2018 – Edition 2 – March 2
Table of Contents
Note: The order of material varies in hotline emails, but is always presented the same on this landing page. Readers scrolling through content on or printing this page will find it organized consistent with the table of contents.
ARSA Unveils Full Agenda of Engagement
On Feb. 28, the ARSA unveiled the full agenda for its 2018 Annual Repair Symposium, which will include events in and around the nation’s capital from March 13-16. In the two decades since ARSA first hosted the symposium, it has grown to include a Legislative Day of congressional engagement and – new this year – a day of Executive to Executive (E2E) Briefings. The expanded event provides a platform for aviation maintenance industry leaders seeking to influence government, learn about the newest regulatory developments, get up to speed on industry economic trends and network with peers.
The inaugural E2E day (March 13) will bring officials from the Departments of Commerce, Transportation and State face-to-face with a select group repair station leaders for updates on administration priorities. Then, on Legislative Day (March 14), ARSA will turn on its grassroots legislative advocacy by delivering industry professionals to the Hill for congressional meetings. Top issues this year include FAA reauthorization, workforce development, regulatory reform and government contracting. Participants will break for lunch with Senator Jim Inhofe (R-Okla.) and the release of the 2018 Global Fleet & MRO Market Report, produced for ARSA by Oliver Wyman.
The traditional symposium will come to order on March 15. Speakers will include aviation safety officials from the United States, Europe, Canada and Brazil in addition to industry and policy experts. Combined with FAA-lead breakout sessions on safety assurance and contract oversight on March 16, the 2018 Annual Repair Symposium will live up to its reputation as the industry’s premier substantive event.
“There’s always a bit of magic in watching the agenda come together,” said Brett Levanto, ARSA vice president of communications. “Announcing the schedule today is very satisfying, because it shows how all of the legwork and planning done by our team pays off: For four days, we’re going to be all over the nation’s capital – in office meetings and briefings, sitting for panels and listening to speakers, giving awards and enjoying each other’s professional company. The actual events are the reward for a lot of good work and a chance to do even more.”
Current registrants should familiarize themselves with the schedule in order to make the most of their trip. Registration remains open for interested attendees.
Video – “A Priceless Base of [Networking] Knowledge”
Hear from attendees at ARSA’s 2017 Annual Repair Symposium – both first-timers and experienced participants – about the value of networking at the repair station community’s premier event. The participants, panelists, speakers and special guests combine to form a “priceless base of knowledge”:
Video – “Be Persistent” at Legislative Day
Hear from attendees at ARSA’s 2017 Legislative Day – both first-timers and experienced participants – about the value of engaging with elected officials and the opportunity to do so with the repair station community. When you come to the nation’s capital and even after you go home: Be persistent.
The Platinum Sponsors
HAECO Americas & New Experiences
Special thanks to HAECO Americas for its Platinum Level Sponsorship of ARSA’s 2018 Executive to Executive Briefings, Legislative Day & Annual Repair Symposium in and around Washington, D.C. on March 13-16. The company continues its long-time support of ARSA events and has committed its 2018 sponsorship to the newly-added Executive to Executive Briefings.
By sponsoring “E2E,” HAECO Americas is supporting the direct connection between maintenance community leaders and American federal policymakers through meetings held on Tuesday, March 13. The current schedule includes stops at the Departments of Commerce, State and Transportation and a visit to the FAA’s acting deputy administrator.
Moog Aircraft Group & Breaking the Ice
Special thanks to Moog Aircraft Group for its Platinum Level Sponsorshipof ARSA’s 2018 Executive to Executive Briefings, Legislative Day & Annual Repair Symposium in and around Washington, D.C. on March 13-16. The company will serve up drinks, hors d’oeuvres and maintenance community networking at the March 14 “Ice Breaker” Reception, which begins at 5:30 at the Ritz-Carlton, Pentagon City.
Moog is regularly represented at ARSA’s events and the company understands the value of personal engagement. Through this sponsorship, Moog supports its fellow association members — and industry allies — by providing time for attendees to enjoy each other as colleagues and friends.
