) and the general (which happens in November). However, the contribution limits also apply separately to runoffs and special elections.
In the 2021-2022 election cycle, an individual may contribute:
- $2,900 per candidate per election.
- $5,000 to a PAC.
- $10,000 to a state, district or local party committee.
- $36,5000 to a national party committee.
In 2014, the Supreme Court struck down limits on the total or aggregate than an individual can contribute, so you can give maximum contributions to as many candidates as you want. Also, an individual cannot make cash contributions that exceed $100 (because cash is harder to track) and anonymous contributions are limited to $50.
For FEC purposes, the term “contribution” means more than just money; the term is defined broadly as anything of value give, loaned or advanced to influence a federal election. In-kind contributions are goods or services offered for free or less than the usual charge; paying for something on a candidate’s behalf is also considered an in-kind contribution. Campaigns must report in-kind contributions and they count against contribution limits.
As part of our 2022 campaign strategy, ARSA strongly encourages its members to host candidates at company facilities. The meetings are an excellent opportunity for a candidate to gain knowledge about your business and industry and meet employees (i.e., voters). Hosting a standard facility visit (meeting with company execs/owners and a tour) shouldn’t raise campaign issues. However, if you want to host an event at your facility (i.e., a rally or fundraiser for a candidate), but sure to familiarize yourself with the applicable rules.
Supporting candidates and industry PACs is just one way to impact America’s political process. ARSA is standing by to support your engagement.
May 10, 2022
In this edition…
From honoring absent friends to collaborating with allies to welcoming new leaders to engaging the government, this edition of the hotline shows just some of the ways ARSA builds connections for the good of its industry.
From “The President’s Desk”…
Collaboration Brings Results Across the Globe
According to Oxford Languages, collaboration is “the action of working with someone to produce or create something.” In the international business of aviation, collaboration with many diverse people and organizations produces useful results.
From its inception, ARSA understood the international nature of aviation and the need for mutual interests to be identified and to prevail. To that end, collaboration is key. That’s why NORDAM was a founding member of ARSA and why we continue our allegiance to the association today. This representational powerhouse facilitates collaboration among individuals, companies, unions, trade associations, appointed and elected government officials, local organizations, and foreign aviation authorities.
The association operates with limited resources, using its expertise to identify issues that must be addressed and support those matters that are being addressed. Whenever ARSA learns of a current or future need, it begins the process of collaboration. It seeks allies from across a wide ranging spectrum of parties to develop mutual positions. Even if a given concern doesn’t directly affect association members but instead their customers and business partners, we still support any resulting initiative with informational resources for the broadest perspective for decision-making.
Another level of collaboration that strengthens us as an organization? Collaboration among members. As president of ARSA, I want all members to understand the depth and breadth of its collaborative – and independent – process. To spread the word to reach every maintenance organization, and inspire them to join.
Why should every MRO be part of ARSA? The first reason is to receive the most current information on almost any regulatory compliance topic confronting an international aviation maintenance business. Incidentally, this is why it’s critical for you to respond to ARSA surveys – so we can keep our finger on the pulse of this community. Did you know an ARSA representative responds to written member queries within two business days and often sooner with practical and understandable answers? Even if we don’t know the answer immediately, because of our collaboration efforts, ARSA readily finds another dependable source to inform our response.
The next reason is the power of ARSA’s representation on the most important issues to aviation maintenance organizations. Our collaboration with allies during the worst of the COVID pandemic resulted in direct monies for aviation maintenance organizations. And ARSA leadership on the workforce development front resulted in a multi-year grant program supporting education of aviation maintenance technicians.
If those two reasons somehow are not convincing enough, I can tell you from personal experience ARSA’s publication of model documents to establish compliance with 14 CFR part 145 was invaluable to NORDAM. These documents empower any user to move from quality control to quality assurance to establish safety systems. Likewise, ARSA’s global footprint and its powerful collaborative capabilities helped our company establish a thriving certificated repair station in Taiwan. That’s across the globe from our headquarters in Tulsa, Oklahoma. And we achieved it in the midst of an unprecedented global pandemic.
If you have any questions the association team can’t answer about the importance of collaboration among all certificated maintenance organizations through ARSA membership: Please send me a message. I will explain in more detail why, as a leading innovator in composite repair for aerospace, NORDAM is convinced of it.
2022 ARSA president | NORDAM assistant general counsel and corporate secretary
February 4, 2022
In this edition…
ARSA works key issues for years, revisiting and upgrading past efforts (with the help and feedback of members) regularly. This edition of the hotline delivers both new and familiar tools for use in pursuit of long-known goals.
From the “Regulatory Update” section…
Kissing Your SISter
The European Union Aviation Safety Agency (EASA) recently conducted Sampling Inspection System (SIS) visits in the United States. SIS visits are part of the U.S.-EU Maintenance Annex Guidance (MAG), and are a method by which the bilateral partners verify oversight of each other to the requirements of the MAG.
Reports that the SIS visits are resulting in findings directly against U.S. repair stations are troubling. In recent SIS visits, accusations that the MAG does not allow U.S. repair stations to use ARSA’s E-100 form to document a 14 CFR part 43 inspection of new parts that are not accompanied by Form 8130-3 issued by the production approval holder (or an FAA-designee) were brought to ARSA’s attention.
In 2016, the FAA provided ARSA a letter stating that the proper use of ARSA’s E-100 form, in combination with an 8130-3 (with a maintenance approval for return to service) complies with FAA regulations and the MAG. While the E-100 issue is being discussed yet again by the two authorities, we wanted to provide an understanding of how the SIS visits are supposed to work (see a complete review of the form’s functions in this edition of the hotline).
Bilateral relationships between civil aviation authorities (CAAs) are based on the notion of “trust but verify.” Before signing a bilateral agreement, and technical implementation procedures or maintenance implementation procedures or maintenance annex guidance, authorities audit each other’s legal system, regulations, and surveillance program to ensure the two systems of governance result in equivalent safety outcomes. Significant regulatory differences are addressed through the issuance of Special Conditions. Once the agreements are in effect, the authorities monitor each other’s oversight of the Special Conditions to maintain confidence in the equivalent level of safety and control.
In addition to the SIS visits (which are authorized by section 2.2. of the U.S./EU MAG), the signatories notify one another of regulatory changes, provide training to inspectors overseeing facilities operating under the MAG, and follow specific procedures to resolve differences in interpretation.
SIS visits are audits of the CAA’s oversight, not of the repair station or approved maintenance provider. Under the FAA/EASA MAG, only in the case of a Level 1 finding that lowers the safety standard and seriously impacts flight safety is the visiting CAA (in this case EASA) authorized to act directly. In the case of visits from EASA to monitor the FAA’s oversight, the MAG’s sec. 220.127.116.11 clearly states that, “For all other findings raised in the [CAA] visit report, [Approved Maintenance Organization] follow-up of the findings shall be accomplished by the [Flight Standards Office] and reported to EASA for closure with a copy sent to AFS-300.” In other words, corrective action on the part of the U.S. repair station after an EASA visit and finding is in the hands of the FAA, which must advise EASA when appropriate actions to resolve an issue have been completed.
On the other hand, if the SIS visit results in an issue of interpretation, the MAG sets out a process by which the matter can be elevated through the chain of command, meaning informal resolution by the respective Directors of Flight Standards or their designees, elevation to the Joint Maintenance Coordination Board (JMCB) and, if necessary, to the Bilateral Oversight Board (BOB).
In the absence of a level 1 finding, U.S. repair stations should understand the SIS visits do not impose any immediate obligation to change their practices unless the two authorities agree on the appropriate resolution in accordance with the MAG’s Special Conditions. And even when that is the case, the process by which corrective action and follow up is achieved resides with the host country’s CAA, in this case the FAA.
In cases where there is a disagreement between the agencies on how the Special Conditions should be interpreted, the MAG spells out a clear process whereby the issue can be resolved in an orderly, rather than precipitous, manner. The resolution is not to create a finding against the repair station or approved maintenance organization.
In this edition…
Worth Doing Again
By building on success and learning from shortcomings, we get better every time around.
Year in review…
Delivering newsletter emails is a constant challenge. Figuring out how to play nice with firewalls, spam blockers and subscription issues is a constant struggle.
ARSA now provides an avenue for members to access the hotline’s landing page directly. To jump right into the “2021 Year in Review” edition, complete the form below, verifying your member information. (The form will remain on ARSA’s newsletter webpage; it will continue to direct to the current edition.)
December 3, 2021
In this edition…
Life of the Party
This edition of the hotline looks expectantly towards the 2022 Annual Conference, with some key updates about the association’s ongoing advocacy. Reader challenge: Count the number of times the phrase “maintenance community’s premier substantive event” appears.
From the “Training” section…
From the FAA – Failure to Follow Procedures
ARSA invites members to take advantage of the FAA’s training session “FFP: The Buck Stops with Me.” Here’s the session description from the agency:
While aviation maintenance personnel are fully aware of the consequences of failing to follow procedures (FFP) – and have likely received training on this issue – FFP continues to be one of the leading safety issues in aviation maintenance.
The purpose of the “FFP: The Buck Stops with Me” course is to help aviation maintenance personnel better understand and appreciate how an organization’s culture affects safety with respect to FFP. Once learners have completed the course, they will be equipped with the tools to champion a commitment to reduce FFP events in their working environments.
For session information and to register, click here.
November 5, 2021
In this edition…
Who We Are
As ARSA turns towards a new program year, its team and board continue to focus on its core mission for the maintenance community. This edition of the hotline highlights ongoing work with a little reflection about shared commitment to the association.
From ARSA President Terrell Siegfried
Throwing Our Weight Around
Fellow ARSA member,
While I am relatively new to the board, I’m proud to represent a company that was a founding member of the Aeronautical Repair Station Association. That company, NORDAM, was itself founded on family values more than 50 years ago in Tulsa, Oklahoma by my father, Ray Siegfried. He foresaw a need to represent the shared interests of the global civil-aviation maintenance industry, providing seed money for the association in 1984.
Both organizations have grown through the decades by turning challenges into opportunities. Today, both are internationally known hard-hitters in the industry they serve.
In addition to aviation and many other interests, my dad loved boxing. So, while working with the ARSA team on a news release announcing my election as 2022 president, a familiar phrase kept coming to mind: “ARSA punches way above its weight class.” This consortium of a few dedicated, extremely knowledgeable people – fueled by a lean operating budget – has left a mark much greater than the sum of its parts on the global aviation marketplace.
Here’s their secret: While ARSA’s team provides the punch, its members provide the weight. Through investment, time and expertise, every company and contact in our member directory allows the association to be seen, heard and remembered while demanding consideration from international regulators and legislatures.
As your president, I am adding my personal weight to the association’s punch by asking you to practice your footwork, starting with these simple steps (click the links to learn more):
(1) Keep your membership in good standing. If your membership has lapsed, take the time to renew it; you won’t regret it. ARSA membership is insurance against future industry issues.
(2) Get everyone in your company signed up to receive ARSA communications to stay up to date on the latest industry news.
(3) Sponsor, register for and attend our Annual Conference to visit with congressmen, meet industry counterparts, show your face to international regulatory leaders and bring home lessons on how government action impacts your business’ future.
(4) Respond to the annual member survey, as well as the “quick questions” we ask every month. Your feedback shows what is important to you and prepares ARSA to fight for it.
(5) Recruit new members! Each one earns you a discount on your dues. In fact, scout enough rookies and your membership is free.
(6) Actually use your member benefits – These include access to model publications, discounts on training, and the right to Ask ARSA First! By taking full advantage of your member benefits, you’ll score a return on investment every year.
Like any boxer worth his salt, everyone who benefits from ARSA’s good work must pay their dues. This year let’s put in the effort to keep our stance strong as we generate the power and defensive skills to continue our mutual winning streak.
2022 ARSA president | NORDAM assistant general counsel and corporate secretary
October 4, 2021
In this edition…
Here We Go
The arrival of fall brings seasonally flavored coffee drinks, harvest-focused family activities and the ramp up of global aviation policy activity. This edition of the hotline won’t provide ARSA’s position on pumpkin-spiced lattes, but it will review a busy September of engagement on behalf of the maintenance community.
Since there was so much to report about September’s work, this “hotline highlight” directs readers to their own editions to check out four different updates (though you should read it all!):
From the “On the Move” section…
A Talent Showcase
The 2022 Aerospace Maintenance Competition will be held in conjunction with MRO Americas from April 25-28 in Dallas, Texas. The AMC provides an opportunity for current and future maintenance professionals to showcase their abilities and offers industry employers a chance to support and benefit from the skill and competitive spirit of these professionals.
From the “Training” section…
Thinking Simpler on IA Renewal
For several years, ARSA has been encouraging the FAA to streamline its procedures related to Inspection Authorization renewal course acceptability. In September, the agency began accepting comments on a draft Advisory Circular — a chance for public engagement in pursuit of sensible acceptance.
From the “ARSA Works” section…
CMT Expands ARSA’s Global Reach
One of the ways the association engages with industry and regulators to iron out problems in bilateral relationships is by participating in regular meetings of the Certification Management Team.
September 7, 2021
In this edition…
The Right Tools
From helping the FAA build a research database to making smart personnel decisions to navigating new international regulatory structures, this edition of the hotline shows how ARSA makes good on your investment.
From “Quality Time”…
Editor’s note: The views and opinions expressed by contributing authors do not necessarily state or reflect those of ARSA and shall not be used for endorsement purposes.
“Like Google for Regulations”
By The FAA DRS Development Team
What do the letters DRS mean to you? The FAA hopes they will come to mean quite a lot (and asks for your help in the process).
The Dynamic Regulatory System is going to turn some heads. DRS is a comprehensive knowledge center that combines an ever-expanding number of document types from more than a dozen repositories into a single searchable application. It will keep growing.
Bottom line: When you’re researching the aviation safety rules, DRS will isolate what you need in moments, not hours.
“This is a win across the board: for AVS, FAA, and for all of aviation,” said Ali Bahrami, Associate Administrator for Aviation Safety at the time of the system’s release. “Building DRS has been a huge undertaking. We reached beyond AVS to our global aviation partners. There’s a vast diversity of the kinds of jobs we do—and the kinds of information each of us looks for. DRS is a tailor-made solution for individuals as they do their own regulatory research. It’s like Google for aviation safety.”
DRS is a treasure trove. It centralizes aviation safety rules and related guidance. It includes all information found in the Flight Standards Information Management System, the agency’s Regulatory Guidance Library and more than a dozen other information sources. Information is updated every 24 hours.
Search results include links among and between CFR sections and related guidance or supporting documents – more than two million are available for search via a complex search engine. Users can make basic searches or construct advanced queries, applying a variety of filters to browse pending, current and historical versions of all documents.
In a word, DRS never gets old.
“The system represents a giant step forward in providing consistency and standardization of regulatory interpretation,” said DRS Program Manager Pete Devaris. “Research projects that used to take days of effort now can be done with a few clicks and in a matter of minutes.”
Making good on that giant step demands taking further steps. The system’s initial operating capabilities far exceed the requirements set by congressional mandates for DRS development, but there is much to be done. The FAA needs ARSA members’ help – along with the support of the entire aviation community – to improve the resource. As the agency adds features and functionality, it needs feedback right now:
(1) Make sure drs.faa.gov is bookmarked on every computer in your facility and a regular stop for regulatory compliance questions. (EDITOR’S NOTE: The authors encourage you to make the DRS your first stop for questions, but graciously accepted the association’s reminder that members should “Ask ARSA First.”)
(2) Carefully review instructions available at drs.faa.gov/help.
(3) Every time you use the system, consider the experience. How could it be better? Submit thoughts by clicking on “DRS Feedback” on the top banner of the site and submitting the form.
The Dynamic Regulatory System is a comprehensive knowledge center of regulatory compliance material from the FAA Office of Aviation Safety. Get started with the DRS by visiting drs.faa.gov.
July 2, 2021
In this edition…
ARSA’s work is about making connections, not just between regulatory requirements and business needs but between people. From changes within its own team to distributing government resources to reporting back on event presentations, this edition of the hotline demonstrates how those relationships are made and maintained.
From the “Membership” section…
A Member Asked…A Blind Umpire?
Q: Are you aware of a vision test, (e.g., Jaeger #2) requirement for maintenance personnel other than those performing NDI/NDT or Welding tasks?
I can find requirements for flight personnel (part of medical certificates), industry standards for welding inspections and have located AC 65-31 for NDI persons, but I am unable to find a regulatory requirement for persons performing visual inspection during maintenance.
We have local policies that require inspectors to have vision tests, but I trying to run down any regulatory requirements.
A: There are no direct requirements—the regulatory hooks that ultimately require maintenance personnel to have good eyesight are:
Section 145.155 that requires inspectors to be:
(1) Thoroughly familiar with the applicable regulations in this chapter and with the inspection methods, techniques, practices, aids, equipment, and tools used to determine the airworthiness of the article on which maintenance, preventive maintenance, or alterations are being performed; and
(2) Proficient in using the various types of inspection equipment and visual inspection aids appropriate for the article being inspected.
It is hard to be proficient in using the equipment and “visual” inspection aids without having good eyesight!
Another regulation (that applies to all maintenance personnel) is § 145.163 that requires the training program to ensure persons are capable of performing assigned tasks. While physical capabilities (eyesight) are not “training,” it is hard to argue that a person with bad eyesight is capable performing maintenance tasks, let alone be an inspector…although umpires may be blind (HA).
With respect to “normal” MRO personnel; the general requirement for all repair station personnel is found in section 145.151(b), which states that a repair station must “provide qualified personnel to plan, supervise, perform, and approve for return to service the maintenance, preventive maintenance, or alterations performed under the repair station certificate and operations specifications…” (Emphasis added.)
I don’t know how one would provide “qualified” personnel if they did not have necessary physical attributes – lifting 50 pounds, being flexible enough to maneuver appropriately for the work required, etc. Again, while this may not be a direct requirement for adequate eyesight, it certainly falls within ensuring proper qualifications are set forth by the certificate holder.
On the pragmatic side, it seems checking a person’s driver’s license, could be used to verify that the person can perform general maintenance tasks and verify that task was performed properly, provided s/he uses any “corrective lenses” noted on the license.
June 8, 2021
In this edition…
Turning Back Time
As parts of the world (hopefully) emerge from the pandemic, certain storylines have begun to reappear. From celebrating history to workforce challenges to restarting personal engagement with Congress, this edition of the hotline shows how ARSA makes progress in familiar ways.
From the “ARSA on the Hill” section…
Workforce Is Priority for Proposed Aviation Advancement Center
Senators Jim Inhofe (R-Okla.) and Tammy Duckworth (D-Ill.), longtime champions for U.S. aerospace jobs, are leading a new effort to strengthen America’s 21st century aviation workforce.
On May 21, the senators introduced a bill to create a National Center for the Advancement of Aviation (NCAA), which would “serve as a national, independent forum to facilitate collaboration and cooperation between all sectors of aviation and aerospace stakeholders and related partners, with a particular focus on aviation and aerospace workforce development.”