Lufthansa Technik & the Club Lounge
Special thanks to Lufthansa Technik for its Platinum Level Sponsorship of ARSA’s 2018 Executive to Executive Briefings, Legislative Day & Annual Repair Symposium in and around Washington, D.C. on March 13-16. One of the association’s leading European members will share its continental hospitality (and German precision) at the Club Lounge Happy Hour at the Ritz-Carlton, Pentagon City: Doors open at precisely 5:00 p.m. on March 15.
Lufthansa Technik’s commitment to ARSA has long underscored the association’s impact beyond the United States. By dedicating time and resources to symposium — and helping attendees relax after a hard day of engagement with regulators, government leaders and industry professionals — the company has become an essential part of ensuring aviation safety worldwide.
FAA Lifts DCT Burden from Industry
On Feb. 20, FAA Notice 8900.451 became effective, setting the policy for completing data collection tools (DCTs) associated with the agency’s Safety Assurance System (SAS). The notice states that applicants and certificate holders shall not be required to complete any component of the DCTs until the FAA Flight Standards Service obtains approval from the Office of Management and Budget (OMB).
The policy update was issued in response to ARSA’s Feb. 1 letter on the subject. Citing the common practice of aviation safety inspectors requiring applicants and certificate holders to answer the DCTs’ numerous questions, the association highlighted the Paperwork Reduction Act’s (PRA) prohibition against federal agency information collection without OMB approval. Considering the substantial time and expense demanded, the association’s letter reminded the FAA of its statutory obligations.
“We recognize that the agency has instituted the SAS to implement a risk-based approach to its safety oversight responsibilities,” the letter said, noting the demand placed on the FAA by Congress as well as executive branch auditors to implement reasonable safety oversight with limited resources. “However, those pressures do not relieve the agency of its obligations under the laws passed by Congress; particularly those that reduce the burdens on small businesses.”
Notice 8900.451 acknowledges that the PRA applies to all Federal agencies and that the FAA must seek OMB approval “regardless of whether the collection is mandatory, voluntary, or required to obtain or retain a benefit”. Ironically, the document then states that “use of the external portal to collect [listed information] will be voluntary.” Finally, the policy attempts to make clear that the DCTs, “are intended for inspector use only and should not be given to the certificate holder to complete.”
“Regardless whether the agency obtains OMB approval, we expect to see some fundamental changes,” said ARSA Managing Director & General Counsel Marshall S. Filler, who signed the Feb. 1 letter. “As currently constituted we find it hard to believe the OMB would countenance a paperwork burden of the magnitude dropped on applicants and certificate holders under the current DCTs.”
Any association that is told by an inspector to complete any portion of a DCT should contact the association immediately.
ARSA Urges Industry to Comment on EASA ICA Proposal
On Jan. 29, EASA issued Notice of Proposed Amendment (NPA) 2018-01 pertaining to Instructions for Continued Airworthiness (ICA); comments are due by April 30, 2018. ARSA urges all members interested in this important subject to submit comments. The NPA is the result of an effort begun in 2009 (Rulemaking Task 0252, MDM 056) to review the European Commission’s (EC) ICA regulations and determine whether changes are needed.
After evaluation of the comments received concerning the NPA, EASA will develop an opinion containing the proposed amendments to Part-21 and submit it to the EC as the technical basis to prepare an EU regulation. (Note: In Europe, the EC issues Implementing Rules. This rulemaking would affect one of those rules, Commission Regulation (EU) No 748/2012 dated Aug. 3, 2012 laying down implementing rules for the airworthiness and environmental certification of aircraft and related products, parts and appliances, as well as for the certification of design and production organizations.)
Following adoption of the rule by the EC, EASA would issue a Decision publishing the Acceptable Means of Compliance (AMC) and Guidance Material (GM).
The highlights of the NPA are:
(1) ICA would become part of the EASA type certificate although not all changes to the ICA would be considered changes to type design.
(2) With respect to components installed on the aircraft, engine or propeller, maintenance information would be ICA if it related to:
(a) The Airworthiness Limitations;
(b) The accomplishment of scheduled maintenance referenced in the product ICA, such as the periodic removal of a component for an inspection or test (e.g., hydrostatic test of a fire extinguisher in the shop); or
(c) If the supplier’s data does not relate to 2a or 2b but includes a maintenance instruction identified in the product ICA.