The legislation (S. 1752) directs the NCAA to:
- Promote development of a well-qualified, well-trained civil and military aviation and aerospace workforce.
- Research and develop new aviation and aerospace training materials and products.
- Coordinate the dissemination of grants for the development of aviation and aerospace oriented high school STEM education curriculum.
- Facilitate collaboration between institutions of higher education or other research institutions engaged in aviation, aerospace or related research or technical development.
Senators Cindy Hyde-Smith (R-Miss.), Marco Rubio (R-Fl.) and Ron Wyden (D-Ore.) joined Inhofe and Duckworth on the bill as original cosponsors. Rep. Andre Carson (D-Ind.) introduced parallel House legislation (H.R. 3482) on May 26 with nine cosponsors, including House Aviation Subcommittee Chairman Rick Larsen (D-Wash.).
The legislation has been endorsed by ARSA, as well as member companies AAR, HAECO Americas, StandardAero, ST Engineering North America, STS Aviation Group, Triumph Airborne Structures and the Wencor Group, among others.
The strong industry and bipartisan support bode well for the legislation, which may be included in larger infrastructure package later this year. In the meantime, please use ARSA’s grassroots action site – presented by Aircraft Electric Motors – to send pre-prepared message to your elected representatives urging them to support the bill. It’s quick and easy. Just go to arsa.org/congress.
May 11, 2021
In this edition…
This edition of the hotline serves as the official release of ARSA’s Model Repair Station & Quality Manual Compilation. Learn what that means and how the compilation – and its authors – can serve your business.
From the Lead…
Manual Transmission Comes Standard
By Brett Levanto, Vice President of Operations
An email subject line from ARSA Executive Director Sarah MacLeod inspired this article announcing the association’s comprehensive repair station documentation system.
MacLeod’s message delivered a complete documented compliance system to a client of ARSA’s management firm for submission to the FAA in support of a repair station certificate. The subject line “Manual Transmission” described the email’s purpose and read like a reference to a car’s stick shift.
Driving a manual transmission demands attention, knowledge and understanding of the car’s machinery. While “sticks” no longer come standard on new cars and aren’t even available on many common models, they provide an apt metaphor for the development of a company’s repair station, quality, forms and training manuals as well as supporting documentation and resources: Your hands, energy, and awareness must be directly and constantly involved to make it work.
After more than a year of intense scrutiny, ARSA has finished its overhaul of the documents available for purchase by repair station applicants and certificate holders. The association’s original Model Domestic Repair Station and Quality Manual, along with its various supplements and supporting tools, had helped countless applicants and certificate holders since its initial release in 2003. With changes in the FAA’s oversight system and years of helping members (and clients) customize the available documents, the time was right for a complete redevelopment.
The resulting compilation is a system for not only showing compliance but enabling applicants and certificate holders to continually improve efficiency and manage economic realities. In the true spirit of “manual transmission,” purchase of the comprehensive compliance system includes consultation with ARSA’s experts to help customize the documents. However, at either the “basic support” or “full customization” level, the purchaser must be hands-on and drive the process: At least 60 hours of hard work by the applicant or certificate holder is needed to fully realize the benefits. For the documents to “work” (i.e., to comply with the rules, meet business needs, and actually be followed by employees) direct involvement by the company is required.
The results of the effort can be reviewed, and members can still receive the revamped Forms Manual and forms as a free benefit by visiting arsa.org/publications.
Regardless of the options you select when purchasing an ARSA model manual, a hands-on manual transmission always comes standard.
April 6, 2021
In this edition…
While the recordings made during the 2021 Annual Conference will carry on the voices of participants, their work will live on – like the memory of old friends and mentors – because of the long-term determination of ARSA and its team. This edition of the hotline chronicles the event and presses on towards the next one.
From “2021 Economic Outlook”…
Cautious Optimism for 2021 and Beyond
For more information about the Annual Conference, including access to recordings and other resources produced during the event, visit arsa.org/conference.
The annual rollout of the Oliver Wyman/ARSA MRO market forecast in conjunction with the ARSA Conference is a must-attend event for industry leaders, reporters and policymakers interested in the aviation maintenance economic outlook. However, the release of this year’s report took on new importance as repair stations to recover from the most challenging business conditions in the industry’s history.
Oliver Wyman Vice President Tom Cooper presented the report during 2021 ARSA Conference’s Legislative Day on March 10. His general assessment was that, while it will take some time to recover to pre-pandemic business activity levels, 2021 will be a much better year for the maintenance industry than 2020.
It could hardly be worse.
According to Oliver Wyman, global demand for maintenance services fell from $82.9 billion in 2019 to an estimated $50.3 billion in 2020, a 40 percent drop. Cooper said that at the height of the disruptions in the spring of 2020, global air travel demand and aircraft utilization were off by 80 percent and 75 percent respectively from prior years. 2020 was also the first time in modern commercial aviation history that the industry experienced a year-over-year decline in the active global commercial fleet size with 57 percent fewer new aircraft deliveries and twice as many aircraft retirements than in recent years.
According to Cooper, the worst is behind us and, if current positive trends continue, global demand for the active aircraft fleet is expected to fully recover by the first half of 2022 and maintenance demand will reach pre-COVID levels by second half of 2022.
However, there is still considerable uncertainty in the forecast, particularly when it comes to air carrier maintenance activity. Cooper discussed the four factors that will drive airline recovery: epidemiological timeline(whether and how the pandemic is constrained), traveler sentiment (whether people feel safe getting on aircraft), government restrictions (whether visitors will be freely welcomed from other countries) and macroeconomic conditions (whether the direction of the global economy will support a rebound in leisure and business travel).
Under Oliver Wyman’s most optimistic scenario, the global maintenance industry could grow to $117.6 billion per year by 2031. That assumes continued progress with vaccine distribution and a return to pre-COVID passenger demand levels by the end of 2022. If there are problems with vaccine distribution and/or efficacy or if the global economy fails to rebound, demand for maintenance services could be $15 billion lower than anticipated by the end of the decade.
The economic downturn took a significant toll on the industry’s workforce. An ARSA report released in mid-2020 determined repair stations had lost of quarter of their workforce to layoffs and furloughs in the first half of last year. However, with recovery taking hold, the industry workforce has rebounded slightly and is still an important driver of the U.S. economy. Oliver Wyman estimates that there are 273,000 Americans currently working in the maintenance sector (down from 296,000 pre-pandemic). Of those, two-thirds work at repair stations, 22 percent work for aircraft parts manufacturers and distributors and 11 percent are employed as airline mechanics.
“After an incredibly difficult year, ARSA members we’ve spoken to are generally optimistic about the future,” ARSA Executive Vice President Christian A. Klein said. “But as demand for maintenance services picks up, repair stations are once again facing a technical talent shortage, which we expect to be even more acute than it was pre-pandemic. After a year of just trying to survive, companies are having to pivot quickly back to recruitment and workforce development. It’s definitely causing some whiplash.”
The 2021 report’s executive summary and Oliver Wyman’s Interactive Forecast Dashboard are accessible at arsa.org/news-media/economic-data. The full report is available exclusively to ARSA members free on request. A recording of Cooper’s presentation is available to conference registrants via the event’s Online Meeting Organizer.
2021 Global Fleet & MRO Market Assessment
prepared by Oliver Wyman
November 6, 2020
In this edition…
“Brave New World”
As Americans acted out their “voting plans” in the U.S. presidential election, ARSA’s work on behalf of the global aviation industry continued apace. Regardless of the political winds, the association’s work in October demonstrated that it stays on course.
From the “Legal Brief”…
Lawyers Ruin Everything…Except When They Don’t
By Christian A. Klein, Executive Vice President
Last month’s hotline described ARSA’s efforts (via the pro-bono services of Obadal, Filler, MacLeod & Klein (OFM&K)) to intervene in two National Transportation Safety Board (NTSB) cases involving FAA’s incorrect application of repairman certification rules (see “FAA Running Scared from Repairman Case Intervention”, “Legal Brief: Lawyers Ruin Everything” from last month and get an update with “NTSB Denial is Beside the Point” in this edition).
ARSA and the law firm could have added valuable insights to the proceedings, particularly about the plain language of the regulations and contradictory guidance material. However, despite the cases’ broad impact on ARSA members and their employees, the administrative law judge declined to let the association become a party because the FAA’s lawyers objected. Rather than trying to get to the right answer, the focus was on procedural issues, a classic case of process overwhelming justice.
Sarah referenced the influence of the fictional character Perry Mason on her decision to pursue a legal career. My early inspiration was the movie “Twelve Angry Men”, which underscores the point that everyone involved in the legal system is a human being that can make mistakes resulting in dreadful miscarriages of justice. The best way to avoid miscarriages of justice is to avoid legal proceedings; that is why “prophylactic lawyering” is needed.
“Prophylactic lawyering” means understanding your legal and regulatory obligations so little problems do not metastasize into big ones and, even worse, enforcement or criminal cases. More importantly when you do get caught up in legal proceedings, those early protective measures result in better outcomes.
With that in mind, here are some things to keep in mind when working with members of the Bar to ensure prophylactic measures achieve the desired result…
Members can read Christian’s guidance in this edition of the hotline.
October 2, 2020
In this edition…
On all fronts of ARSA’s work, September provided ample evidence of how the association does what it does. For the discerning reader, there’s even exploration of why it does it all in the first place.
From the “Legal Brief”…
Lawyers Ruin Everything
By Sarah MacLeod, Executive Director
My first hero was Perry Mason; not only was the character a strong advocate, but he ensured justice always prevailed. Even the prosecutors supported the defense’s requests to bring the guilty party forward. The belief that the legal system brought justice drove me to volunteer at a public defender’s office. There I learned very valuable lessons about lawyers and the “practice” of law.
First, not all clients are innocent. There are some really bad folks out there and a defense attorney must put aside any thoughts of justice – the legal system is about the law and the accused party has a right to be represented no matter how reprehensible.
Second, everyone involved in the legal system are human beings that will make horrible mistakes, will stand by those errors and will not serve justice when silence is available. The saga of Richard Jewel illustrates that point.
Those lessons drove me to law school, where I learned even more about my chosen profession.
Members can read about what Sarah learned and how those lessons drive ARSA’s work in this edition of the hotline.
September 4, 2020
In this edition…
The Repairman Issue
In late August, ARSA took new action to pursue a decade-old goal: Reasonable enforcement of the repairman certificate requirements of 14 CFR part 65, subpart E. This edition of the hotline covers the issue from every angle while providing other key updates from the last month.
From the “Membership” section…
A Member Asked…
Q: My question is in regards to 14 CFR part 65, specifically § 65.101(a)(5) that indicates that the individual applying for a repairman certificate must have at least 18 months of practical experience in the procedures, practices, inspection methods, materials, tools, machine tools, and equipment generally used in the maintenance duties of the specific job for which the person is to be employed and certificated.
Let’s say I would like to be an inspector. Is it safe to say that I must have 18 months of practical experience in the procedures, practices, inspection methods, materials, tools, machine tools, and equipment generally used by inspectors? Or am I interpreting the eligibility requirements incorrectly?
A: Let’s get you on the right slalom course, then we can get you through the correct gates in the right order:
You do not need a repairman certificate to do inspections under the repair station certificate, the individual assigned those duties, responsibilities and authorities by the repair station needs to be qualified under section 145.155, which includes being:
- Thoroughly familiar with the applicable regulations in this chapter and with the inspection methods, techniques, practices, aids, equipment, and tools used to determine the airworthiness of the article on which maintenance, preventive maintenance, or alterations are being performed.
- Proficient in using the various types of inspection equipment and visual inspection aids appropriate for the article being inspected.
- Able to understand, read, and write English.
If the job position the repair station assigned includes the duties, responsibilities and authority to either supervise (§ 145.157) or approve work for return to service (§ 145.153), one of the qualifications for persons required to direct maintenance and/or to oversee persons unfamiliar with their tasks and/or to approve work for return to service for the repair station is to hold an appropriate part 65 certificate, that is either a repairman or mechanic certificate.
When a repair station recommends an individual for a repairman certificate, the air agency certificate holder must ensure the person is qualified under § 65.101. That section, as you note, requires the employer to ascertain (usually through the assessment made under the Training Program Manual and reference to the duties, responsibilities and authorities set forth in the RSQM for the position) whether the individual is:
- Specially qualified to perform maintenance on aircraft or components thereof, appropriate to the job for which he is employed.
- Employed for a specific job requiring those special qualifications.
After which the employer completes the Employment Summary (since inspectors, supervisors and persons authorized to approve work for return to must be on the Repair Station Roster). Based upon that information, the employer recommends the employee for certification.
The evaluation by the employer should determine that the person has at least 18 months of practical experience in the procedures, practices, inspection methods, materials, tools, machine tools, and equipment generally used in the maintenance duties of the specific job. If the person does not, the employer would ensure the individual completed training through the FAA-approved Training Program Manual procedures since that should certainly qualify as formal training that is acceptable to the Administrator.
Member questions should be submitted directly to the association’s team via arsa.org/contact.
August 7, 2020
In this edition…
Knowledge is Power
July continued the pandemic-infused onslaught of tough-to-cope-with information. “Grim” survey response data. The re-emergence of threatening legislation from the U.S. Congress. More challenges in managing regulatory impact. ARSA’s work is focusing its knowledge into effort.
From “ARSA on the Hill”…
House T&I Committee Reports Anti-Repair Station Bill
On July 29, the House Transportation & Infrastructure Committee reported the Safe Aircraft Maintenance Standards Act (H.R. 5119). Dubbed “the anti-repair station bill,” the legislation would cause significant disruptions for the global aviation maintenance industry, U.S. air carriers, passengers and cargo shippers, general aviation operators and aerospace manufacturers. ARSA is leading a coalition of 10 organizations to defeat the legislation.
Given that H.R. 5119 was approved by the House T&I Committee last November, it’s unclear why the House T&I Committee leaders have chosen this moment to report it to the full House. The bill has been added to the Union Calendar, which means it is ripe for consideration on the House floor. Adding fuel to the fire, detrimental repair station language was included in the second major coronavirus relief passed by the House earlier this summer, so its clear that anti-repair station lawmakers and their union allies are determined to impose new restrictions on contract maintenance. ARSA opposes using regulatory policy and false safety arguments to achieve labor’s economic objectives. H.R. 5119 would make it even harder to recover the present economic crisis.
What you can do to help prevent H.R. 5119 from becoming law? Visit arsa.org/legislative/hr5119-actioncenter.
July 2, 2020
In this edition…
Hotline readers should be quite familiar with ARSA’s commitment to learning and growth. In addition to the association’s commitment to training resources, its team constantly utilizes feedback and insight from its members. This month’s edition shares ongoing lessons of pandemic response, seeks input regarding event planning (Get the 2021 Conference on your calendar!) and teases some new projects
From the “Membership” section…
Under Construction – ARSA Publications Overhaul
One of the key benefits for the ARSA team and its members is development and access to model manuals, programs and supplements designed to assist companies with regulatory compliance. Anyone who visited the publications webpage in June noticed that ARSA’s most important models are not available for purchase or download.
Don’t panic: This is good news.
The ARSA team is currently overhauling its model repair station, quality, training program and forms manuals and related documents. When this update is complete, new versions will be available from the association.
During the overhaul of the part 145 documents, the other tools available only to ARSA members, e.g., the Working Away Advisory, Repair Station Security Resources, remain accessible. Each model or template is maintained and improved by the association based on industry experience, agency guidance and plain-language interpretation of regulatory requirements.
If you need assistance development or correcting repair station documentation, contact ARSA for more information and possible assistance by its management firm, Obadal, Filler, MacLeod & Klein, P.L.C.
June 5, 2020
In this edition…
This edition of the hotline demonstrates how the attention of ARSA’s work remains focused on continual stakeholder engagement and commonsense tools for managing business and government.
From the “Membership” section…
Asking Again – A New Survey for 2020
ARSA is conducting this survey to gather information about the impacts of pandemic-related economic disruptions on the maintenance industry. In addition to helping the association focus its resources, your responses will help support advocacy for repair stations. Some of the questions are the same as those included in ARSA’s 2020 Member Survey earlier this year, but many are related specifically to the pandemic.
Please complete this survey even if you completed the 2020 member survey.
The survey has 23 questions and should take between 10 and 15 minutes to complete. Responses are confidential and are reported only in an aggregate format. Open-ended responses will not be attributed to you. If you have any questions, please contact ARSA at firstname.lastname@example.org.
Note: The survey closed on July 2, 2020. If you have questions about response data or pandemic impacts, contact ARSA.
May 4, 2020
In this edition…
The New Normal?
What will the “new normal” will look like for global industry? On both new fronts and old, ARSA continues is activism on behalf of good business, good government and good safety.
From the “Legal Brief”…
Apply, Don’t Run Out of Cash – Tapping into Federal Relief
By Al Givray, Partner, Davis Graham & Stubbs LLP
The following analysis was prepared for ARSA by Al Givray, law partner at the law firm of Davis Graham & Stubbs in Denver, Colorado, and general counsel to The NORDAM Group LLC in Tulsa, Oklahoma. He can be reached by email at email@example.com. You can learn more about Mr. Givray’s experience at: www.dgslaw.com/what-we-do/industries/aviation and www.nordam.com/who-we-are/leadership.
To keep tabs on all of ARSA’s work related to the current pandemic, visit arsa.org/anti-viral-measures.
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.
The rollout of the Small Business Administration’s (SBA) Paycheck Protection Program (PPP) has been rocky (some would call it a disaster). The initial pool of cash allocated by Congress was quickly exhausted – in some cases disbursed to, and subsequently returned by, companies amid bad publicity – and then replenished, requiring many applicants to “re-enter” the line for relief.
For aviation businesses too large for the PPP (500 or more employees or larger than the applicable SBA small business size standard) or otherwise not eligible (e.g., affiliation rules), there is aid money available from the U.S. Treasury Department and Federal Reserve. There are restrictions and equity winds to navigate and some deadlines have passed (don’t despair); but financial resources for many outside the SBA universe are and will be accessible.
To see Givray’s complete analysis, which builds off his original content published publicly on ARSA.org and utilizes the most-recent guidance regarding Treasury Department and Federal Reserve administration of relief programs, members should check out this month’s edition of the hotline. Can’t find it in your inbox? Contact ARSA to see why. Can’t wait? You can access the edition via the association’s online portal (look for the “badge” on your home screen after login).
April 4, 2020
In this edition…
What Hasn’t Changed
The world seems completely different than it was when the last edition of the hotline was delivered. While a lot has changed, ARSA’s commitment to serving the aviation community never will. This month, review coverage from the 2020 Annual Conference and catch up on the association’s efforts to provide pandemic resources and relief.
From the Membership section…
A Member Asked…
Q: First off, great job of keeping everyone informed over the past several weeks. We would truly be flying blind without you.
I am trying to figure out what the big relief bill [The Coronavirus Aid, Relief and Economic Security (CARES) Act] means for our company and want your additional perspective.
What procedures do we have to follow in order to apply for assistance under the law?
Thank you again for your guidance, advocacy, and continuing support.