(3) On the other hand, if removal and replacement of the component was identified in the product ICA and the ICA did not reference the supplier’s maintenance instructions as necessary for continued airworthiness, the CMM/OHM would not be considered ICA. However, the DAH could still reference those manuals as additional or optional maintenance information without them becoming part of the ICA.
Availability of the ICA would not significantly change as it would require both the ICA and any subsequent changes to be made available to anyone required to comply with those instructions, such as owner/operators, approved maintenance organizations and continuing airworthiness management organizations (CAMO).
EASA indicated that its proposal would result in disharmonization with the FAA but did not specifically state why. However, current FAA rules do not recognize ICA as part of the type or supplemental type certificate and there would be subtle differences regarding which component maintenance data would be considered ICA if the NPA was adopted.
The Government Comes to You – SBA Regulatory Roundtables
The U.S. Small Business Administration (SBA) Office of Advocacy recently announced two new dates for its ongoing “regulatory roundtable” series. On March 19 in San Antonio, Texas and and March. 20 in Houston, Texas, the SBA will speak directly with small businesses about which regulations concern industry the most.
Any ARSA member that can attend either of these specific events is highlight encouraged to do so – and report back on the discussion. Regardless of possible attendance in Texas (or at future roundtables), every ARSA member should submit input to the office directly by following the link below and completing the input form:
The SBA Office of Advocacy is an independent office that serves as a voice for small business within the federal government, the watchdog for the Regulatory Flexibility Act (RFA) and the source of small business statistics. Advocacy advances the views and concerns of small business before Congress, the White House, federal agencies, federal courts and state policy makers.
The purpose of Advocacy’s Regional Regulatory Roundtables is to:
(1) Identify regional small business regulatory issues in order to assist agencies with regulatory reform and reduction in compliance with Executive Orders 13771 & 13777.
(2) Compile crucial information for Advocacy’s new report on existing small business regulatory burdens across the nation, identifying specific recommendations for regulatory changes based upon first-hand accounts from small businesses across the country.
(3) Inform and educate the small business public as to how Advocacy and SBA can assist them with their small business goals.
For more information regarding Advocacy’s efforts to help reduce the regulatory burden on small businesses and upcoming roundtable events, please visit: www.sba.gov/advocacy/regulatory-reform.
For those who can attend either of the upcoming dates in Texas, use the following links to register. For those who can’t, get active and submit an input form now:
Monday, March 19, 2018- San Antonio, Texas
UTSA Downtown Campus, Durango Building, SBDC Training Room, 501 W. Cesar Chavez Blvd., San Antonio, Texas, 78207
8:30 a.m. – 12:30 p.m. Regional Regulatory Roundtable (click here)
1:30 p.m. – 4:30 p.m. NAFTA Modernization Outreach Meeting (click here)
Tuesday, March 20, 2018- Houston, Texas
Amegy Tower, 1717 West Loop South Freeway, Houston, TX, 77027
8:30 a.m. – 12:30 p.m. Regional Regulatory Roundtable (click here)
1:30 p.m – 4:30 p.m. NAFTA Modernization Outreach Meeting (click here)
FAA Publishes Bonderite AMOC
On Feb. 5, the FAA published an approved alternative method of compliance (AMOC) allowing the use of the renamed Henkel “Bonderite” products for all airworthiness directives and previously-approved AMOCs specifically calling for the application of “Alodine.”
Henkel changed the product’s name from “Alodine” to “Bonderite” as part of a “branding strategy” begun in 2014. In identifying the product, as seen on the safety data sheet for Bonderite M-CR 1201 AERO, the company continues to note “known as Alodine.” For clarity, the Henkel website includes a statement regarding the new branding: “There will be no changes to the product’s chemical formulation…[or] specifications…All approvals and certifications will remain valid.”
However, since the former brand name was specifically called out in ADs and previous AMOCs, the FAA issued an additional AMOC to remove any doubt that the switch was legitimate. When contacted regarding the matter, ARSA did not believe the additional government step was necessary, but assisted the agency in assuring the new publication provided a clear path to compliance for users of the chromate conversion product.
“The FAA should learn from this,” said ARSA Executive Director Sarah MacLeod. “When it calls out specific materials in a law, such as an airworthiness directive, a simple marketing change made by a company producing those materials can require bureaucratic backflips. This [new AMOC] is a fine fix, but the government needs to be more circumspect in proscriptive rulemaking.”
For the industry’s sake, the need to develop this AMOC should underscore the importance of differentiating between the process – the chromate conversion coating – and a name-brand. Though “alodining” had become shorthand for process, it is in fact referring to a brand name. Just as the agency did in its rules, maintenance providers codified a product name into their “tribal knowledge” and only exacerbated the confusion caused by a company’s marketing efforts.
Final Documents/Your Two Cents
This list includes Federal Register publications, such as final rules, Advisory Circulars and policy statements, as well as proposed rules and policies of interest to ARSA members.
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.
Alodine is Not a Verb
By Sarah MacLeod, Executive Director
When brand names become synonymous with a process, confusion, complexity and – eventually – alternative methods of compliance (AMOCs) to airworthiness directives (ADs) result.
The FAA contacted the association for its take on the change of name by Henkel from “Alodine” to “Bonderite” as numerous service bulletins incorporated into ADs specifically names the former as the material that “must” be used to accomplish a conversion process on certain metals. My initial response was the same as almost 80 percent of the technical personnel that I contacted amongst ARSA membership: that alodine is used in alodining, which is a preservation process for non-ferrous metals.
So much for the wisdom of the crowd, because those technical personnel and I were wrong. The generic process is called chromate conversion and method of accomplishment is application of a coating containing chemicals, including salt, that create better adhesion for corrosion inhibitors or primers. It can also be used to provide a decorative finish or to retain electrical conductivity.
Chromate conversion coating is a type of conversion coating used to passivate steel, aluminum, zinc, cadmium, copper, silver, magnesium, and tin alloys. It is primarily used as a corrosion inhibitor, primer, decorative finish, or to retain electrical conductivity.
The bottom line is that Alodine is a brand name, not a process – when it is called out as “the” material to use in a service bulletin and that document is referenced in an airworthiness directive or in a document that is referenced in an AD, it becomes “mandatory.” So, instead of calling out Alodine, if the service bulletin required application of a chromate conversion coating, any “brand name” material could be used that resulted in the proper result. The service bulletin could even dictate a coating that complied with a standard as an “acceptable” alternative, which would in turn allow the use of that chemical compound without needing an AMOC.
As you can see, the web we weave becomes tangled; the agency was unsure of whether the AMOC for Alodine to Bonderite was even needed since the “new” named marking is saying that it was/is also known as Alodine, which “should” mean that there is no “alternative method” needed to comply since the original method is evidenced by the label.
Unfortunately, the agency (and industry) loves to err on the side of caution which of course leaves maintenance providers completely in the lurch. Even when a “decision” is made and communicated, more questions rise to the surface since people that were not aware or worried in the beginning start wringing their hands, too. For example, a “good” aviation safety inspector tried to answer some internal questions and found himself quite wrapped around the axle – the fact that an AMOC was issued indicated to other safety inspectors that one was actually needed.
In fact, if the AMOC was needed, it can be used to answer any questions relating to any other repairs or alterations and/or other instances where Alodine is called out. An airworthiness directive is the highest level of aviation safety compliance one can achieve – according to FAA legal interpretations (you know from the guys that have never turned a wrench in the field), an AD must be followed to the letter. If there are mistakes in the AD or in the service bulletin or in any document referenced in the service bulletin at any level (even three or four references down the chain), an AMOC must be obtained. This concept is known as “strict compliance” – these interpretations are being followed by some and ignored by others, but they exist just the same. Therefore, when an AMOC is issued, particularly a “global” one, it can be used to comply with less strict instances of rule compliance, such as calling Alodine out in non-AD situations, such as DER-approved repairs, “normal” SRM repairs and the like.