A: The association’s Anti-Viral Measures page is being updated regularly with information on the various programs, departments and implementation measures. While the association is certainly not providing legal, tax or other financial or professional advice in this arena, the general approach would be to determine which of the many “relief” programs are applicable.
So you may start with determining if you are a small business—to ferret that out use the NAICS Identification Tools to review each description in detail – while the general description uses the term “manufacturing,” many of the codes include “overhaul” and other maintenance activities.
|Aviation Maintenance Related NAICS Codes and Small Business Size Standards|
|NAICS Code||General Description||Small Business Size Standard|
|336411||Aircraft Manufacturing, including “overhaul”||Fewer than 1,500 employees|
|336412||Aircraft Engine and Parts Manufacturing, including “overhaul”||Fewer than 1,500 employees|
|336413||Other Aircraft Parts and Auxiliary Equipment Manufacturing||Fewer than 1,250 employees|
|488190||Other Support Activities for Air Transportation||Less than $35 million in annual revenues|
Next, review your current financial situation with appropriate tax, financial, business and legal professionals to determine which loan or relief provision(s) will be best for your company and employees.
The general descriptions of the possibilities provided by ARSA is not a substitute for careful review and consideration of any “Catch-22” elements that always come with “help” from the government!
For a review of CARES Act implementation so far, see this month’s Legal Brief.
February 7, 2020
The Conference, the Conference and the Conference
The association’s broad work on behalf of the maintenance community was in full swing in January (not that it had slowed at all at the end of 2019). Across all of ARSA’s departments, which are reflected in the hotline’s sections, the many issues and actions are bending towards convergence at the 2020 Annual Conference from March 10-13.
From the “Membership” section…
Showing Class – CRT University Begins First Semester
On Jan. 24, ARSA Member and 2020 Conference Gold Sponsor Component Repair Technologies (CRT), of Mentor, Ohio, launched the first semester of CRT University, an onsite associate degree program in partnership with Lorain County Community College (LCCC). CRT and LCCC have developed a program specifically tailored to employees who are interested in obtaining a technical degree while leveraging the knowledge and expertise gained through employment and on-the-job experience.
The inaugural class includes ten current CRT employees who will take three classes per semester towards an Associate Degree of Applied Science in Mechanical Engineering Technology. The program will take roughly three and a half years to complete and all classes will be taken either online or onsite at CRT. Employees in the program are paid for their time in class and the full cost of tuition is covered by CRT. Onsite courses will be taught by CRT employees who have undergone a process to become adjunct faculty of LCCC.
“We could not be more excited about the launch of CRT University” says CRT Human Resources Manager John Gallagher. “We think this is a huge win for CRT, our employees and Lorain County Community College. This type of collaboration benefits everyone involved. CRT employees who might not otherwise utilize tuition assistance can further their educational path right in the workplace. LCCC can partner with a business two counties away and CRT employees with a desire to teach can become adjunct college professors in their current workplace. It’s amazing when you step back and realize how many barriers have removed here.”
“In our industry we are constantly training and evaluating the team to make sure we are adhering to quality standards while also arming our workforce with the skills they need to succeed. What makes CRT University unique is that we are not just meeting traditional employee development needs, we are combining the full force of an accredited university with real world practical application. Employees will expand on the skills and competencies they are already using, learn the principles behind them and be able to immediately apply what they learn.” said Cory Hutter, training supervisor.
To learn about another program at CRT – S.O.A.R. – launched last year to work with job candidates and parents, you can read about it in the May 2019 edition of the hotline.
|Component Repair Technologies, Inc. (CRT) is an FAA certificated repair station specializing in gas turbine engine component repairs for air, land, and sea. Our wide variety of processes and skilled employees have positioned us as leaders in the aviation, industrial, and marine turbine component repair industry. CRT has built a reputation for quality and responsive service by providing precision turbine engine component inspection, repair and overhaul services for the world’s leading turbine engine manufacturers and major airlines since 1985. Visit componentrepair.com for more information.|
December 6, 2019
In This Edition…
Hostile Legislation, International Cooperation and Constant Motion
November 2019 was a busy month for the aviation maintenance community. In the United States, the specter of hostile legislative action became reality. Across the Atlantic, the long-awaited update to the U.S.-EU Maintenance Annex Guidance finally got published. Throughout this edition of the hotline, see the number of ways the association is managing these major issues – content for each covers almost every section of the newsletter – while continuing with the constant work of representing the international aviation maintenance industry.
From the “Membership” section…
ARSA Recognizes Retirements of Lynden’s Pull & Willing
On Nov. 22, ARSA helped to recognize the retirement of two colleagues from member company Lynden Air Cargo. Jeff Pull and Paul Willing have long been steadfast supporters of aviation safety and committed backers of ARSA’s work on behalf of the entire aviation maintenance community.
“When ARSA found out that two of our internal regulatory experts were retiring they dashed around to provide two awards, both of which are being presented for the first time tonight and I have the honor in assisting that presentation,” said LAC President Rick Zerkel during the ceremony held at the company’s facility in Anchorage, Alaska.
Since the association’s team had such fun procuring the necessary materials for each “award” and developing the script for their presentation – which Zerkel utilized – it is providing the entirety of that script for all of its members’ reading pleasure (Should you know someone getting ready to retire whom you believe is deserving of such recognition, let ARSA know):
Script for November 22, 2019 Presentation of “Golden Shovel” Award and Doctoral Degree in Regulatory B.S.
For those of you who may not know, LAC has for years been a member of a trade group in Washington, D.C. called the Aeronautical Repair Station Association. Although LAC is not a repair station, we belong because of two lawyers – Sarah MacLeod and Marshall Filler – that help the company navigate the slalom course of aviation safety regulations.
Sarah and Marshall’s firm provides discounts to association members, which makes membership financially valuable for LAC. Beyond that, Sarah uses ARSA as a platform to practice what she calls “prophylactic lawyering,” which helps keep the entire aviation industry out of trouble and has made our 19-year connection to the association a business imperative.
When ARSA found out that two of our internal regulatory experts were retiring they dashed around to provide two awards, both of which are being presented for the first time tonight and I have the honor in assisting that presentation.
The Golden Shovel Award – Jeff Pull
On ARSA’s behalf, I present Jeff Pull with the association’s first-ever “Golden Shovel” award for service to the maintenance industry.
This award has long existed only in the mind of ARSA’s Executive Director Sarah MacLeod and in discussions among and between the association’s team members. It represents the years of “shoveling” that must be done by any determined aviation professional in order to stay in business and ensure aviation safety while surviving the whims of regulators, inconsistency between the plain language of the rules and their implementation and the constant struggle to make sense of it all.
At best it feels like shoveling against an incoming tide and hoping to keep the water beneath your chin.
At worst it feels like shoveling someone else’s manure – plenty of which flows out of Independence Avenue in Washington, through regions and districts across the country and onto the desks, workbenches and repair shop floors of maintenance professionals – and finding yourself consumed by the mess.
While many have undertaken this effort, only the very best see it through for a career in continued commitment to good aviation safety and good business sense. The “Golden Shovel” could not be made real until today, with the retirement of a member of the industry whose career demonstrated the dedication worthy of its gleaming handle. It is in recognition of Jeff’s tireless shoveling on that we can bestow this award.
Jeff, wear this pin, whose true meaning will be unknown to most who see it, with pride.
The Doctoral Degree in Regulatory B.S. – Paul Willing
On behalf of ARSA, I confer upon Paul Willing the association’s highest degree: A doctorate in regulatory B.S.
While no academic accrediting body or government regulator has yet had the insight or courage to bestow on ARSA the authority to confer degrees, the association has taken upon itself the right to recognize and rightly honor those who have—
(1) Successfully completed the required course of study – presented every day by the university of professional life, and
(2) Accumulated the compulsory practical experience to survive the often maddening and frequently comical FAA regulatory slalom course.
Though ARSA’s regulatory experts are currently all legal professionals holding their own Juris Doctor degrees, the team recognizes the need to honor Paul’s attainment of these standards with the true Ph.D.: “Piled Higher and Deeper.” As we’ve already recognized the considerable shoveling necessary to survive in this industry, a professional with the experience and mastery of Paul surely has accumulated his own considerable pile.
Given the importance of credentialing in both academic and professional interests, not to mention personal pride, we trust you will display your newest degree for all to see.
Congratulations to Jeff and Paul
The joy of recognizing Jeff and Paul’s retirement is dimmed only by the knowledge of the deep loss represented by their departure. Their life beyond work has been well earned, but ARSA’s team recognizes their precious value to the aviation industry, the maintenance community and the general public throughout their long careers. Jeff’s “Golden Shovel” and Paul’s “Ph.D.” will hopefully bring smiles to their faces for years to come, a small “thank you” on behalf of the association, it’s team and the many people who depended on their good work.
November 1, 2019
From the “Regulatory Update”…
MMT Meeting – MAG Change 7 Signed, Mutual Recognition Progress Slowed
This year’s Maintenance Management Team (MMT), comprised of the civil aviation regulatory authorities of Brazil, Canada, the European Union and United States met in Cologne, Germany during the week of Oct. 21. The MMT and its sister quadrilateral group, the Certification Management Team (CMT) focus on issues of common interest to the four authorities while recognizing that any formal changes to existing aviation safety agreements occur bilaterally.
For that reason, the MMT authorities spent most of the week engaged in various bilateral maintenance discussions. This was followed by an industry-authorities preliminary meeting on Oct. 24 to review the agenda for “industry day” which occurred on Oct. 25.
Industry representatives and the authorities updated attendees on:
- MMT action items (from the meetings in Ottawa and Brasilia in 2017 and 2018).
- MMT governance and collaboration strategy.
- Status of the ICAO airworthiness panel’s efforts in support of mutual acceptance by authorities of various maintenance oversight activities.
- FAA regulatory situation relating to mutual recognition of approved maintenance organizations.
- Status of SMS programs (both mandatory and voluntary).
- Authority briefings on the status of its bilateral agreements with the other MMT regulators.
Regarding mutual recognition of approved maintenance organizations (AMOs) among the MMT authorities, ARSA and its industry colleagues were disappointed to learn that the FAA has no immediate plans to amend its regulations to allow the agency to enter into U.S.-Canadian-style bilateral maintenance agreements with other authorities.
The agreement with Canada, authorized in 14 CFR §§ 43.3, 43.7 and 43.17 and the FAA-TCCA Maintenance Implementation Procedures (MIP), allows work to be performed by maintenance providers in both countries on articles subject to their respective jurisdictions without the need for a separate certificate. Therefore, no fees apply as they do between the United States and Europe. Under the FAA-TCCA agreement, AMOs and certificated individuals work under the regulations of their geographic authority and only a few special conditions apply to component maintenance providers. Industry strongly supports having a similar arrangement adopted by the FAA and EASA, but it cannot occur without a rule change to 14 CFR (see § 145.53(b)). This is not the case in the EU because a bilateral agreement takes precedence over EASA regulations.
MAG Change 7
Of particular note was the announcement by the FAA and EASA that change 7 to the Maintenance Annex Guidance (MAG) had finally been signed. Although not yet posted on the FAA’s web site (stay tuned to ARSA for posting and comparison to change 6), it affirmatively addresses several issues of importance to ARSA and its members including the recognition that maintenance performed on U.S.-registered aircraft at FAA-EASA approved repair stations in the European Union does not require Form 8130-3 to document new parts. Such maintenance is not subject to the MAG because only a single FAA release is issued; unfortunately, the new regime only applies to aircraft maintenance. This issue was originally brought to the authorities’ attention by Gulfstream and while there was broad consensus that the aircraft manufacturer was correct, resolution got hung up due to the administrative delays in signing change 7, many of which were due to the FAA’s reorganization of its Flight Standards Service.
Another important MAG change embodied in change 7 addresses the procedure for approving articles for return to service when the design has only been approved by a single authority. This issue arose several years ago in the context of the Sukhoi Superjet because it has not been type-certificated in the United States. American component manufacturers needed a way to document work on those components but could not issue a dual release under the MAG since the FAA had never issued a type certificate for the aircraft. A work-around was developed to address the issue which will now be institutionalized in MAG Change 7. It will allow the issuance of single releases as more fully described in that document.
Unfortunately, there was no movement on the issue of documenting new commercial and commercial off-the-shelf parts. It appears that no further action will occur among the MMT authorities until EASA completes its parts documentation rulemaking (RMT.0018).
To follow ARSA’s coverage of MAG-related matters, visit (and bookmark) arsa.org/mag.
The next MMT meeting will occur in the fall of 2020 in Washington, D.C. In the meantime, ARSA and its industry partners will continue working the issues of importance to the international maintenance industry.
October 4, 2019
From the “Membership” section…
Service Spotlight – Erickson Earns Master Mechanic Distinction
The Charles Taylor Master Mechanic Award recognizes the lifetime accomplishments of senior mechanics and is named in honor of Mr. Charles Taylor, the first aviation mechanic in powered flight. Taylor served as the Wright brothers’ mechanic and is credited with designing and building the engine for their first successful aircraft. To be eligible for the award, nominees must:
- Hold a U.S. Civil Aviation Authority (CAA) or Federal Aviation Administration (FAA) mechanic or repairman certificate.
- Have 50 or more years of civil and military maintenance experience.
- Be a U.S. citizen.
- Have NOT had any airman certificate revoked. Revocation of any airman certificate will disqualify a nominee.
Erickson (the master mechanic) began his aircraft maintenance career in September 1969 at Big Bend Community College in Moses Lake, Washington. He has held numerous positions at Erickson (the company) since arriving as a Sikorsky S-64 crew chief in 1981. In the decade after completing school, he had served as a Sikorsky crew chief at Carson Helicopters, Boise Cascade Corporation and Siller Brothers. He joined ARSA’s board in 2002 and represented the interests of both helicopter and engine businesses for nearly two decades; he will complete his service to the association at this October’s annual meeting in Washington, D.C.
“50 years…a well-deserved lifetime achievement award,” said Marshall S. Filler, ARSA managing director and general counsel, when the association heard the news. “It is always gratifying when an ARSA member receives such an accolade. But when it’s one of the association’s longstanding board members and industry compliance leaders, it carries a special meaning. Congratulations, Chris and keep them Cranes flying!.”
By recognizing the industry’s most experienced and dedicated personnel, the master mechanic award showcases individual commitment and aviation excellence in general. This is a very important part of highlighting the career paths available for technical personnel and growing a sustainable workforce.
If you know a certificated mechanic or repairman with 50 or more years’ experience, get them nominated today.
From “ARSA on the Hill”…
Earp Aviation’s Arnett Sets the Pace for Industry Engagement
By Christian A. Klein, Executive Vice President
There’s an old saying: Give a man a fish and you feed him for a day; teach a man to fish and you feed him for a lifetime. That philosophy is at the core of ARSA’s advocacy work.
Yes, we’re zealous champions for repair stations with regulators, the media and elected officials, but we also spend a lot of time teaching members how to be better advocates for themselves. Recent examples include toolkits to help seek exemptions from FAA’s “current” data requirements under 145.109(d), file a complaint with the Small Business Administration about the FAA’s inconsistent enforcement of maintenance manual rules and contact Congress to get funding for the new aviation workforce grant program.
Encouraging engagement by ARSA members serves dual purposes. It makes you more effective advocates for your own needs while also expanding ARSA’s reach and impact. While it may sometimes be hard to remember given all the things ARSA does, we’re a small organization with a tiny (but extremely talented!) staff. Your engagement helps us punch above our weight class and demonstrate broad industry support for the association’s priorities.
While we’re sometimes disappointed when members fail to pick up the ball, it’s extremely heartening when they do. A case in point is Bob Arnett.
Tell Congress to Make Aviation Workforce a Priority
ARSA’s signature legislative victory in 2018 was convincing Congress to create a new grant program help repair stations recruit and train aviation maintenance technicians. Our priority now is getting the program funded … and we need your help. ARSA has completely revamped our grant program action center to help you learn more about the issue and urge your members of Congress to appropriate the money we need. It’s quick and easy. Take a second now the tell your elected represents to make aviation workforce a priority!
Bob’s been a fixture at ARSA events like our Annual Conference and executive summits for decades. He’s also always ahead of the game when it comes to organizing meetings on Capitol Hill during ARSA’s annual Legislative Day. In his capacity as vice president of quality at Barfield, Inc. in Miami and as a member of our government affairs committee, he helped coordinate numerous ARSA meetings with local industry leaders and congressional offices.
Bob recently moved from Miami to the Phoenix area to start a new repair station called Earp Aviation Repairs LLC. Lest there be any doubt about Bob’s commitment to engagement, one of the first things he did in his new role was invite his local congressman, senators, their staffs and other local officials to Earp’s grand opening.
That outreach and engagement doesn’t just help elected officials better understand how Bob’s company contributes to the local economy, it also helps raise the visibility of our entire industry with lawmakers by putting a local face on it. That, in turn, will make them more receptive and responsive when ARSA reaches out to talk about workforce, regulatory and other issues that impact its members. And it’s a good bet that when Bob calls those offices with a problem, he’ll get a quick response.
The maintenance industry is in a period of considerable political risk. The MAX 8 investigations are still underway and may lead to legislation that affects the whole industry. Hostility to free trade threatens the progress we’ve made to reduce regulatory burdens for approved maintenance organizations operating internationally. The new chairman of the House Transportation & Infrastructure Committee is a long-time contract maintenance skeptic. Repair station opponents on the Hill and their union allies have made noise about introducing hostile legislation. At the same time, there are opportunities, including securing full funding for the aviation technician grant program ARSA helped create as part of last year’s FAA bill.
With elections looming on the horizon, members of Congress and candidates are anxious to get to know businesses and their employees “back home”. Whether you’re an experienced political angler or want to learn how to fish, ARSA is the bridge over America’s troubled political waters that can help you connect.
Shoot me an email at firstname.lastname@example.org and let’s set up a congressional visit to your facility this fall.
Want to Learn More 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. In this critical election year, ARSA PAC has never been more important. But ARSA is prohibited from sending PAC information to members who haven’t opted in to receive it.
Please take a second to give us prior approval to talk to you about ARSA PAC. Doing so in no way obligates you to support PAC. It just opens the lines of communication.
Click here to give ARSA your consent today.
August 2, 2019
From “Sarah Says”…
Meet Me Halfway
By Sarah MacLeod, Executive Director
A member recently relayed a conversation with a FSDO manager that had him baffled and, for obvious reasons, concerned.
Constant misunderstandings between the assigned aviation safety inspector and the member’s quality department necessitated the accountable manager arrange a meeting with the FSDO manager to discuss outstanding issues and develop an understanding of the best way to move forward. During a discussion of one issue, the accountable manager was told very clearly that if the regulations did not require action…then no action was required.
Immediately after accepting that as fact and stating the matter was therefore closed as far as the company was concerned, the FSDO Manager accused the accountable manager of not “meeting the agency halfway.” The member was baffled by that conclusion—so he called ARSA and asked how can the agency “demand” the company meet something that is not required by the regulations? After being assured the government cannot enforce something that is not demanded by its laws or rules, we got down to how to salvage the relationship between the company and the agency.