I hope this now is as clear as mud—if it is not and members still have questions regarding regulatory compliance with respect to the use of Bonderite instead of Alodine, please “ask ARSA” first!
ARSA on the Hill
Aviation Workforce in the Spotlight as ARSA Ramps Up FAA Bill Lobbying
By Christian A. Klein, Executive Vice President
It’s been a busy month for ARSA on Capitol Hill and things are about to get a lot busier!
I’ve been wearing out the shoe leather walking the halls of Congress in recent weeks building support for two important ARSA legislative priorities: aviation workforce development and improving Department of Defense procurement. We’ve made considerable progress in both areas.
As previously reported in “ARSA on the Hill,” the association has proposed legislation to create a new grant program that incentivizes collaboration between aviation companies, schools and local governmental entities to pursue innovative solutions to the technician shortage. The potential bill has gotten considerable traction on the Hill and, as of this writing, was set to be introduced in the Senate the first week of March by Sens. Jim Inhofe (R-Okla.), Jerry Moran (R-Kan.), Richard Blumenthal (D-Conn.) and Maria Cantwell (D-Wash.).
If you follow politics, you’ll appreciate how unlikely that group of senators (who aren’t just from different parts of the country, but from different ends of the political spectrum) is to agree on much. However, given the scale of the threat posed by the aviation workforce skills gap, all four are putting partisanship aside and leading the charge to help address the problem.
We’re thrilled to be working with this distinguished group of senators and equally thrilled that all the major trade organizations representing every sector of the aviation industry have endorsed the legislation (more coming on that…stay tuned).
Getting legislation introduced with bipartisan support is no small task, but we know that for ARSA the hard work is just beginning. Now comes the challenge of encouraging other senators to cosponsor the bill. The goal is to round up at least 60 cosponsors to queue it up as possible amendment when the FAA bill hits the Senate floor in the next few months.
Given developments in recent days, we don’t have a lot of time.
House Transportation & Infrastructure Chairman Bill Shuster (R-Penn.) announced Feb. 27 that was ending his bid to include language in the FAA bill privatizing U.S. air traffic control (ATC) (which is currently the responsibility of the FAA). Shuster had worked aggressively to build support for ATC privatization among his Republican colleagues. Although the proposal had strong airline support, the general and business aviation communities were staunchly opposed, which made it difficult to garner support from rural state members of Congress.
Shuster’s announcement means the FAA bill is back on track after months in limbo. That said, given that the current short-term FAA authorization expires March 31, another short-term extension (probably through the summer) will likely pass Congress in the next few weeks to give lawmakers more time to work out the details of a final bill.
As a reminder, ARSA members have a big stake in the outcome of the FAA bill debate. The Senate bill contains language supported by ARSA to restore the ability of repair stations to voluntarily surrender their certificates. The Senate bill would also task the FAA’s Aviation Rulemaking Advisory Committee to examine ways to enhance the value of repairman certificates. The House bill contains language directing the Government Accountability Office (GAO) to examine causes and consequences of the aviation technician shortage. Both the House and Senate bills would ensure that the aviation maintenance industry is represented on FAA’s new Safety Oversight and Certification Advisory Committee. ARSA will be working to make sure all those important provisions become law.
FAA Bill Maintenance Amendments Box Score
|ARSA Proposal||In House Bill||In Senate Bill|
|Adding “aviation maintenance” to stakeholders on new Certification & Oversight Advisory Committee||Yes – Amendment by Rep. Hank Johnson (D-Ga.) and Rob Woodall (R-Ga.) adopted by voice vote||Yes – Amendment by Sen. Jim Inhofe (R-Okla.) adopted by voice vote|
|Asking FAA to explore ways to enhance value of repairman certificates||No – ARSA is working to identify a sponsor||Yes – Amendment by Sen. Jim Inhofe (R-Okla.) adopted by voice vote|
|Directing FAA to undertake rulemaking to reinstate voluntary surrender of repair station certificates||No – ARSA is working with Rep. Dan Webster (R-Fla.) to include in House bill||Yes – Amendment by Sen. Jim Inhofe (R-Okla.) adopted by voice vote|
|Directing GAO to study causes, effects and solutions to aviation technician shortage||Yes – Amendment by Rep. Cheri Bustos (D-Ill.) adopted by voice vote||No – ARSA is working to identify sponsor|
|Creating grant program to support aviation maintenance workforce development initiatives||No – ARSA is working to identify sponsor||No – Sens. Jim Inhofe (R-Okla.) and Richard Blumenthal (D-Conn.) planning to sponsor amendment on Senate floor|
FAA reauthorization and the aviation workforce grant program will be front and center when ARSA members descend on Capitol Hill for the association’s annual Legislative Day on March 14th. Dozens of industry leaders have already signed up for the event, but the more foot soldiers we have for ARSA’s policy priorities, the better our chance for success. Please consider joining us in D.C. on March 14 and becoming an active part of our advocacy program. To register for the event, go to arsa.org/news-media/events/arsa-symposium/.
Aside from FAA reauthorization and aviation workforce, ARSA is also working to improve efficiency in Department of Defense (DOD) procurement. Our ask is simple: include language in this year’s National Defense Authorization Act (NDAA) to require DOD to accept FAA-approved products, materials, parts, components, processes and appliances for use on FAA-type certificated aircraft owned and operated by DOD (so- called “civilian derivative aircraft”). The provision would reduce the need for redundant DOD Source Approval Request (SAR) reviews. ARSA members tell us that DOD often lacks the technical resources, capacity and incentive to validate FAA approvals. It’s common sense that one branch of the government – in this case the DOD – should accept the approvals by the agency responsible for aviation safety.
It’s going to be a busy spring for the aviation maintenance industry on Capitol Hill. Whether you’re coming to DC for ARSA’s Legislative Day, hosting a member of Congress at your facility, writing a note to your representative in support of our initiatives, or getting more involved in our political program, thanks in advance for your support!
Want to Learn More About ARSA PAC?
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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.
Government Forecasts Partly Sunny Skies for Aviation Maintenance Careers
By Crystal Maguire, Executive Director, Aviation Technician Education Council
New Bureau of Labor Statistics (BLS) data may help pique the interest of would-be aviators. Aviation maintenance industry growth and open job projections nearly quadrupled since the Bureau’s last biennial report.
The latest Occupational Outlook Handbook adopts a new way to calculate the industry’s needs due to retirement, which accounts for at least some of the increase. Under the new approach, the projected number of openings for aviation maintenance mechanics and technicians over the next ten years increased from 3,300 to 12,400 per year. That number coupled with anticipated growth, which jumped from 1 percent to 5 percent, supports expected total employment of 157,000 by 2026.
While the numbers fall short of some industry demand forecasts, improvements in the BLS projections will have positive ripple effects. Since federal and local funding mechanisms and policymakers rely heavily on the dataset, the boost in numbers could mean more funding for things like educational partnerships.
Career development tools and resources should also paint a better picture for aviation technical careers. For instance, the U.S. Labor Department-sponsored resource MyNextMove.org historically dubbed aviation mechanic and technician jobs as “less likely in the future.” The new numbers upgrade the aviation maintenance career outlook from “below average” to “average.” (“Bright outlook” designations require 10 percent projected growth, or 100,000 or more job openings over the next ten years.)
It is important to note that the data does not distinguish between certificated and noncertificated personnel. A request by ARSA and other trade organizations to make the distinction went unheeded in the 2018 Standard Occupational Classification (SOC) revision.
In its response to the coalition’s comments, the SOC revision committee stated that—
“Avionics Technicians reflects a unique occupation. Avionics Technicians work on electronic equipment (avionics), while Aircraft Mechanics and Service Technicians work on engines and assemblies. Furthermore, the recommended breakouts for 49-3011 Aircraft Mechanics and Service Technicians were not accepted based on classification principles 2 [proposed classification not based on work performed], 6 [classification must delineate between supervisory and non-supervisory positions], and 9 [inability to collect and report data on the proposed occupations].”
The coalition will have an opportunity to respond to those comments, and once again attempt to influence change in 2026, which the codes are again up for revision.
Crystal Maguire is the executive director of the Aviation Technician Education Council, which represents part-147 certificated AMT schools across the United States. To learn more about the council’s advocacy on behalf of educators, students and the maintenance industry, visit www.atec-amt.org.