The FAA and the industry have been doing a good job of “talking” about “culture change” for years with little change or success. The reason? Nobody demands regulatory compliance FIRST and “good business practices” or “better ways” second, third and fourth. The guidance material provided to the industry is years out of date and the “new” guidance is rarely based upon the plain language of the regulation. Heck, often guidance material is developed during the rulemaking process and never updated to reflect the final rule language! The “risk-based” oversight system was created from principles of the nuclear industry for cripes sake—an industry with maybe half-dozen viable designs. How that ever became the basis for the Air Transportation Oversight System (ATOS), the forerunner to the Safety Assurance System (SAS), has always been a mystery to me.
The industry works hard to “get along” with the agency’s representatives rather than clearly and succinctly stating how the applicant or certificate holder complies and asking the agency to tell it where compliance (as stated in the RULE) is lacking. All “going along to get along” does is enhance the “culture” to the point where we all have sour milk instead of yogurt or at least kefir! We feed the “what the hell can I do” attitude of industry and the arrogance of the FSDO manager that had the gall, yes, gall, to accuse a certificate holder of not “meeting the agency” halfway on something it could not require!
I (and therefore ARSA) take a different approach; rather than go to the agency with my hat in my hand asking for its “help” – I tell the agency how my people are or can comply with a particular section or paragraph of the regulations. I remind the agency of two very significant facts:
(1) It is not responsible for compliance, the applicant or certificate holder is.
(2) I did not write the regulations – we all did or should have – I am just showing compliance or providing a method of establishing compliance.
When asked why I (or the member or client) doesn’t want to do something that is not required by the rule, the question usually takes the form of: “Why are you against safety?” I answer that I (or my member or client) IS complying with the regulation. I can be sucked into senseless arguments, but I am rarely caught off-guard by questions that I have not thought about and/or to which I don’t have the legal or practical answer. I am not intimidated by the agency’s “threats” because I don’t hold a certificate; I started my relationship with the agency and the industry on the basis that I would not come to it with a problem and no solution. I do my research and use my “critical thinking” to develop facts and analyze those data against the plain language of the regulation – without embellishment or expectation except for the goal of regulatory compliance.
So, I am not humble or subservient to the agency and a certificate holder should not take that approach either; it just feeds the arrogant and ignorant culture that has prevailed for so many years and resulted in the comment from the FSDO manager that jumpstarted this editorial.
In the “you aren’t meeting the FAA halfway” case, facing reality straight on while changing the relationship between the parties, we worked up a polite letter to the FSDO manager clearly explaining all the steps the company had taken to “satisfy” the “local office” request to comply with the inspector’s “guidance” (yes, it was in the SAS oversight “elements). We (again politely) requested that the matter be closed with no further action necessary.
Although there has been no answer to the request, the agency is moving forward with other requests and I am hopeful that the letter was taken as having met the agency “halfway.” The company also promised to institute a much more formal approach to communication with the agency – no longer letting it dictate how communications take place. Everything important is put in writing, all written communication is sent in a manner that receipt can be verified. No more phone calls, no casual emails, etc. In other words, the company promised to control the elements that create professionalism and (hopefully) will stick to them throughout the years and changes in inspectors, frontline managers and managers. A significant culture change for a company that had always “gotten along” with its “local office” and did not feel the “necessity” to “be so formal.” Maybe it won’t stick, but if it doesn’t the company will at least have an understanding of how to put itself back in a more professional position.
In all other cases, I stick with a tee-shirt my husband (and his sons) bought me years ago: “Just Do As I Say And No One Will Get Hurt.” The only time I believe in meeting someone halfway is when the road is clear of unnecessary obstacles and unsupported opinions. A road to regulatory compliance that is based upon the SAS “elements” and oversight “requirements” does not meet that criteria.
Want to hear more of Sarah’s guidance for building a professional relationship with the agency? Invest an hour in ARSA’s online training session on dealing with the government, which is featured in the “Training” section of this edition and is at arsa.org/dealing-gov-training.
July 5, 2019
From the “Getting Facetime” section…
The ARSA Annual Conference – Catch a Glimpse
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. Catch a glimpse of the 2019 event and hear from some of its participants, then block your calendar for next March (and every one after that).
June 7, 2019
From the Lead…
Attention to Detail
By Brett Levanto, Vice President of Operations
This month, an ARSA online training user queried Executive Director Sarah MacLeod after completing “What is Acceptable to the Administrator? – The Performance Rules of § 43.13.” He contacted the instructor to contest the answer to question 26 on the test administered after the session:
True or False: A repair station must prepare and follow a repair station manual that is acceptable to the FAA.
We confirmed the caller was right (the answer was wrong), corrected the session materials, updated the syllabus and course information, re-loaded the materials and sent a note to all past attendees highlighting the correction. This happens from time to time: Training participants contact us with an issue with a session and we make corrections.
This time, it got us thinking. The session was recorded in 2016 and accessed hundreds of times. Nobody else noticed the error? Did some recognize the incorrect answer but not report it?
“Attention to detail” is a requirement in aviation and a standard to which ARSA holds itself (many an intern or job applicant has proclaimed to have it…only to find, the quality lacking under the association team’s standard). The focus on details does not eradicate failure, it enhances the responsibility to watch for, report and correct mistakes at all phases of an operation or objective. We hold ourselves, our members, our partners and our governments to high standards, often providing immediate correction to deviations.
The training team works hard to get everything right every time a session is created and posted. It’s what attendees need and deserve. With the association’s library approaching 100 sessions and new content being developed (including the Human Factors series and sessions supporting use of ARSA’s model manuals), there will always be opportunities to find errors.
We invite you to keep us attentive to the details needed to stay “smart, current and out of trouble” in your business operations and compliance activities.
How is your attention to detail? Put it to the test with a training session. Attendees have the enduring privilege of contacting instructors with questions and comments, and your help might earn you benefits for future sessions. Click here to get started.
What’s the right answer to question 26? Click here so you can find out.
May 3, 2019
From the Getting Facetime section…
Take It With You
Brent Webb, president of Aircraft Inventory & Management Services, managing partner at A.I. Intellectual Property and the so called “secret weapon” for newly-certificated CAVU Aerospace, is an active supporter of ARSA. He is a regular Annual Conference attendee, a reliable sounding board on industry issues and a ready champion for the association in his own travels.
Webb brought ARSA with him and put this commitment on the stage at ICAO’s 2019 Blockchain Aviation Summit and Exhibition in Abu Dhabi on April 4. During his presentation as part of a session on “How to adopt Blockchain,” he included ARSA in coverage of industry association involvement (along with the Aviation Suppliers Association, the Aircraft Fleet Recycling Association and the ATA e-Business Program).
“In an industry that consistently is looking for new technologies for the future, it is important to recognize the wealth of knowledge and industry experience that organizations like ARSA bring to the table,” Webb said, explaining his inclusion of the association. “For Blockchain technology, it is ARSA members that will be an entry point for certification data and there will be both benefits and repercussions to them. Recognizing the work that ARSA does on behalf of their membership, they will be an important voice for the future.”
By connecting his presentation to ARSA, Webb demonstrated the network of industry interests constantly at work on behalf of maintenance providers around the world. In addition to his own professional benefits of event participation, his use of the association’s logo added additional use to his time in Abu Dhabi.
“What Brent did is an outstanding example of ‘championing’ ARSA’s work,” said Brett Levanto, ARSA vice president of operations. “For him, all it took was a quick email to me and then dropping a file into his presentation – couldn’t be simpler. For the association, he helped to expand its reach to an event that our small, focused team would likely never have been able to attend independently. This is exactly what our network of ‘champions’ do: get out and spread the ARSA word.”
How can you take ARSA with you? To learn about how you can become an ARSA champion – taking association information along with you to industry events, trade shows, symposia and conferences – contact Levanto at email@example.com or 703.739.9543 Ext. 103.
To learn more about Webb’s work, track him down via www.acinv.com, www.aiipllc.com or www.cavuaerospace.com … or plan to attend the 2020 ARSA Annual Conference (held in and around Washington, D.C. from March 10-13).
April 5, 2019
From the Membership section..
Going Big with a Mini Display of ARSA Pride
From March 20-22, ARSA Regular Member AeroKool Aviation Corporation– which has become an exemplar of proactive membership as a Platinum Sponsor of the 2019 Annual Conference – carried the association along on its participation in SkyWest Airlines annual Mini Indy races.
“Mini Indy brings together teams from international and local businesses, community leaders and various civic groups to race miniature Indy-style cars through a twisting course,” the event website explains. “Funds raised from this event help support the United Way Dixie. The organization helps hundreds of local people every day by funding non-profit, tax-exempt charitable organizations.”
A regular participant in the event, AeroKool contacted ARSA asking permission to include the association’s logo on this year’s car. Placed right next to the company’s name on either side of the driver’s seat, the association’s logo demonstrates commitment to good safety and commonsense regular compliance as part of AeroKool’s dedication to positive action in the community.
“This event is a fun way to do some good for others,” said Jon Silva, AeroKool president. “It’s great to get out of the facility, ‘compete’ alongside industry colleagues and raise money for a worthy cause. After all that ARSA has done for us, it just made sense to celebrate our membership at the same time.”
The association will support almost any request to brandish its branding, and most opportunities don’t require a race car (AeroKool also notes its membership on the “Certifications & Approvals” page of its website…that’s an easy place to start). Contact Brett Levanto (firstname.lastname@example.org) for help or go straight to arsa.org/membership/show-your-colors.
To see more about the Mini Indy event, visit www.miniindy.org.
To learn about AeroKool, visit www.aerokool.com.
— Sean Broderick (@AvMROSean) March 25, 2019
March 1, 2019
From the Training section…
Annual Conference Accepted for IA Credit
The ARSA training team got both the March 14 “opening salvo” and the March 15 breakout on ARAC’s 145 working group accepted for IA renewal credit. Attending both sessions will earn participants five hours towards meeting the requirements of § 65.93(a)(4).
…and, where you were at the conference or not, check out ARSA’s training resources at arsa.org/training.
February 8, 2019
From the Membership section…
Serving Through Survey Responses – Oliver Wyman and ARSA
Oliver Wyman’s annual MRO survey’s response deadline has been extended. The global consulting firm has surveyed members of the maintenance, manufacturing, airline and aviation finance communities for more than a decade. Through its partnership with ARSA – which produces the association’s annual market assessment – the survey team is inviting repair stations to participate.
The survey is open for responses until Feb. 12. Use the link below to access it and submit your response today.
Responding to Oliver Wyman’s questionnaire is the perfect warmup for ARSA’s Annual Member Survey – the first invitation will be delivered to the inboxes of all primary contacts during the week of Feb 11.
The entire aviation community, including ARSA and its members, benefits from good data. The time taken to respond is an investment that moves the industry forward:
(1) To access Oliver Wyman’s MRO Survey and submit your response, visit: https://oliverwyman.co1.qualtrics.com/jfe/form/SV_5jYWgaXl3LTp8aN. Direct any questions to the research team at MROsurvey@oliverwyman.com.
(2) Ensure the invitation for ARSA’s member survey will make it to your primary contact and that it gets the attention it deserves. (If you don’t know who the primary contact is, we can help.) Help your company submit its response. Direct any questions to email@example.com.
The 2019 Global Fleet & MRO Market Assessment, prepared by Oliver Wyman, will be unveiled in March during ARSA’s Annual Conference. Click here to register now.
December 10, 2019
From the special lead section…
What’s in a Name?
By Brett Levanto, Vice President of Communications
Registration is officially open for ARSA’s 2019 Annual Conference.
The association’s most-loyal attendees might, right now, be wondering what happened to the Annual Repair Symposium. Don’t panic: The symposium’s regulatory content and compliance discussions will be as much a part of the event as ever.
Heard enough? Click here to register. (Registrations are accepted through the association’s new online portal, for a quick briefing on how to use the registration system refer to this month’s “AMS Update.”)
Why the new name? The annual event has grown and so too has its title. What began decades ago as the 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. Each March, ARSA’s signature event provides a venue for members and invited guests from around the world to network and discuss issues that matter to the repair station community.
It was getting harder and harder to list all of the components of the week side-by-side – though they’re still around – so the entire experience has been consolidated verbally under the very simple “Annual Conference.”
The rooms have been reserved at the Ritz-Carlton (book yours before Feb. 18) and the 2019 schedule is set (though specific details may change). See what awaits you at the conference:
Tuesday, March 12: Executive to Executive Briefings
[Registration for this day is available only to sponsors at the Platinum, Gold and Silver levels.]
Industry executives will participate in meetings with senior executive branch officials organized by ARSA. The day will conclude with an exclusive IATA briefing on the status of international market competition issues and the agreement reached with CFMI on maintenance data availability.
Wednesday, March 13: Legislative Day
After a morning of briefings and policy updates, Legislative Day participants will fan out across Capitol Hill to meet with members of Congress and committee staffers to connect the impact of the maintenance community to each state and congressional district. The day will include ARSA’s release of its Annual Global Fleet & MRO Market Assessment, produced by Oliver Wyman, as well as the presentation of the association’s Legislative Leadership Award.
Thursday, March 14: Annual Repair Symposium
As always, ARSA’s regulatory experts will lead a full day of panel discussions and presentations on regulatory and business development matters. Invited participants from the FAA, EASA, Transport Canada and ANAC Brazil will join industry members to address issues impacting the ability of maintenance providers to work and grow.
Friday, March 15: Annual Member Meeting & Breakout Sessions
During breakfast, the president of ARSA’s Board of Directors will overview the state of the association and share priorities for the coming year. Participants will then select one of two sessions to complete their conference engagement: (1) an update on ARAC’s part 145 tasking or (2) a workshop on “creating careers” in aviation maintenance.
See the full preliminary agenda, learn about sponsorship opportunities and begin planning your trip: Click here to get started.
Nov. 2, 2018
An update from the publisher…
The release of the October 2018 hotline comes with a special gift: A printable, PDF version.
Listening to member requests, ARSA has returned to the trusted practice of producing a single hotline document. Get yours today, print copies and distribute them among your personnel and across your facility. Put one in your lobby or waiting room. Put TWO in every bathroom. Place a copy on every work station and desk. Get physical proof of your association membership (and its benefits) into your people’s hands.
To download a copy:
(1) Find your copy of the hotline email. On the top menu, click “Print this Edition.”
(2) Log in to ARSA’s secure online portal via arsa.member365.com. On the right side of your dashboard you will see a “badge” (in the system’s parlance) with a bright red header proclaiming the availability of the hotline. Click the link to download your PDF.
For now, the printable version is in the exploratory phase and there is still a webpage-based version to which the article links on the hotline email direct. However, if the “hard copy” proves useful and accessible enough, the communications team will transition to its sole use (with some upgrades to style and function within the document).
How can you help with that decision? Tell us what you think? Is the PDF more useful than the webpage? Less? Did you give out copies to your people? How can we help get it into more (member) hands? What would make it better?
Answer these questions and share any other thoughts you have about ARSA’s newsletters at arsa.org/contact.
October 9, 2018
From “Sarah Says”…
A Turning Point
By Sarah MacLeod, Executive Director
This issue of the hotline is chock full of content about the new FAA bill. “ARSA on the Hill” takes a deep dive into what’s in the bill and how ARSA made things happen for the industry. “Legal Briefs” explores the odd process by which the bill got done. “A Member Asked” discusses next steps for the workforce development grant program ARSA helped create and how to position yourself to take advantage of it.
Before you read any of that, though, let’s explore the broader context.
Christian Klein, ARSA’s executive vice president and registered lobbyist, has been quoted as calling the bill “historic.” He’s sometimes exaggerates, but this isn’t one of those times. It is historic for ARSA.
We have a long record of success on regulatory issues, but that hasn’t been the case on Capitol Hill. In fact, Congress has regularly used repair stations as a punching bag and scapegoat. Over the last two decades, FAA bills imposed new and unnecessary mandates on the maintenance sector. Unions opposed to contract maintenance have successfully used false safety arguments to achieve economic objectives (i.e., driving up costs. making you less competitive and efficient).
By “fighting” those initiatives, we have become a trusted resource for committee staff. ARSA was and is consulted about the impact of new laws and the complexities of aviation regulation; thus minimizing the impact of congressional micro-management. We’ve also prevented some bad things from happening. In other words, we’ve been playing defense, not offense.
This reauthorization cycle changed the paradigm. With staff changes in early 2017, Christian dedicated himself to expanding ARSA’s visibility and effectiveness on the Hill. Methodically working his way through the key committees’ rosters, building relationships with member offices and committee staff in a position to shape transportation, defense, trade and small business policy; participating in close to 200 meetings with members of Congress and congressional staff (197 to be exact). (If you can believe his iPhone Health app, walking more than 150 miles and 626 flights of stairs in that effort.)
At each meeting, ARSA reinforced key themes: contract maintenance makes the aviation sector safer and more efficient, there’s enormous oversight, it supports more than 200,000 in communities throughout the country, it’s dominated by small businesses (many of which serve a global customer base), it’s growing, it’s high tech and its desperate for technically competent workers. The bottom line: legislation that hurts repair stations or disrupts global maintenance trade will hurt U.S. companies and their employees.
Those messages resonated on both sides of Capitol Hill and with both parties. As a result, this was the first FAA bill in memory that didn’t attack repair stations. Not just that, it is the first FAA bill that included proactive ARSA proposals to actually make things better. We succeeded in adding several provisions to the bill, including the crown jewel: a new $5 million per year grant program to attract and train the aviation maintenance workforce.
The reauthorization activities didn’t just strengthen relationships and ARSA’s presence on the Hill. Christian built a coalition of more than 35 aviation groups in support of the grant initiative. ARSA’s leadership dramatically elevated its visibility and reputation with locally and nationally (several local aviation associations joined the effort).
The efforts gave rise to unprecedented member engagement, with maintenance industry executives participating in dozens of Hill meetings both as part of ARSA’s annual Legislative Day and ad hoc visits to D.C. More members responded to calls to action and contacted lawmakers.
I’ll confess to being very cynical about the legislative process. It’s extremely sloppy, unpredictable and hard to control. There are so many participants that it’s almost impossible to get to a good result. Even sophisticated staffers are generally clueless about the nuanced impact laws can have on regulation and how industry will be impacted.
It is difficult to quantify the value of lobbying; how do you calculate the value of preventing something? ARSA is a nonprofit, but it’s still a business. We’re always watching the bottom line and demand a return on investment for all every activity. Therefore, we must engage with Congress, which has enormous influence over FAA activities and members’ bottom lines. Having seen too many bad pieces of legislation in my time; we cannot and will not ignore Capitol Hill. We will continue to make the investment of time and resources to ensure positive results from our activities.
Unfortunately, this “historic” victory, as is the case with so many others, was made to look easy. Members and non-members alike will no doubt say, “you did it with the resources you have, so why should we invest more in ARSA” or, “ARSA did it (and will keep doing it) without me, so why should I spend the money…I’ll let someone else foot the bill.” That attitude frosts me. We do what we do on a shoestring (ARSA’s entire annual budget is less than what some executives in the aviation industry earn).