New Date: FAA Internal Training on Repair Station Certification Open to Industry
From June 11-15, 2018, the FAA is hosting another installment of its week-long training session “Certification and Surveillance of Part 145 Repair Stations.” It will be administered in person at the FAA Academy in Oklahoma City and is open to industry enrollment.
The course is designed to provide aviation safety inspectors with knowledge and skills necessary to participate as certification project team members for repair stations. Attending a session like this is the perfect opportunity for an industry professional to go directly to the source and see what the FAA is teaching its own personnel; it helps a lot to understand the perspective of an ASI if you know what they’ve been told about the rules…and it provides an opportunity to help the agency make the whole process better.
The course includes:
(1) Information on the differences between certification of repair stations located inside and outside the United States.
(2) Overview of international agreements for maintenance.
(3) Instruction on application of risk-based certification management.
(4) Review of what ASIs should look for during continuing surveillance.
Once students are enrolled, they will receive a welcome letter from the course manager providing specific instructions for access to the facility. For more information on logistics, individuals can reach out to the FAA Academy Student Services Section. Information regarding lodging options is also available through the FAA Academy Housing List.
The course is currently scheduled to be held multiple times this year after the June session. While seat availability cannot yet be determined for future sessions, consider contacting the FAA about getting your people into the classroom.
In case you can’t make it to Oklahoma…ARSA Online Training Resources
The association’s training program is provided through Obadal, Filler, MacLeod & Klein, P.L.C., the firm that manages ARSA. To go directly to OFM&K’s online training portal, visit PotomacLaw.inreachce.com. To learn more about the association’s training program and see course availability, visit arsa.org/training.
Featured Course (Click title for more information)
Public Aircraft Training Series – Package Available
ARSA’s three-part series on the regulations and guidance for public aircraft operation is ready for on-demand purchase. Purchase now and get 90 days access – unlimited viewing – to all three sessions. After completing the substantive presentation on the law and regulations and a review of FAA guidance pertaining to PAO, challenge your staff with 11 case studies designed to test comprehension and apply the rules and guidance to “ripped from the headlines” examples.
Description: This three-part series on the regulations and guidance for public aircraft operation will provide in-depth analysis and case-study review of various requirements. Sessions must be purchased together and viewed in order, completion of each pre-requisite – either via a live session or on-demand recording – is required for access to subsequent classes.
Instructor: Marshall S. Filler
Session 1 – The Law and Regulations
Session 2 – FAA Guidance
Session 3 – Case Study
Note: Public aircraft sessions must be viewed in order. Completion of each pre-requisite is required for access to subsequent classes.
Registration for the series includes:
- Access to the on-demand recording of each session for 90 days.
- Digital copies of the presentation and all reference material with links to relevant resources and citations.
- A certificate upon completion of each class (including any test material).
The association’s training program is provided through Obadal, Filler, MacLeod & Klein, P.L.C., the firm that manages ARSA. To go directly to OFM&K’s online training portal, visit potomaclaw.inreachce.com. To learn more about the association’s training program and see course availability, visit arsa.org/training.
From EASA – A Comic Safety Endeavor
ARSA loves it when agencies dare to get creative about aviation safety, so the European Aviation Safety Agency gets points for giving us the comic hero we all need right now. Welcome to the world, Sunny Swift, here’s to clear skies and tailwinds:
Join Sunny Swift in her adventures where she uses her skills as a GA pilot in mitigating risks while flying. This new initiative, which is part of the GA roadmap, will be available once a month on a Wednesday. For more information from EASA, click here.
Regulatory Compliance Training
Test your knowledge of 14 CFR §§ 65.17, 18 & 19 – Testing (Multiple Sections).
2018 NextGen Awards – Celebrate Young Talent
ARSA’s commitment to building the aviation maintenance workforce of the future means celebrating the excellence of the men and women who already keep the world safely in flight. The association encourages its members to celebrate outstanding young personnel through Aircraft Maintenance Technology Magazine’s Next Gen Awards. The 2018 schedule for the awards has been shifted earlier from previous years, so act now while memories of last year’s winners are fresh.