In honor of John Lennon’s upcoming birthday, imagine what could be done with more resources. Imagine what we need to keep the people we have and attract the next generation of ARSA team members. Imagine how much more influential we would be with Congress and regulators with just a few more highly-motivated, talented, smart people. And imagine if those people had the resources really needed for sustainment and growth.
Support ARSA—sponsor and attend the Symposium and Legislative Day. Use the online portal to connect every person in your organization to member resources, take training sessions; buy or download publications. Sponsor advocacy on an ad hoc basis. Reach out to non-members (your vendors and customers) and get them to join. Nothing succeeds like success, build on every success for the future.
Yes, the FAA bill is a historic achievement and ARSA has done and will continue to do well for the industry. But it cannot be just a single event. It’s the moment for more companies to join ARSA and for more members ask not what the association can do for them, but they can do for the association.
September 7, 2018
From the Quality Time section…
Researching the Maintenance Workforce
The challenge of finding and retaining skilled technical workers has gained national attention.
In September, the FAA will host its inaugural one-day Aviation Workforce Symposium at Reagan National Airport outside of Washington, D.C.
Individuals from ARSA member companies regularly contact the association in search of resources to help describe the challenges facing the industry. All can speak eloquently of their personal experience, often highlighting the current state of workforce development with stories of their own career development – explaining how traditionally-reliable pipelines for talent are no longer sufficient.
What they need, though, is help creating a larger context. Some resources can help. The following list is a useful start – take advantage of it and share your own information with ARSA:
(1) This year’s state-by-state data sheet compiled for ARSA by CAVOK, along with the executive summary of this year’s complete report: arsa.org/market-assessment
(2) Two infographics ARSA produced based on “quick questions” regarding technician onboarding and certification breakdown in the workforce:
(a) Time to Onboard a New Technician
(b) Technician Workforce by Certification
(3) Salary data from the Bureau of Labor Statistics: www.bls.gov/ooh/installation-maintenance-and-repair/aircraft-and-avionics-equipment-mechanics-and-technicians.htm.
(4) “My Next Move,” a resource sponsored by the Labor Department that provides analysis related to the employment outlook for aircraft mechanics and service technicians: www.mynextmove.org/profile/summary/49-3011.00.
(4) ARSA’s Workforce Legislative Action Center: arsa.org/legislative/grant-program-action-center
(5) The “Pipeline Report” produced by the Aviation Technician Education Council, which has great data on industry turnover and demographics, including certification: www.atec-amt.org/2017-survey.
(6) A presentation presented on by ATEC Executive Director Crystal Maguire at the National Training Aircraft Symposium on Aug. 14 in Daytona Beach. Maguire compiled resources from multiple sources – including ARSA – to produce a quick review of most relevant data related to the maintenance workforce:
On Oct. 9, ATEC will present a webinar providing “A Closer Look at Boeing’s 2018-2037 Technician Outlook.” For more information and to register, click here.
There is no perfect data source for capturing the aviation maintenance workforce and describing each issue. Each has drawbacks and blind spots, but taken as a whole and combined with personal observation, they help to tell a powerful story.
August 3, 2018
From the Training section…
Education (and Entertainment) On the Hill
There’s a lot that goes into making (or preventing) law on Capitol Hill. It takes decades to completely master the magic of Washington policymaking, but here’s a three-minute primer from the classic Schoolhouse Rock television series:
In the months leading up to this year’s mid-term elections, the hotline will run content in the “ARSA on the Hill” section on ways to be an active constituent. Look for the first installment in this edition, with “Constituents Matter – Congressional State/District Offices.”
July 6, 2018
From the ‘Membership’ section…
Member Spotlight – Gulfstream
The first Gulfstream aircraft, the Gulfstream I, debuted in 1958. It had been conceived at the end of World War II, when Roy Grumman proposed the development of an aircraft specifically designed for fast, efficient and comfortable business travel.
The Grumman Aircraft Engineering Corporation had deep experience building warplanes and the company’s co-founder was in search of new business horizons as the world turned to peace. After years of developing an aircraft to fit the necessities of business, Grumman introduced the Gulfstream I.
Since then, Gulfstream Aerospace Corp. has celebrated countless milestones. In 1968, the company’s GII became the first business jet to cross the Atlantic Ocean nonstop. In 1983, the GIII was the first business aircraft to fly over both poles in a single flight. The GV won the prestigious Robert J. Collier Trophy in 1997. The G650 held the title of the world’s fastest business jet from December 2012 to June 2014 and has since flown around the world in 41 hours, 7 minutes. The G650 won the Collier Trophy in 2014, while the G550 won it in 2003.
Today, the company continues to build on its long history as a leader in business aviation. “Gulfstream engineers, manufactures and services the world’s finest business aircraft,” the company’s website proclaims. “Headquartered in Savannah, Georgia…Gulfstream operates facilities on five continents and employs more than 17,000 people worldwide.”
There are a number of different pieces that go into making such a great company. Gulfstream’s focus on engineering and research allows its manufacturing and maintenance facilities to support and expand its record-breaking fleet of aircraft. Customers can personalize their aircraft – customizing and stylizing cabin elements and amenities – so that each delivery is unique.
Gulfstream offers the largest factory-owned service network in the business aviation industry. Through its well-trained customer support organization and the product expertise that is part of this original equipment manufacturer’s DNA, the company helps its owners solve issues ranging from simple checks to engine replacement and complete overhauls. Gulfstream relies on ARSA to be its voice in Washington, D.C., for the company’s 13 service centers worldwide. The association’s experience and knowledge of the FAA and other civil aviation agencies allow Gulfstream to focus on leading and innovating.
For some “inside insight” into the company’s commitment to growth, the future of the industry and the value of collective industry action through organizations like ARSA, the association’s team went to Heidi Fedak, the company’s director of Corporate Communications and Media Relations:
ARSA: Gulfstream has the Field and Airborne Support Teams (FAST), which provide mobile support. How has that enhanced the company’s ability to serve its customers?
Fedak: Plane-side service and support is a necessity in business aviation. Often, your customers can’t come to you, so you need to be able to get to them as quickly as possible. Our Field and Airborne Support Teams (FAST) are designed to ensure swift, well-coordinated support for operators in aircraft-on-ground situations, particularly in areas where we do not have a maintenance facility. Gulfstream FAST provides 24/7 customer support and includes specially equipped vehicles in the U.S. and Europe, more than 125 dedicated technicians worldwide and two dedicated aircraft based in the U.S. The aircraft can deliver parts and/or technicians to operators in North America, Central America and the Caribbean.
ARSA: What does the future of business jets look like?
Fedak: Gulfstream is primarily focused on its next two aircraft to enter service, the G500 and G600, but we continuously evaluate the products and services we offer to customers. This kind of exploration could not be accomplished without a robust research and development program, which involves the work of approximately 1,500 engineers.
ARSA: What was the process of opening up the first service facility in mainland China like?
Fedak: Gulfstream Beijing, the first original equipment manufacturer-owned business jet service center in China, was borne out of tremendous growth in the Chinese market, which was – and still is – led by Gulfstream. Gulfstream’s fleet in China grew from 84 aircraft in 2013 to more than 124 since; it is approximately 200 in Greater China (China, Hong Kong, Taiwan, Macau).
The process to establish a service center in China began in approximately 2010, when Gulfstream started negotiations with two subsidiaries of Hainan Airlines Group (HNA), including charter operator Deer Jet, which first added a Gulfstream aircraft to its fleet in 2004 and had more than 20 by 2010. Chinese law dictates that foreign companies who wish to do business within the country must enter into a partnership with a Chinese company.
Gulfstream announced its joint venture with HNA in February 2012, and operations began at Gulfstream Beijing in November 2012 after the site was approved as a Part 145 maintenance facility by the Civil Aviation Administration of China. Gulfstream Beijing earned U.S. Federal Aviation Administration Part 145 approval in April 2015.
ARSA: What separates Gulfstream from its competitors?
Fedak: Gulfstream sets itself apart through a combination of factors. First, we have an unwavering commitment to delivering on our promises, providing aircraft that meet or exceed our customers’ expectations. The G650, for example, had 1,000 nautical miles more range than we promised (6,000 nautical miles vs. 5,000). With the Gulfstream G550, we delivered the PlaneView flight deck with enhanced vision, a first for the industry. With the G280, we delivered 200 nautical miles more range. With our G500 and G600, which will enter service in 2018 and 2019, respectively, we announced in 2017 that they will deliver range beyond our initial projections.
Another factor that distinguishes Gulfstream is our willingness to listen to our customers, whether we’re working with them to develop their customized interior or garnering their input on future designs. In terms of designing our aircraft, we have two customer-based groups we leverage, a Customer Advisory Board (CAB) and an Advanced Technology Customer Advisory Team (ATCAT). Together, these groups provide a tremendous level of feedback in terms of existing and future products, and we truly value the insight they provide.
We’re also set apart by our long history of designing and building industry-leading products. We’re the only business aviation company that has won the prestigious Robert J. Collier trophy three times for three different aircraft: the GV, the G550 and the G650. The trophy recognizes the greatest achievement in astronautics or aeronautics in North America.
Another differentiator for us is our customer support network, which is the largest in business aviation, with more than 4,700 professionals worldwide. No other business jet manufacturer offers a wider range of service, enhancements, spares, support functions and technical publications than Gulfstream.
ARSA: Considering the record-breaking history of Gulfstream’s aircraft, how does the company continue to push itself forward?
Fedak: We have a continuous improvement culture at Gulfstream. Throughout the company, from the hangar floor to the engineering department, we always look for ways to improve our processes and become more efficient. By continually getting better at what we do and subscribing to a team philosophy, we can meet or exceed customers’ expectations.
ARSA: How important is it to have the collective support of industry groups like ARSA? What value does this representation bring to Gulfstream?
Fedak: It is very important. ARSA is the only industry group devoted to the needs of the civil aviation maintenance industry worldwide. Gulfstream’s maintenance organization, Customer Support, is a major element of the company, with nearly 30 percent of its 17,000-plus employees devoted to the business unit. Through constant communication with legislators, federal regulatory bodies and the media, ARSA helps member companies such as Gulfstream operate more efficiently and effectively, while continuing to ensure the safety of its worldwide fleet.
Gulfstream has been an ARSA member since 1999. To learn more about the company, visit www.gulfstream.com/company.
June 12, 2018
The New AMS is Coming – Get Ready
This is your first warning (a good one):
ARSA is transitioning to a new membership engagement tool. The “association management system” (AMS) will integrate with www.arsa.org through an online portal providing direct access for members to information, benefits and resources.
Once the new AMS is unveiled, members will be able to manage the contacts included under their organization, navigate a contact directory, access/purchase publications, register for events, pay invoices and communicate with ARSA’s team and each other.
The ARSA team has spent the first half of the year learning the new system, tailoring it to member’s specific needs and updating procedures to accommodate its various features. The final review of current membership data is underway; it will be uploaded into the AMS shortly.
You will receive a “launch” notice via email when your membership information has been loaded into the new system. The message will include basic instructions for setting up your member portal account and begin exploring.
May 5, 2018
From the ‘ARSA Works’ section…
The aviation community was reminded about the potential impact of Brexit with the April 13 “Notice to Stakeholders” from the European Commission’s Directorate-General for Mobility and Transportation entitled “Withdrawal of the United Kingdom (UK) and EU Aviation Safety Rules.”
The notice explains that unless a withdrawal agreement establishes a different timeline or other rules, on March 30, 2019 all EU laws will cease to apply in or to the UK, including those related to civil aviation safety. Among the potential consequences:
- EASA carries out the functions and tasks of the state of design on behalf of EU member states. This includes the issuance of type certificates for products, design approvals for parts and appliances and design organization approvals. Such approvals issued by EASA to persons and organizations located in the UK will no longer be valid in the EU.
- Certificates issued by the UK pursuant to EU rules (including airworthiness, approved maintenance organization, maintenance training organization, manufacturing, and mechanic certificates) will no longer be valid.
- Certificates confirming compliance with EU rules issued before the withdrawal date by persons certificated by the UK pursuant to EU rules will no longer be valid (with some limited grandfathering exceptions).
- UK aircraft operators will be considered ‘third country’” operators by the EU and require an authorization from the EASA.
- EU aircraft operators using UK-registered aircraft will need to comply with EU rules on air services concerning the use of ‘third country’ registered aircraft.
Individuals, as well as organizations located in the UK holding certificates who wish to continue EU activities will need to ensure compliance with EU aviation safety requirements. The notice also states that the Commission is considering whether any additional steps or guidance are needed to facilitate compliance for products, parts and appliances certificated before the withdrawal date and put in use in the EU before the withdrawal date and/or relevant organizations or persons requiring certification.
The Commission’s notice sets forth the worst-case scenario. Aviation safety is a key issue in Brexit negotiations and policymakers on both sides of the English Channel will look for ways to avoid massive disruptions. A UK government report states that the UK and the EU are working to pave the way for the UK to continue participating in EASA through the end of 2020.
As for the longer-term future, the UK could become an “associated” country for purposes of EASA, the status enjoyed by Iceland, Liechtenstein, Norway and Switzerland (European countries but not EU members). According to the FAA, associated countries can enter into bilateral agreements with third countries (as long as they don’t contradict EASA’s interest). The UK could therefore conclude separate bilaterals with the United States to minimize headaches for companies doing business between the two countries.
Before you take the EC’s notice as gospel, visit EASA’s webpage for additional perspectives on the Brexit negotiations and links to other EU and UK resources.
April 9, 2018
Regulatory Compliance Training
Each edition of the hotline includes a regulatory training sheet. Each sheet is provided as a printable PDF document that can be downloaded and circulated through a maintenance facility for use as a teaching tool.
The purpose of the training sheet is to provide basic instruction on specific sections of 14 CFR (relevant section text is always provided) and encourage careful reading of the rules by asking four true/false questions (answers provided on the back side) that can be answered based entirely on the regulatory text.
This month, an reader pointed out to the ARSA team that the answer key overlooked a specific phrase from the rule. Based on this feedback, the sheet was updated to correct the statement in order to support the provided answer…which proves that it is a team effort to read and interpret the rules no matter how straightforward they might appear.
Test your knowledge of 14 CFR § 65.20 – Applications, certificates, logbooks, reports, and records: Falsification, reproduction, or alteration.
Symposium 2018 – Sponsor Salute
Thank you to the organizations that have stepped up to commit support to the repair station community’s premier event. These companies are the perfect demonstration of the aviation world’s shared commitment to both good safety and good business (to learn more about a sponsoring organization, click the appropriate logo):
November 3, 2017
Compliance Over a Dead Body – Lessons on a Long-Fought-For Exemption
By Sarah MacLeod, Executive Director and Brett Levanto, Vice President of Communications
When dealing with a regulator, being “right” only gets you half way. You have to be accurate in your interpretation of the rules, armed with the technical capabilities and data to reinforce your position and then willing to see it through until the end.
The ARSA website is littered with examples (the association’s team is still “fighting for your right to surrender” three years after the update to 145.55…and that’s nothing). Recently, though, the association’s management firm Obadal, Filler, MacLeod & Klein, P.L.C. provided a case in point by virtue of an indefatigable client.
In 2014, Stone Aviation International (SAI) obtained foreign military surplus UH-1 composite main rotor blades. They had been produced to an FAA-approved design and possessed the same part numbers as blades produced in the United States by the design and production approval holder. Though they were manufactured according to the specifications of those on American military helicopters, the specific blades had been manufactured for and declared surplus by a foreign military. As a result, they failed to meet the criteria in 14 CFR § 21.9(c) requiring military articles be declared surplus by the U.S. armed forces in order to be sold as suitable for installation on type-certificated aircraft.
Initially, there was mass confusion about where the blades fell in the regulations. After the company queried the FAA, the agency’s personnel reached consensus that they could not be sold for use or used on restricted category helicopters.
Facing this initial refusal, SAI contacted OFM&K. Based on the firm’s counsel and supported by data collected from various designees, mechanics, rotor blade repair specialists, consultants and agency personnel, the company developed an initial “pathway for approval.” Unfortunately, the proposal faced additional misunderstanding within the agency before being delegated to the company’s principal maintenance inspector (PMI).
After an apparently successful audit and examination, the Flight Standards Service indicated the blades would subsequently be add to Advanced Composite Structures Florida’s (ACSF) capability list. Unfortunately, the agency never followed through – SAI was forced to go back to the compliance drawing board.
We constructed a new plan: OFM&K would spearhead a request for exemption under Advanced Composite Structures Florida’s (ACSF), the FAA repair station with appropriate ratings and capabilities. The request would be based on verifiable data, the company’s inspection of the blades against the design specification and the aviation safety rules’ fundamental requirements of airworthiness. Based on the new approach, both the firm and its new client were confident despite the countless aviation lawyers, compliance firms and even FAA officials consulted by the company who insisted the blades were a “dead end.”
The request for exemption was submitted in January, 2017 and supplemented in June before its acceptance was finally published in September – four years and multiple rejections after the blades were initially purchased. The exemption allows ACSF to maintain the rotor blades and offer them to restricted category operators. It requires the company to issue an FAA form 8130-3 for each. The maintenance release will be based upon the proprietary process submitted during the exemption process and added to the repair station’s quality procedures. The process is the reason the FAA accepted ACSF’s assertion that it can establish each blade meets agency-approved design, operating and maintenance requirements. This is the first time the agency has granted an exemption on foreign military surplus articles.
“ACSF has requisite design and production data and historical records to enable it – and the FAA – to make competent airworthiness determinations,” the grant of exemption states. “The FAA agrees with ACSF that this exemption would be in the public interest because many restricted category type-certificated helicopters…fly missions under contract for federal, state and local governments.”
Good data supported the exemption, but OFM&K made it happen. When the SAI/ACSF first went looking for compliance help, other lawyers said ‘no.’ Everyone said ‘no.’ There were even some voices at the FAA whose ‘no’ was accompanied by an ‘over my dead body.’ The firm (and ARSA) can say ‘yes’ – or at least ‘why not’ – more often than others because our team understands the reality of the aviation safety rules. We don’t stop after one reading of a regulation and we sure as hell won’t stop because of an unsupported ‘no’ from a regulator.
ACSF is now working to fulfill the obligations of the exemption, which will allow the long-awaited delivery of those composite main rotor blades to market. As business ramps up, both ARSA and OFM&K will continue to share news, updates and lessons-learned from the process. Stay tuned to both the hotline and Dispatch and review content at potomac-law.com/blades-pay-off.
October 6, 2017
Laissez-Faire? We Wish
By Sarah MacLeod, Executive Director
A recent article accused the FAA of taking a laissez-faire approach to aviation safety. The news item seems to have been triggered by the negative audit this year by the Department of Transportation’s Office of Inspector General of the FAA’s suspected unapproved parts program.
The Sept. 20 exposé from the Crime Report begins with the “news” that “[a] tide of defective and possibly counterfeit airplane parts has been making its way into U.S. aircraft unreported and unchecked…”. The story quotes a former inspector general, Mary Schiavo, in addition to a whistleblower and some former FAA employees.
The reason for this “tide,” it appears, is that the FAA takes a “laissez-faire” approach to aviation safety oversight. If that is true, I would hate to see what the general media would think is the proper amount of scrutiny. While it is true the FAA may not efficiently and effectively notify federal law enforcement authorities about “suspected” parts problems, it is equally true that the FAA will be looked upon by those same agencies to determine if there is enough evidence to establish a criminal case. The fact that the government will rely upon the design or production approval holder to determine whether an article is airworthy should not be taken as a “hands-off” approach to aviation safety oversight.
Unfortunately, the general media combines unsubstantiated and often unrelated information into a “story” for consumption by the general public. When the story involves highly technical issues in a closely regulated industry, both the oversight authority and individual companies become the target of misinformation and misconceptions.
As ironic as it sounds, counterfeit does not automatically mean unairworthy. Similarly, falsification of records does not mean that the article being examined failed to meet specifications. Each element of a non-compliance or non-conformity has to be evaluated thoroughly and carefully to determine impact on the aircraft and ultimately the safety of the flying public. It’s equally true that law enforcement agencies must present “evidence” – not merely suspicion – to a prosecutor and ultimately courts of law. The court system in America is based upon the premise that one is innocent until proven guilty—no such standard applies to the “free” press.
Unfortunately, negative stories “sell” and the industry has a laissez-faire approach to media relations. While ARSA responded to The Crime Report’s queries and was even quoted, the article managed to make it sound like repair stations thought the agency was justified in taking a “hands-off” approach to oversight. In aviation, we will continue “to hear the truth [we’ve] spoken twisted by knaves to make traps for fools,” but it will not deter us from responding to negative publicity.
September 5, 2017
Maintenance industry leaders attending the 2017 ARSA Strategic Leadership Conference in Washington, D.C. this fall have something else to look forward to: FAA Administrator Michael Huerta is now confirmed as the meeting’s keynote speaker. Huerta will discuss current FAA priorities while reflecting on his tenure as the agency’s head.
The annual ARSA SLC provides a forum for maintenance industry C-level executives and their air carrier customers to come together to discuss and confront challenges and opportunities facing our sector. Topics for this year’s meeting include FAA reauthorization, strategies for engaging in the new political environment, developing independent manufacturing and repair sources, and protecting intellectual property rights.
The 2017 SLC is taking place in Washington, D.C. on Oct. 18 and 19. Following a reception on the evening of 18th, attendees will spend the morning of the 19th hearing from top level speakers and discussing priority issues. The second half of the day will be spent in delegation meetings coordinated by ARSA on Capitol Hill and with executive branch officials.
To see more about what will happen at the SLC, check out the rest of this edition of the hotline, stay tuned to ARSA for updates and visit the event page. Registration is open to any interested maintenance industry leader, but space is limited.
To learn more about Administrator Huerta, click here to read his official bio.
August 4, 2017
A Member Asked…
Q: Section 145.211(c)(iii) states that you must perform a hidden damage inspection on all articles that have been involved in an accident. In this instance, how is an accident defined? If an aircraft hits a tree while being transported on a trailer, is this an accident in the view of the regulations? My answer is no. An accident is only a flying or operational accident with an aircraft. If an aircraft is being transported before maintenance I do not view this as needing hidden damage, but I need ARSA’s assistance here.
A: There are two answers to your query: the regulatory one, where “accident” is defined by the NTSB (not the FAA) and the business one, which requires your work to result in a usable item. Therefore, the ARSA model repair station and quality manual defines “accident” thusly:
With respect to aircraft, the term is defined by the NTSB and means an occurrence associated with the operation of an aircraft which takes place between the time any person boards the aircraft with the intention of flight and all such persons have disembarked, and in which any person suffers death or serious injury, or in which the aircraft receives substantial damage. (See, 49 CFR § 830.2.)
With respect to other civil aviation articles, the term refers to the article being subjected to extreme conditions not covered by or anticipated to be corrected by maintenance data issued by the manufacturer. The repair station must have actual knowledge that the article was involved in such an occurrence.
When an article you received for maintenance has been subject to conditions that would render it “unairworthy” in some manner it would behoove the repair station to ensure that it was not releasing something that would fail. So, if the repair station has ACTUAL KNOWLEDGE of a condition that could not be discovered without a “hidden damage” inspection, it should be addressed.
For example, if you are told that something was dropped from a high platform to a concrete floor, you wouldn’t ignore the impact (no pun intended) that could have on the continued airworthiness of the article. Or if during the inspection process (or maintenance process) a condition was found that was obviously due to an extreme condition (overtemperature of an engine), it would be hard to ignore the finding. Indeed, if during the transport of the aircraft it was subjected to a condition that could render it unairworthy and that condition would be found or “cleared” by a “hidden damage” inspection, why wouldn’t the inspection be prudent?
Of course, the hidden damage inspection needs to be such that would find the unairworthy condition; a repair station may need help from a qualified engineer or the manufacturer, but it would be better than having the hidden damage render the article unairworthy, particularly when a repair station has ACTUAL KNOWLEDGE of the article’s “accident.”
Ironically, an aircraft can have an accident as that term is defined by the NTSB but it may have absolutely no impact on an installed article. Substantial damage to (or a fatality in) an aircraft does not automatically render every installed item on that aircraft “unairworthy.” Unfortunately, the regulations are not always logical. So, if an article is removed from an “accident aircraft,” a repair station must perform a “hidden damage” inspection. That inspection should include an explanation of the accident so that an appropriate parameter can be established for the article’s review. Some articles may only need to undergo a “normal” inspection found in the maintenance manual, while others may need a “special” inspection developed to find any “hidden damage.”
Have a question for ARSA? Click here to let us hear it.
July 7, 2017
House, Senate FAA Bills Include Key ARSA-Supported Provisions
The last week of June was the busiest and most successful for ARSA on Capitol Hill in recent memory. The focus of all the activity was the markup of FAA reauthorization bills by the House Transportation & Infrastructure Committee (June 27) and Senate Commerce, Science & Transportation Committee (June 29). In the “ARSA on the Hill” section of this month’s hotline, members can get a detailed review of ARSA’s work to move out on positive policy initiatives and amendments to address the aviation maintenance industry technician shortage and improve the regulatory environment for repair stations.
Regardless of the details, the entire repair station community should take a moment to thank the members of Congress who have taken the lead in support of aviation maintenance:
|Say Thanks To Our Champions!
As we prepared for the FAA markups, ARSA was fortunate have several members of Congress who were willing to go to bat for repair stations and sponsor amendments. If someone from your state is on the list, shoot a quick note of thanks. It doesn’t have to be anything fancy and could be as simple as: “Thank you for your leadership on aviation maintenance issues during the recent FAA markup. As a member of YOURSTATE’s repair station industry, I sincerely appreciate your efforts on our behalf.”
(Clicking on the names below will open up a blank email address to their aviation staffers.)
June 9, 2017
Sarah Says: You Can’t Be a Little Bit Pregnant
By Sarah MacLeod, Executive Director
No, this is not about abstinence. It’s about the impossibility of getting rid of bad laws and the facts associated with unintended consequences.
Once legislators have enacted a law, it is almost impossible to reverse the process – you have to deal with the results. The “baby” is coming and the industry (or general public) will have to raise it regardless of its true parentage.
Case in point: In 2003, Congress passed a law forbidding the FAA from certificating foreign repair stations until the Transportation Safety Administration (TSA) issued new security rules. The TSA didn’t want to control repair stations, because they were such a low security risk in a time where the agency had plenty to keep it busy. The repair station community certainly didn’t want security regulations since many aren’t even on airports – where’s the threat? – and most are small businesses that can’t absorb the costs of unnecessary requirements. The FAA didn’t want to stop certificating foreign repair stations since they are required for operators of U.S.-registered aircraft operating overseas.
Neither the facts (the lack of an actual threat to aviation security) nor the unintended consequences (no actual stakeholder sought the congressionally-mandated outcome) stopped the law from being passed; the only thing that stops or starts the legislative process are the taxpayers and voters. Sure, politics is disheartening. So is direct involvement in the process. But without activism, we all end up having to comply with the unintended consequences of unwanted laws.
Activism is essential to a democracy. It is our one prophylactic measure against a lifetime of unwanted regulatory responsibility. Now is the time to exercise that protection: Lawmakers have gotten busy reauthorizing the FAA, flirting with regulatory and tax reform and courting the technical workers of the future. The association needs your support as it works for you on the Hill.
Regardless of what you do this summer, you should join us this fall. At October’s Strategic Leadership Conference, ARSA will focus on activism. Come to Washington and tell our story, face to face, with law and policymakers. They say abstinence is 100 percent safe, but it’s in aviation that good safety is good business – come show off the goods.
May 5, 2017
Forewarned is Forearmed: New Repair Station Ban Looms in FAA Reauthorization
By Christian A. Klein, Executive Vice President
There’s a lot happening on Capitol Hill this spring. The air is abuzz, not just with D.C.’s notorious spring pollen, but also with talk of fixing, repealing or replacing Obamacare, tax reform, and national security issues. FAA reauthorization is also high on the agenda. The reauthorization debate poses some important opportunities – but also significant risks – for repair stations.
Where Things Stand
Authorization for the FAA is set to expire on Sept. 30. The goal for the current Congress is to enact a new, multi-year budget blueprint for the agency to provide more long-term certainty about FAA resources and priorities.
The starting point for reauthorization is the FAA bill reported by the House Transportation & Infrastructure Committee during the last Congress. The legislation is generally positive. It contains provisions aimed at greater consistency in FAA regulatory interpretation, making greater use of organization delegation authorization (ODA), improving the certification process, and promoting international acceptance of FAA certifications and approvals.
The process is well underway. The House and Senate aviation subcommittees have started holding hearings, engaging stakeholders, and drafting proposals. There’s talk that FAA legislation may start moving as soon as late May or early June. There are some difficult issues lawmakers need to resolve (e.g., whether or not to privatize air traffic control), but with the clock ticking towards the Sept. 30 deadline there’s a strong incentive for Congress to move quickly.
Check out this month’s edition of the hotline for the full article…
April 7, 2017
White House Education & Workforce Policy Outlook: Heavy Praise, Skinny Budget
By Brett Levanto, Vice President of Communications
President Trump’s administration is taking ideological shape in Washington. Even as hundreds of presidentially-appointed positions remain unfilled and the signature legislative effort to repeal and replace Obamacare fell flat in Congress, the White House has generally outlined key policy initiatives including regulatory reform and military investment.
Restoring and protecting American jobs was a central tenet of the president’s 2016 campaign and workforce issues have remained at least in sight during the early days of the administration. During his well-reported meeting with German Chancellor Angela Merkel, Trump described skills training as “very important.” Opening a roundtable discussion with Merkel and a group of American and German business leaders, Trump specifically highlighted apprenticeships: “Companies across the [United States] have a chance to develop vocational training programs that will meet their growing needs and to help us achieve greater prosperity,” the president said. “The German apprenticeship model is one of the proven programs to developing a highly skilled workforce…And we need that because we’re training people as the jobs are pouring back in.”
The relationship between job growth, performance and education is clear. Considering the White House’s infrastructure goals – generating up to $1 trillion in funding through a mix of public and private investment – ARSA and its industry allies have highlighted the need for well-trained technicians and specialists to perform the actual work needed on roads, bridges, airports and other transportation facilities. In addition to apprenticeships, members of the president’s cabinet have underscored the value of industry sector partnerships, aligning curriculum with employer demand and bolstering job training programs.
The White House website’s issue page on jobs uses workforce growth as the unifying thread connecting the administration’s other policy goals, specifically tax reform, and relates it to Trump’s well-publicized business acumen: “As a lifelong job-creator and businessman, the president also knows how important it is to get Washington out of the way of America’s small businesses, entrepreneurs and workers.”
All of these initiatives, as general expressions of policy, are consistent with industry demands for better skills-based training. Last September’s House-passed “Strengthening Career and Technical Education for the 21st Century Act” (H.R. 5587) would have codified many of these requirements. Unfortunately, that bill to modernize and reform the federal government’s primary vehicle for investment in career technical education was never taken up in the Senate. Early indications are that the 115th Congress’ effort to reauthorize the Carl D. Perkins Act will pick up where the 114th left off – good news for businesses in need of technical skills.
However, it’s not clear what resources would be made available to support a full reauthorization of Perkins or even maintain existing programs; on March 16, President Trump released his budget blueprint for FY 2018. The “skinny budget” – limited in detail but promising a more-comprehensive update later this spring – cuts $2.5 billion in funding from the Department of Labor and another $9 billion from the Department of Education.
Though presidential budgets are not legally binding and Congress has the final say in authorization and appropriations, Trump’s blueprint would stretch existing workforce programs and threaten education resources. According to a report from Democratic staff for the House Appropriations Committee, the White House proposal would cut job training and employment services provided under the Workforce Innovation and Opportunity Act (WIOA) by 35 percent. The reductions in WIOA, which passed in 2014 with large bipartisan majorities in both houses of Congress, could threaten access to employment services for millions of Americans. On the education side, the president’s budget preserves the Pell Grant program for higher education assistance and bolsters investment in school choice programs but threatens resources for working adults and lower-income students.
There are plenty of workforce and training policy questions unanswered. Repair stations, their suppliers and industry partners must drive the debate at both ends of Pennsylvania Avenue on skills development.
March 6, 2017
White House Order Brings Some Form to Regulatory Reform
By Brett Levanto, Vice President of Communications
On Feb. 24, President Donald Trump issued an executive order providing general instruction for staffing and procedure to execute his policies for controlling regulatory burden.
The order directs the head of each agency to designate a regulatory reform officer (RRO) to oversee implementation of reform initiatives. Each RRO will chair a to-be-established regulatory reform task force to evaluate existing regulations for recommended repeal, replacement or modification.
In performing this assessment, each task force must seek out rules that, among other things, eliminate jobs, “impose costs that exceed benefits” or are “outdated, unnecessary or ineffective.” The boards are further instructed to “seek input and other assistance…from entities significantly affected by federal regulations, including…small businesses, consumers, non-governmental organizations and trade associations.”
ARSA is uniquely positioned to offer counsel on behalf of repair stations and eager to help thoroughly review existing regulations. Through service on the Aviation Rulemaking Advisory Committee (ARAC) and other stakeholder bodies, the association can serve as the voice of the maintenance community to help the FAA comply with White House directive.
The executive order provides the first insight into logistics for the president’s regulatory reform initiatives. In a series of actions taken during his first week in office, Trump froze regulatory activity and made good on his “two for one” campaign promise – consistent but vague expressions of a sea change in oversight policy. As that reform begins to take real shape, a lingering question remains: What exactly is a “regulation”? More than a thought exercise for an ARSA training session, the White House’s Jan. 30 executive order left the issue open by use of an expansive definition:
“Sec. 4. Definition. For purposes of this order the term ‘regulation’ or ‘rule’ means an agency statement of general or particular applicability and future effect designed to implement, interpret or prescribe law or policy or to describe the procedure or practice requirements of an agency, but does not include:
(a) regulations issued with respect to a military, national security, or foreign affairs function of the United States;
(b) regulations related to agency organization, management, or personnel; or
(c) any other category of regulations exempted by the Director.”
For FAA certificate holders, the definition could apply to any agency rule or guidance – a great but expansive opportunity to review every statement produced by the agency in execution of its duties.
In the meantime, ARSA members should:
(1) Review the entire executive order: www.whitehouse.gov/the-press-office/2017/02/24/presidential-executive-order-enforcing-regulatory-reform-agenda.
(2) Catch up on ARSA’s previous coverage of President Trump’s regulatory reform efforts: arsa.org/reg-reform-2017.
(3) Begin practicing the guidance in last month’s hotline: “Analysis for Action – Control Regulatory Costs by Reporting Them.”
Feb. 3, 2017
Analysis for Action – Control Regulatory Costs by Reporting Them
By Sarah MacLeod, Executive Director and Christian A. Klein, Executive Vice President
President Trump’s executive order to control regulatory costs enhances the director of the Office of Management and Budget’s role as the “hall monitor” for executive agencies. The director is to ensure that every agency “manage the costs associated with the governmental imposition of private expenditures required to comply with Federal regulations. Toward that end, it is important that for every one new regulation issued, at least two prior regulations be identified for elimination, and that the cost of planned regulations be prudently managed and controlled through a budgeting process.” Additionally, unless contrary to law, the president directs that “[f]or fiscal year 2017, which is in progress, the heads of all agencies are directed that the total incremental cost of all new regulations, including repealed regulations, to be finalized this year shall be no greater than zero…”
The directive also defines the word “regulation” very broadly to include ‘“an agency statement of general or particular applicability and future effect designed to implement, interpret, or prescribe law or policy or to describe the procedure or practice requirements of an agency…” Given that expansive definition, the order may very likely apply to guidance, which articulates (i.e., interprets) acceptable methods of compliance with a regulation (i.e., law). We expect OMB to soon provide clarification about how the Order is to be implemented.
The presidential directive may be heartening to those of us in aviation being inundated by orders and policy in the guise of regulations, but it will take more work on industry’s part to ensure that the director of OMB and the FAA actually understand the executive order’s impact. This is our chance to remove redundant and confusing rules, but without explaining the amount of money that will be saved, the presidential objectives cannot be achieved for either the agency or the industry.
If you’re not already, you should start thinking about regulations not simply in terms of the frustration and headaches they cause you, but in how much time is associated with compliance and how much money that is worth. Organizations that are able to articulate those metrics will be the most successful in the new regulatory environment.
December 12, 2016
Successful Oversight Requires Collaboration
By Ryan M. Poteet, Regulatory Affairs Manager
The aviation maintenance industry is complex and, often, requires regulators from different countries to oversee and countenance a certificate holder’s operations. Similarly, the FAA’s highly specialized lines of business have caused intra-agency divisions that lead to rules and guidance being created in a vacuum. As such, the development of rules and advisory materials takes significantly more time and resources because the FAA is forced to reconcile duplicative or ambiguous requirements in response to public comment.
What if the aviation maintenance industry was able to provide its perspective before the FAA began drafting guidance or proposing new regulations?
To see the full “legal brief” and learn how ARSA is working to re-engage the Aviation Rulemaking Advisory Committee (ARAC), check out this month’s edition. 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.
November 7, 2016
From SLC to Symposium
By Brett Levanto, Vice President of Communications
In the last hotline, we celebrated a successful trip to Montreal for ARSA’s 2016 Strategic Leadership Conference (if you somehow missed the association’s coverage of the event, visit arsa.org/slc-2016). As we worked with maintenance industry leaders in Canada, the team at ARSA’s headquarters opened registration for the 2017 Legislative Day and Annual Repair Symposium in the U.S. capital next March.
The symposium and SLC are the key points on the association’s calendar. ARSA’s team builds its yearly schedule around planning, preparation for and execution of each event, and you should, too.
Help the team put the finishing touches on the symposium agenda by completing the questionnaire that pops up on the event page.
Attending ARSA events provides you with personal access to a global network of maintenance community stakeholders. You’ll hear presentations from industry leaders and government officials, participate in discussions with international regulators and strengthen your connections with colleagues and peers. You will also be supporting the only organization dedicated to providing a voice to repair stations around the world.
So, whether you had a great time with us at IATA’s headquarters on Oct. 5 and 6 or jealously followed along at home (have you been to arsa.org/slc-2016 yet?), you can reserve your spot at next year’s symposium right now. Early registration is open; submit yours before Dec. 31, 2016 and get 2016 rates.
For more information and to register, visit: arsa.org/news-media/events/arsa-symposium.
Whether you’re an “early bird,” an “eager beaver” or just a passionate supporter of ARSA and its members, register now.
October 14, 2016
Elections Have Consequences
By Daniel B. Fisher, Vice President of Legislative Affairs
Editor’s Note: This is the fourth part in a series on active political engagement.
If you’re living in the United States, you’ve been bombarded with television and radio ads, reflected on what is and isn’t “locker room talk” and met Kenneth Bone, an unassuming citizen who asked an insightful, policy-related question to the presidential candidates during the second debate…and immediately became an overnight sensation.
I’m pleased to announce the 2016 election cycle is in the home stretch; however, no matter how much you want the campaigns to end, it’s important not only that you vote, but also that you encourage your employees and colleagues to head to the polls on election day (if not before, as absentee voting is already in full swing).
Make sure you’re registered and know where to go on election day (or get your absentee ballot) by clicking here to visit the 2016 election voter toolkit provided by ARSA’s management firm, Obadal, Filler, MacLeod & Klein, P.L.C.
There’s a bunch a stake both on a federal, state and local level. The battle for the White House and control of both houses of Congress will determine the future of tax, trade, environmental, regulatory and aviation policy for the next decade. While the House is expected to remain Republican into 2017 (though in this political environment, anything can happen), GOP margins will likely shrink. In the Senate, Democrats have a legitimate shot at overtaking the Republicans’ 53-47 majority; GOP-held seats in North Carolina, Missouri, Florida, New Hampshire, Indiana, Wisconsin and Pennsylvania remain “toss-ups” and incumbent Sen. Mark Kirk (R-Ill.) needs to pull-off the upset of the year to keep his seat.
While federal elections get all of the attention, don’t forget state and local races. Governorships, legislatures, county councils and city halls are up for grabs across the country. The outcome of these races will oftentimes have a larger impact on your business and your day-to-day life than the national elections. Educate yourself about your local candidates and issues (including ballot measures) and vote!
Get educated, get engaged, and make your mark at the polls on Nov. 8. Remember, you can’t really complain about the results – or celebrate them – if you don’t vote.
September 2, 2016
State Department Relaunches Company Visit Program to Assess ITAR Compliance
By Thomas McVey, Esq. and Williams Mullen, a firm of more than 200 attorneys that blends law, government relations and economic development across 16 practice areas.
Editor’s Note: Readers with questions about import and export compliance issues – particularly relating to the application of ITAR – should review Thomas McVey’s previous submissions:
And register for the upcoming free webinar:
The State Department’s Directorate of Defense Trade Controls (DDTC) has relaunched its Company Visit Program to review compliance activities under the International Traffic In Arms Regulations (ITAR). With its resumption, every repair station with activities regulated under ITAR must understand how the Program works.
Companies are selected for a one to two day visit by DDTC Compliance Office officials under DDTC’s screening criteria. Visits include meetings with senior executives and compliance personnel to review the company’s activities. DDTC has recently issued additional information about the program, including a series of Frequently Asked Questions, The following selected FAQ’s are instructive:
What is the Company Visit Program?
The Company Visit Program entails visits by DDTC officials to U.S. entities registered with DDTC as manufacturers, exporters or brokers of defense articles and defense services, as well as others involved in ITAR-regulated activities, to include foreign companies and foreign governments.
What is the purpose of the Company Visit Program?
The program has several purposes. First, it ensures DTCC understands how compliance programs are implemented in accordance with ITAR. Second, the program enables DDTC to gather information to support the directorate’s development of regulatory policy and practice. Finally, DTCC uses site visits to glean, assess and disseminate industry best practices, provide feedback to individual companies on their compliance programs, and share information on compliance programs industry-wide.
How is the DDTC team staffed for each visit?
A team typically consists of two or more staff from DDTC, depending on the size of the individual company/site being visited and number of companies/facilities visited per trip. On some visits, staff members from DDTC’s Offices of Licensing and Policy, or other relevant agencies, may participate. One DTCC team member serves as team lead and primary point of contact with the company.
How is a visit conducted and what should a company expect?
Once a company is selected for a potential visit, DTCC contacts the company for scheduling. The company can elect not to participate in the visit. Once visit dates are finalized, DTCC sends the company a formal visit notification letter and may request pre-visit materials. Before the visit, DTCC will work with the company to finalize the agenda.
At the visit’s opening, DTCC meets with senior management to explain the purpose and agenda. The company should provide an overview of its operations and export activity during opening discussions. Visits generally last one to two days, depending on the purpose and occur on the company’s premises in offices and conference rooms and include tours of business operations departments. At the visit’s conclusion, the DDTC team briefs company senior management and export control staff to share information the team gathered. DDTC invites the company to provide feedback, ask questions, or raise concerns for follow-up.
After the visit, the DDTC team generates an internal report. The team also follows up on company feedback. DTCC will send a formal close-out letter to the company to summarize the visit, indicate best practices, recommend areas for improvement and address feedback, questions or concerns raised by the company. DTCC also requests feedback on the visit’s quality and usefulness and suggestions for improving the program.
It is important to be ready if DDTC requests a visit with your company. Companies are advised not to wait until the last minute but rather have their ITAR compliance house in order in prior to being contacted for a visit.
To make sure your house is in order, join a free export compliance webinar on Thursday, Sept. 8. The session is provided as a benefit to ARSA members, click here for more information and to register.
This article contains general, condensed summaries of actual legal matters, statutes and opinions for information purposes. It is not meant to be and should not be construed as legal advice. For more information, please visit www.williamsmullen.com or contact Thomas B. McVey, 202.293.8118 or firstname.lastname@example.org.
July 1, 2016
As American’s prepared to celebrate 240 years of independence, the Kingdom of Great Britain suddenly – and somewhat unexpectedly – voted to remove itself from the European Union. How will this modern insurrection affect aviation maintenance providers? Find out in your July 1 edition of the hotline, as Regulatory Affairs Manager Ryan Poteet answers this month’s “A Member Asked…”
May 6, 2016
ARSA on the Hill – By Daniel B. Fisher, Vice President of Legislative Affairs
ARSA’s been sounding alarm bells for years: the FAA reauthorization process is wrought with threats and opportunities for the aviation maintenance sector. Unfortunately, as in past years, dangers from unnecessary, burdensome mandates divert the association’s time and energy away from actually seeking productive policies that would improve conditions for repair stations. The industry has to play defense and the reason is simple—scarce resources.
The aviation industry and lawmakers rely upon ARSA for its expertise and savvy. We organized industry lobbying efforts to defeat burdensome mandates regarding life-limited parts and restricting FAA foreign repair station certifications. The association is seeking modifications to the “repair station” specific provisions in both the House and Senate reauthorization bills. While the broader aviation industry is willing to support our campaigns, ARSA is expected to carry the water. And the association does it on a shoestring budget.
Examine the first quarter 2016 lobbying disclosure reports. The Transport Workers Union of America (AFL-CIO), Transportation Trades Department (AFL-CIO) and the International Association of Machinists and Aerospace Workers are leading the charge for provisions to drive up costs on contract maintenance providers. Included are burdensome pre-employment background checks and foreign drug and alcohol testing requirements (that would once again halt foreign repair station certifications until finalized). These well-heeled organizations spent $735,000 during the first three months of the year compared to about $30,000 from ARSA—nearly 24 times more resources obviously buys more lobbyists, Capitol Hill contacts, and access.
ARSA’s Capitol Hill successes have been the result of hard work, adeptness at navigating the legislative process, regulatory and industry expertise. We’ll continue to fight hard and win battles, but well-funded organizations are perpetuating false safety, security, and economic arguments against contract maintenance. To win the war we need greater resources. There’s a saying in Washington, “if you’re not at the table, you’re on the menu.” ARSA’s is certainly at the table, but it can’t afford all the courses.
Lobbying resources come from the portion of member dues set aside for advocacy. Help grow this pot by recruiting new members, making sure all of your company’s locations pay dues or upgrade your membership. Even better, help all ARSA programs by purchasing a publication, utilizing the services of a preferred provider, sponsoring an event or attending an online training session.
Your investment furthers the association’s efforts on behalf of the maintenance community in all arenas. I promise you’ll see an exponential return.
April 4, 2016
The association recently conducted an industry survey to quantify repair station audit burdens. The survey received a total of 69 repair station respondents, representing a combined 369 facilities certificated under various national aviation authorities.
Of those facilities, 42 percent hold ratings for completed products, 73 percent for components and 39 percent specialized services. All respondents are FAA certificated, 82 percent hold EASA certification, 29 percent hold Civil Aviation Administration of China (CAAC) certification and 20 percent a certificate from the National Civil Aviation Agency of Brazil (ANAC).
On average CAAC proves the most costly certificate to maintain, with respondents reporting auditing fees and expenses of more than $11,000 on average.
Reporting facilities received 6,723 paper and in-person audits in the last year including 797 from the FAA (including 209 from the certificate management office [CMO], which illustrates the continuance of redundant agency reviews), 1,183 from internal sources, 2,698 from customers and 277 for commercial certification (e.g., ISO, NADCAP).
The audits resulted in 561 findings, 79 of which were from the FAA, 173 found internally, 70 from customers and 41 from commercial certifications.
Of those findings, 57 percent were administrative (e.g., typographical errors), 25 percent contradictory (i.e., different opinions on what constitutes compliance), 21 percent duplicative and 10 percent concerned commercial requirements (i.e., contractual or business obligations).
Thank you to the repair stations that participated in the survey. The response data is a valuable tool in the effort to simplify auditing requirements. Stay tuned.
February 9, 2016
In August 2014, the Federal Register published the FAA’s final rule amending 14 CFR part 145. The new repair station rule omitted the word “serious” from the service difficulty reporting requirement in § 145.221. ARSA led a coalition of aviation interests in petitioning the agency to re-insert the word, which was done in concert with the rule’s Nov. 10 effective date; in 88 days, the association and its allies averted a “serious” problem.
Register today for the 2016 Annual Repair Symposium and attend a Friday morning breakout session on the FAA’s Aviation Data Exchange (AVDEX) program – join the effort to improve the agency’s system for managing service difficulty reports.
December 4, 2016
In 1963, an iconic episode of The Twilight Zone shook the nerves of travelers everywhere with a haunting suggestion: There’s something on the wing. Passenger Bob Wilson spent his “nightmare at 20,000 feet” desperately trying to alert others to a wing-walking gremlin bent on destroying the aircraft and dooming its passengers.
The aviation maintenance community’s gremlin is not a physical (or hallucinated) being, but rather the uninformed, hackneyed and all-too-well publicized fears that the “rise” of contract maintenance has a negative impact on aviation safety. The association has long battled with forces bent on dooming the entire industry. It has, despite extremely limited resources, repeatedly repelled false safety and economic campaigns designed to denigrate “outsourced” labor.
ARSA’s positive publicity campaign, media relations and communications efforts have succeeded in counteracting negative press. Similarly, ARSA’s legislative effectiveness has dissuaded lawmakers from openly micromanaging repair stations. However, the industry can’t take the association’s recent feats for granted. Contract maintenance’s opponents are well-funded and politically connected. They, just like ARSA, understand that media (whether factual or not) drives Capitol Hill action and reaction.
It is no coincidence that with the FAA reauthorization process underway in Congress, the aviation maintenance gremlin has returned in full force. In November, Vanity Fair (the same publication that promises the ultimate holiday gift guide, from cashmere to kayaks) took a strong interest in aviation safety. It published James B. Steele’s “Disturbing Truth About How Airplanes are Maintained Today.” Disturbing is putting it mildly.
As a work of fiction, Mr. Steele’s story is entertaining. Unfortunately, when his “investigation” of contract maintenance stumbles upon actual truth, it is repeatedly presented mendaciously: misleading, incomplete and designed to arouse popular passions rather than accurately assess a vital industry. It’s a shame to miss an opportunity for a frank discussion about the men and women who keep the world safely in flight; in its place we got a lazy, half-hearted exposé that scores useless points based on old or inadequate references.
Christian A. Klein, ARSA’s executive vice president and a fellow managing member of Obadal, Filler, MacLeod and Klein, PLC, wrote an incisive and direct response to Mr. Steele’s bile. To paraphrase Christian’s assessment: the author is either ignorant or dishonest. Either way, he has underscored the need for repair stations to have a strong voice.
By replacing Mr. Steele’s skewed narrative with the truth – the world can’t fly without the hard working, safety conscious, talented men and women who turn wrenches and run tests every day – ARSA and its allies provide an invaluable service. For maintenance providers, the association’s efforts translate into a more-favorable regulatory and business climate. For the flying public, this work means open access to the safest era in the history of air transport.
To continue to combat opponents, the association needs your financial support. It is time for you to get new ARSA members, attend and sponsor the annual symposium, and participate in ARSA training. While the association does champagne work, it is on a beer budget. Without resources, success won’t continue; the better funded will inevitably prevail. In other words, ARSA will continue fighting; but, without financial resources, that thing on the wing can bring us all down.
November 6, 2015
A: The new rule, which will allow PAHs to issue FAA Form 8130-3s instead of requiring an FAA designee’s signature, becomes effective on March 29, 2016.
Industry has requested that the agency allow early compliance so PAHs may implement issuance of the FAA Form 8130-3 prior to that date. The ability to exercise the privilege early will facilitate system transitions. Early compliance may be allowed by the end of this year, but there has been no definitive response from the agency to date.
Obviously, allowing early compliance would help ease the workload for the Manufacturing Inspection District Offices (MIDOs) review of the PAH procedures to implement the new privilege.
Resources and guidance on the MAG change can be found throughout this month’s edition of the hotline. To learn more about this and other issues related to the new rule and MAG Change 5 visit http://arsa.org/mag-change-5/ or access the on-demand recording of ARSA’s recent listening session The FAA, EASA and MAG Change 5.
October 5, 2015
As the 2015 Strategic Leadership Conference approaches, ARSA thanks the following sponsors for their contributions. This invitation-only event for aviation maintenance executives is made possible due to the generous support of sponsors.
September 3, 2015
Engaging with the government is not always easy, but persistence is key to aviation safety and business success. Contrary to what you may think, angry mobs with pitchforks don’t form over compliance issues. Even more importantly, anger, mobs and pitchforks have very little impact on the highly-regulated civil aviation industry. There are more modern and civilized tools for righting regulatory wrongs.
Any person who is affected by the FAA’s regulations – codified in Title 14 of the Code of Federal Regulations (14 CFR) – may petition for either exemption from an existing rule, or for the issuance, amendment, or repeal of a rule. These are known as petitions for exemption and petitions for rulemaking. If either of these types of petition is denied, the petitioner may seek reconsideration. The process for submitting these petitions is outlined in 14 CFR part 11.
No matter the outcome, petitioning for rulemaking or exemption can be a meaningful way to implement change or call attention to a matter. When the existing regulatory framework doesn’t allow a particular action or inaction, consider asking for a change in the rule, or for exemption from it.
Learn more about the process of petitioning for rulemaking or exemption and access templates, examples and other resources on ARSA’s petitions issue page.
August 7, 2015
A Self-Paced Training Session
The FAA has issued another legal interpretation on the term “overhaul” – stimulating a flurry of member questions about the term’s applicability to the everyday work of maintenance providers. In this edition of the hotline, ARSA offers a complete education on the matter using the association’s three levels of training. Class is in session.
Required Reading: [Hotline Feature] Overhaul Reviewed Yet Again
Get background on the issue from ARSA’s initial post on the newest interpretation, including the association’s previous engagement with the agency on the topic.
Level 1: [Legal Brief] “Overhaul” – The Price of a Word
Learn the details and follow the word’s journey through decades of interpretation and debate.
Level 2: [A Member Asked] Inspected, Repaired or Overhauled?
Put the issue in context by considering it through the questions of fellow ARSA members.
Level 3: [Sarah Says] ARSA Insurance: Your Policy Against Bad Policy
Apply the lesson to your operations in the regulatory world. More importantly, apply ARSA’s work to your success in that world.
July 6, 2015
By Christian A. Klein, Executive Vice President
Paying ARSA dues is a resource investment that makes your company stronger. Just like any other business asset, the return on investment (ROI) depends on how well the association’s products and services are incorporated into business strategy. Frequent use by employees who are encouraged to take advantage of an asset or resource increases its value and ROI.
How does ARSA make your business better?
- Ensures you can understand and comply with aviation safety regulations.
- Connects you with top regulatory and elected officials.
- Elevates your profile and brand with aviation industry customers and peers.
- Shares best-practices to improve business efficiency.
- Supports employee recruitment, training and retention.
- Provides industry economic data for long-term trending and effective business planning.
- Improves your public and media relations.
Step 1 – Communicate
Understanding and sharing ARSA’s products and services is the first step in maximizing ROI.
If you’re the only one in the company receiving ARSA communications, you’re definitely not maximizing ROI. ARSA recommends you add:
- Owners and C-level executives so they can be in the loop on major policy developments, economic data and opportunities to engage other industry leaders and government officials at the Annual Repair Symposium and at the “by invitation only” Strategic Leadership Conference.
- Quality and/or legal team members so they can obtain regulatory content in the communications, at the symposium and through ARSA online resources that keep members abreast of developments. They also need to know ARSA specialists can provide guidance on regulatory compliance questions in real time and that Obadal, Filler, MacLeod & Klein, PLC provides discounted legal fees for ARSA members should compliance and enforcement matters arise that need confidential handling.
- Your human resources people to keep them abreast of drug and alcohol testing issues, online and in-person training programs and recruitment tools.
- Your PR folks so they are aware of ARSA’s media outreach resources.
- Your marketing team so you can take advantage of ARSA’s resources to reach new customers (advertising in ARSA publications and sponsoring conferences).
Step 2 – Delegate
While individuals in all roles should be getting ARSA communications and updates, maintaining the relationship with ARSA (and other trade associations to which you belong) needs to be part of someone’s job description. Ensure the relationship and ROI is institutionalized and designate a primary point of contact. Being the association liaison shouldn’t be something that person does in his or her spare time as an extracurricular activity; it should be part of their daily responsibilities. Incorporating that role into a job description sends a powerful message from management that trade association relationships matter. It becomes the company’s stated commitment to keeping its ROI strong because someone is accountable for maintaining the most beneficial relationship, even if the person in the position changes.
- The company expects the employee to spend time on the ARSA relationship (e.g., reading its communications and passing on pertinent information, attending meetings, responding to industry surveys and keeping an eye on short, medium and long-term industry and government strategies).
- Someone will be held responsible for the company’s ROI (for example, by briefing coworkers about key takeaways from ARSA meetings, keeping teammates abreast of new association resources and making sure the association has updated contact information for all appropriate employees).
Step 3 – Allocate
Membership dues are your core investment in a trade association. At ARSA dues give you access to a wealth of information and support aggressive regulatory and legislative advocacy on the industry’s behalf. But the more a company invests in strong resources, the more that business can benefit. At the very least, annual budgets should include money for registration fees and travel costs for ARSA events, access to training programs and necessary publications.
Budgeting to sponsor ARSA meetings or advertise in publications will raise your profile or reinforce your brand as an industry frontrunner. Leading companies are committed to budgeting money to support special ARSA projects (a great recent example is Lufthansa Technik, HAECO, Coopesa, and HEICO’s sponsorship of “You Can’t Fly Without Us,” the industry documentary the association recently helped produce for PBS).
ARSA’s staff has built an organization that provides enormous value to its members and the industry; make sure you’re getting the ROI you deserve. The steps are not only easy, particularly considering the value to your business – not to mention your customers and the flying public – they are necessary.
“Recreational or Medical” Marijuana vs FAA/DOT Drug Testing
June 5, 2015
By Shirley Negri, NATA Compliance Services © 2015 Shirley Negri ALL RIGHTS RESERVED
Nearly 50 percent of the United States currently has laws legalizing marijuana in some form. (See Map.)
How does this impact your repair station? Technically it doesn’t, if your operation performs maintenance on commercial aircraft operations including air tour for hire.
The Department of Transportation and the FAA maintain requirements that all “safety-sensitive or covered” employees (e.g., A&P Technicians, Sheet Metal Mechanics, Avionics Technicians) be subject to drug and alcohol testing. Further, regardless if marijuana was used for recreational or medicinal purposes in a state that has “legalized” the activity, detection of use will result in a positive drug test.
NATA Compliance Services (NATACS) is the aviation industry’s only full-service employee background investigation and HR-compliance company. To learn more, visit http://info.natacs.aero.
April 2, 2015
On Mar. 4, the Northrop Rice Foundation announced the 2015 ARSA Scholarship had been awarded to Paul Mart of Daytona Beach, Florida. Mart is an AMT student at Embry Riddle Aeronautical University (ERAU).
Mart is pursuing a Bachelor of Science in Aviation Maintenance with a concentration in maintenance management in addition to minors in aeronautical studies and flight. Before arriving at ERAU, Mart earned credits at Green River Community College and the University of Colorado, Boulder.
Mart has a passion for advancements in industry-leading avionics and an interest in business aviation. His goal is to someday be Director of Maintenance at a corporate flight department, but Mart understands the work ahead and looks forward to it. Crediting his parents, who immigrated to the United States from Romania, with teaching him invaluable lessons about hard work and sacrifice, Mart has a clear vision of where he’s going and what it will take to get there.
“It is clear that Paul will be a leader in the industry,” noted one of his instructors in a recommendation letter. “He has all the right characteristics that will help him be a great mechanic and [give him] the desire to grow.” Those characteristics, outlined across all of Mart’s recommendations, include effective personal skills, a meticulous nature and the highest level of integrity.
In short, Mart will be a great asset to the aviation maintenance community and the flying public. It is for people like him that ARSA supports this annual scholarship through NRF; those that will grow the industry, uphold the highest ideals of its work and keep the world safe in flight for years to come.
To see all of NRF’s scholarships and winners, click here. Start getting your materials ready for next year; applications are due December 1, 2015.
March 5, 2015
In addition to the aviation maintenance industry’s premier event, spring is a fertile time for the aviation community to come together. Take every opportunity to represent your business in front of colleagues, partners and decision makers.
Stay tuned to ARSA’s industry calendar for more opportunities to come together.
AEA – Aviation Leadership Summit – Dallas, Texas – April 8-11
ATEC Annual Conference – Orlando, Florida – April 11-14
MRO Americas – Miami – April 14-16
Aerospace Maintenance Competition – Miami – April 14-16
Aircraft Interiors Expo – Hamburg, Germany – April 15
Many Signs of New Life – For Industry, ARSA and Its Partners
February 5, 2015
In March, ARSA will release its annual Global MRO Market Assessment. This year’s release marks a special milestone for the consulting firm formerly known as TeamSAI, the association’s partners in providing analysis and insight into the growing aviation maintenance market.
On Feb. 2, Atlanta-based TeamSAI was acquired by Oliver Wyman to be integrated into CAVOK, the firm’s aviation technical services and consulting practice. The combined entity creates a deep source of expertise with over 130 dedicated, full-time specialists who assist airlines, MRO providers, lessors and other aviation and aerospace stakeholders with mission-critical issues surrounding certification, safety and performance and execution support for technical operations.
CAVOK will be at this year’s Legislative Day and Symposium, be sure to see them.
“The expanded content from this change of ownership should be a great advantage in providing even wider content and resources to ARSA and its members,” said Chris Doan, friend of the association and new vice president of CAVOK.
To celebrate this union, and to look forward to the 2015 Global MRO Economic Assessment, this month’s Quality Time highlight highlights Signs of New Life, the report of Oliver Wyman’s MRO Survey 2014. Going on its second decade, the annual survey is an industry standard for information about changing trends in aviation maintenance.
MRO Survey 2014: Signs of New Life – New Partnerships, Fresh Hiring, 3D Printing
Authors: Chris Spafford, Partner and Darryl Rose, Principal
Original equipment manufacturers won the market for high-value, aftermarket aviation services, leaving independent maintenance, repair and overhaul providers scouting for paths to evolve and grow.
The survey found engine and component MROs are preparing to fortify their remaining footholds through strategic partnering and by accelerating development of unique services. Airframe MROs, meanwhile, seek to capitalize on shifts caused by rising labor costs in emerging economies.
- M&A in the sector to heat up.
- S. MROs to step up hiring.
- 3-D printing to be used to make expendable parts, but not proprietary materials.
Have you read the full report? Download it now at: http://www.oliverwyman.com/insights/publications/2014/apr/mro-survey-2014.html.
January 7, 2015
Obadal, Filler, MacLeod and Klein, PLC, the firm that manages the Aeronautical Repair Station Association, is continually accepting law and graduate student applications for its internship program. Interns will gain first-hand knowledge of the legislative and regulatory process and get a behind-the-scenes look at public policy and the impact it has on critical sectors of the economy. Interns will monitor developments in the nation’s capital, draft content for various publications, conduct research on a variety of policy issues, attend industry and congressional events and play a hands-on role in support of the aviation maintenance industry.
Applicants must work well in a team setting and demonstrate independence and initiative in achieving specific tasks and overall objectives, in addition to possessing excellent written and verbal communication skills. Compensation and/or school credit is available, and hours are flexible to accommodate student schedules.
December 4, 2014
The 2015 Aerospace Maintenance Competition (AMC) skills event will be co-located with Aviation Week’s MRO Americas in Miami, Florida on Apr. 14-16, 2015. The 2015 AMC promises to be bigger and better with more teams and a larger audience – a battle of the best skilled maintenance professionals in the industry.
The AMC’s sole purpose is to raise awareness of the training and skills needed to provide safe and airworthy aircraft worldwide. Compete with current and future maintenance professionals as they test combined abilities against their peers.
Competition Categories include:
- Commercial Aviation
- General Aviation
Don’t miss the competition of the decade and see who will take home the William F. “Bill” O’Brien Award for Excellence in Aircraft Maintenance and the Charles E. Taylor Professional AMT Award.
Limited sponsorship opportunities are available. Contact Beth Eddy or Mimi Smith at Aerospace Marketing Group for more details: email email@example.com or firstname.lastname@example.org or call +1 561-279-4646.
Sign up your team to compete: Contact John Goglia at email@example.com or call +1 703-597-4502.
November 7, 2014
By Mohan S Perumal, Ramco Systems
The MRO is a key component to keeping aircraft in the air – safely and efficiently. The mechanic is called to do multiple things in servicing a component, an engine or an aircraft. These highly skilled and important functions are the heart and brain for the equipment and the industry. The more time s/he allocates to ‘actual’ servicing tasks, the better the outcome, for the customer, the public, the job and the MRO business.
Any ‘tool’ that reduces a mechanic’s paper work and other administrative tasks frees crucial time to do ‘real’ work – ‘wrench time.’ As a direct result, owners realize a cumulative positive impact on the business’ bottom lines.
Talk about stating the obvious!
In reality, exploring the deployment of technology-driven ‘tools’ into most MROs’ daily work routines brings to light several significant needs for improvement.
In this and subsequent articles we will explore the Information Technology (IT) infrastructure, systems and applications that can be used to enhance an MROs efficiency. This knowledge will, in turn, open doors for deployment of newer, tested and credible technologies to achieve even greater business benefits.
To set the stage, let us look at the simple yet profound example of the use of technology in fulfilling our banking needs. Most, if not all, of us seldom go to a bank these days. From reviewing statements to paying bills and transferring funds–it is done using smart phones, tablets or at least a computer! This reduces time expended on this routine task, freeing us to expend it on more valuable pursuits. This example has a serious parallel to the MRO workplace.
To begin, let us look at the routine task of labeling and tagging parts. The picture provides a simple evolution.
The change from hand written, paper labels to bar codes was good. However, only the part number and serial number could be bar coded. Today Quick Response (QR) codes can contain all the information available on a given article. The data can be generated and incorporated on a tag or in or on the component itself along with human-readable information. Scanning the QR code can provide information on time between overhauls (TBO), service bulletin incorporation, etc. The data will help decision making for picking articles and repairs and tracking performance.
A Radio Frequency Identification (RFID) can even store more information and does not require a scanner. Walking through the area, the tag can tell the person where an article is located, what its performance and/or life status. This allows distant decision-making and ensures the right part is picked for the right application.
These technical advances have increased efficiency and are routinely used on the airline operations and passenger side of the business, from the
electronic boarding passes on smart phones to the RFID checked bag tags that allow the routing of the bags to the correct flights. When such tools are already in action supporting the safety and efficiency of the aviation industry, it is time to deploy similar tools in MRO operations.
Here is a sample QR Code; use your smart phone QR code scanner available through a free app to read the information!
The views and opinions expressed in this article are those of the author’s and do not necessarily reflect the policy or position of Ramco Systems, hence shall not be liable for any damages arising out of the same.
October 2, 2014
By Daniel Fisher, Vice President of Legislative Affairs
Aviation stakeholders and lawmakers are once again gearing up for another round of Federal Aviation Administration (FAA) reauthorization lawmaking on Capitol Hill.
The current authorization, the FAA Modernization & Reform Act, expires on September 30, 2015. The reauthorization process, which should happen every few years, allows lawmakers to set funding levels and policy priorities for the agency. As Congress crafts new FAA legislation, threats and opportunities abound, and undoubtedly, old ideas will resurface, many that are detrimental to the aviation maintenance industry.
ARSA and its industry partners scored major victories in the FAA Modernization & Reform Act; however, our success was based on preventing detrimental policies from enactment. While ARSA is already engaging lawmakers on the association’s top legislative priorities, the industry will once again be playing defense to stop recycled, anti-contract maintenance proposals and countering false safety and economic arguments about aviation maintenance companies.
ARSA fully expects efforts to curtail contract maintenance on U.S. air carriers, drug and alcohol testing of foreign repair station employees, and mandatory inspections to resurface. Once a bad idea is unveiled in Washington it never disappears. Through education and engagement, ARSA and its members have laid a strong foundation to counteract interests opposed to our industry. However, those hostile to contract maintenance are well-funded, well-connected, and adept at swaying public perception.
Consequently, the aviation maintenance industry must remain engaged both with lawmakers and the media. Below are five activities every ARSA member company should do to ensure favorable policy outcomes in the next Congress:
1. Host candidates and elected officials to visit your facility. The most effective way for policymakers to understand the industry and see the role your repair station plays in the local community is through a company tour.
2. Attend ARSA’s Legislative Day on March 18, 2015. Stay tuned for Legislative Day/Symposium registration in the coming weeks.
3. Learn more about ARSA PAC. ARSA PAC is a special fund that enables the entire aviation maintenance industry to speak with a common voice in the political process and elect candidates who share its legislative goals.
4. Vote on November 3. Participation in the democratic process is an important part of active citizenship. ARSA encourages its members to vote – it’s one of your most basic and important democratic rights. You can’t complain about your member of Congress if you don’t vote!
5. Engage the media. Any opportunity you have to educate the media about contract maintenance’s excellent safety record and contribution to the local economy will help shape policy.
We need your assistance to ensure recycled, bad ideas don’t become terrible laws. ARSA’s legislative and communications team is standing by to facilitate your engagement with key audiences.
September 5, 2014
By Sarah MacLeod, Executive Director
We interrupt your regularly scheduled programming to bring aviation maintenance to a screen very near you…
Coming Soon: ARSA’s in the director’s chair. You’re the producer.
For over 100 years, aviation has captured the world’s imagination and inspired many to soar higher and faster in search of adventure and service of mankind. It’s a great drama with many great actors – from the pilot’s seat to the mechanic’s work station to the passenger cabin. Telling that story is central to ARSA’s mission.
Commercial Break: What is an Aircraft Mechanic?
A key way we communicate this narrative is through constant engagement with regulators. Our team of experts from the law firm of Obadal, Filler, MacLeod & Klein PLC works every day to manage the intersection of business and government. They write letters, attend meetings, make phone calls, provide advice and wear a path around Washington, D.C. and across the world to represent ARSA’s members.
Commercial Break: Beauty over the North Atlantic.
Working behind the scenes is powerful, but setting the scene for the public through media relations and positive publicity is essential. Filmmakers have taken to the skies for years, trying to capture and package the majesty of flight for audiences stuck on the ground. The catalogue of aeronautical motion pictures – from sensationalized feature films to sober documentaries – has covered nearly every corner of the flying world. While repair stations have made it to the screen, the industry still needs a central, seminal work that will tell the world who we are.
Commercial Break: Aircraft Mechanic Training.
The association has been working for months with a professional production company to develop a short documentary about the aviation maintenance industry. It will be the definitive profile of the industry for years to come. The piece will run on public television stations around the country as part of the Leading Edge series, which is hosted by former NFL coach and TV sports commentator Jimmy Johnson. The broadcasts will be a great way to get your message in front of an educated and influential audience.
Commercial Break: Aviation – The Invisible Highway.
But more importantly, the video will be a tool for you. The association will distribute it to members all over the world, who will use it to paint a picture of a dynamic, growing, technologically-sophisticated industry that is improving aviation safety and making major contributions to the global economy. Join this work by sponsoring the project and displaying your logo prominently at the end of the film. Your company will get visibility and recognition as an industry leader around the world for years to come.
Commercial Break: The FAA Talks Maintenance.
Through the examples in this piece, you’ve seen a small sampling of the industry’s catalogue of works. With your support, ARSA can produce one definitive work to show the world who you are and how vital aviation maintenance is to their lives and livelihoods. They can’t fly without you. Become a participating sponsor and be celebrated every time the credits roll.
Credits: Help ARSA tell your story.
August 7, 2014
By Brett Levanto, Director of Operations
Come together with us. Start planning now for ARSA’s 2015 Annual Repair Symposium.
Sarah has already described how important industry-wide cooperation is for ARSA and its members. Individually, we complete work and serve customers. Together, we enhance the maintenance industry and protect the flying public.
The repair station community must work together to guarantee the safety of crews and passengers worldwide. ARSA ensures that happens. The symposium is the perfect place to connect with officials from the FAA and other authorities, as well as key members of Congress and your colleagues. It is an opportunity to join aviation professionals from around the world and engage on issues that directly impact the maintenance industry. Indeed, last year’s conference created an opportunity for quick resolution — “ARSA Works: Engagement Sparks FAA Action.”
The 2015 Annual Repair Symposium will be held March 18-20 in Arlington, Va. For more information, visit our events page.
July 1, 2014
By Ciara Chambers
Access to regulatory, business, and legislative knowledge is one of the key benefits of ARSA membership. We are standing by for your calls, questions, or clarifications. The association will go a step further, though, and give you the tools to build your own knowledge before the problem even arrives.
Our recorded webinars and training sessions are one way ARSA will “teach you how to fish.” They’re all waiting for you; you can start a session right now.
One of the featured training courses available through ARSA is “How to Answer a Letter of Investigation.” In this session, ARSA Executive Director Sarah MacLeod outlines the steps for a company to take in order to answer a letter of investigation from the FAA in writing.
Regardless of the alleged violation, a company will want to handle the scenario in the same way, with a written response. As an “alleged violator”, this is how you tell your side of the story. MacLeod describes the effective format to properly respond to all of the allegations in a factual manner.
You don’t have to panic when you receive an LOI. Take 30 minutes right now to prepare yourself: sign up to view Sarah MacLeod’s training webinar. Editor’s note – Direct registration for this session is no longer available. Interested registrants should contact ARSA directly for assistance.
There was a popular movie released in 1985 about time travel; you might remember it. While the film didn’t choose to address aviation — a flying car in the last sequence doesn’t count — its year feels like a fitting destination for some ARSA time traveling. Let’s take a peek back at this very publication in December of 1985:
For the past 30 years, this association has used every means available to educate its members, inform the public, and communicate with government about the aviation maintenance industry. Then, as now, we have always sought to trumpet our successes and highlight every way that we have made things better for our members.
In the best of cases, we can simply step aside and let our members tell the story for us. In December of 1985, we did just that. Let’s look back:
Members Speak Out (December 1985)
We have been telling prospective new members as well as existing members how we felt they could benefit by joining ARSA. All of these “good things” which we say we can do for you, may seem vague and uncertain and perhaps you have considered such problems not really “my problems”.
Rather than repeat a list of typical items on which we feel ARSA can be effective, we would like to reprint a portion of a letter received from one of our members detailing his experience in a particular issue which was brought to our attention. We quote from his letter:
“We were in the process of expanding our powerplant repair station operations to include crankcase repairs when the FAA put a halt on our operations. They advised us to go through ‘Engineering’ to obtain official approval for such repairs.
However, our region couldn’t handle our request for approval because of lack of expertise in this field. In fact, some engineers in our region never heard of welding or repairing of crankcases and even said it would be better if I bought out another business that already had approval for that repair.
That’s when I called ARSA. I received your letter about the time I was ready to call my Congressman.
ARSA was on the problem immediately, and in fact, we were cutting through red tape in weeks. … ARSA’s persistence in finding us the ‘right’ people in the FAA to deal with won out. … We now have our approval.
That’s why I think that ARSA is a must for anyone in the repair station business in general aviation. At least, we now have knowledgeable spokesmen on our side to help us form ONE FAA with the same rules and guidelines for everyone.
Thank you again, ARSA, for your consideration and promptness in dealing with this matter.
George Czarnecki ,
President Central Cylinder Service, Inc.
Repair Station No. 312-9”
[View the edition here.]
Sound familiar? There is certainly more work to be done, but ARSA’s commitment to finding the “right” people and getting the “right” answers is as steadfast today as it was 29 years ago.
Central Cylinder Service is still an ARSA member. Learn more about them at http://www.centralcylinder.com/.