Criteria for selection include job commitment, industry involvement and contribution, professional achievement and innovation. Anyone working in any aviation maintenance field who will be 39 years old or younger on June 30, 2018 is eligible for nomination. Winners will be featured in the magazine’s August/September issue and celebrated on AviationPros.com.
Anyone submitting a nomination is encouraged to contact ARSA’s Vice President of Communications Brett Levanto, so the association can join AMT Magazine in celebrating the best of this community’s young talent. Through its experience with the awards program in 2015, ARSA saw first-hand the vital importance of celebrating the maintenance industry’s most valuable resource: its people.
Past NextGen Awards...
November 29, 2016
On Nov. 28, AMT Magazine announced its 2016 class of NextGen Award winners. For the second year, the publication honored up-and-coming talent by recognizing maintenance engineers, technicians and support staff under 40 years old.
The list includes eight winners from seven different ARSA member organizations:
Kevin Easley, Maintenance Supervisor, AAR Aircraft Services
Hilary Kerkstra, Turbine Engine Technician, Pratt & Whitney Engine Services
Carolyn Rena Kincaid, Manager of Training and Records Dept., AAR Aircraft Services
Joshua Krotec, Senior Vice President, First Aviation Services
Tony Oggs, Field Service Lead Technician, StandardAero
Josh Riehle, Director of Quality, HAECO Cabin Solutions
John Wing, Program Manager, PEMCO World Air Services
Xiang Yao, Lead Aviation Maintenance Technician, FedEx
“Taking pride in this group is easy,” said Brett Levanto, ARSA’s vice president of communications and 2015 NextGen honoree. “Every person – yes, even those whose employers aren’t ARSA members – represents the best in the aviation maintenance community. From diverse backgrounds, with different experiences and performing a wide range of needed tasks, each one keeps the world safely in flight. We can’t fly without them and we wouldn’t want to.”
Finding and retaining world class talent – like the names listed in AMT’s awards – has become a pressing challenge for repair stations and a key policy focus for the association. While celebrating the best and brightest is a great way to attract attention, ARSA also provides tools for building the aviation workforce of the future:
(1) Aerojobs.org. The web-based recruitment tool specifically targets individuals with the skills needed to maintain aircraft (regardless of what industry they’re in now).
(2) AVMRO.arsa.org. The industry’s information portal introduces the world of maintenance, repair and overhaul. The site has information useful to everyone from job seekers to the media to elected officials to nervous fliers.
(3) Propaganda. “You Can’t Fly Without Us,” a seven-minute documentary on the maintenance industry produced for public television. ARSA provides license for use of the film as an informational or recruitment tool. (Visit arsa.org/documentary to see how you can use the video.)
(4) Training. In addition to a growing library of on-demand recordings, live sessions are hosted weekly on regulatory compliance, government affairs, legal and business development topics. Everything you need to get better at your job and get ready for the next one. (Visit arsa.org/training for course information and to register.)
“While celebrating [the NextGen honorees’] hard work, let’s consider how to help them move ahead,” Levanto said, encouraging broader industry action. “Nurture their careers while attracting new applicants to work and learn alongside them.”
To see all of the winners, visit: www.aviationpros.com/article/12278511/2016-amt-next-gen-40-under-40-award-winners.
Are you from one of the organization’s represented on the list of winners? Click here to contact ARSA to share how you’re celebrating your young talent.
Welcome & Welcome Back – New & Renewing Members
ARSA’s members give the association life – its work on behalf of the maintenance community depends on the commitment of these organizations. Here’s to the companies that joined or renewed in February:
New Members (Member Category)
Renewing Members (Member Category, Member Since)
Aero Endeavors LLC dba Reliable Aerostructures, R01, 2017
Aero Tech Engineering Consultants, Affiliate, 2016
Airborne Maintenance and Engineering Services, R06, 2010
Austin Aerotech Repair Services, Inc., R01, 2012
BBA Aviation, Corporate, 2013
Brothers Aviation Maintenance Services, Inc., R01, 2016
Central Cylinder Services, Inc., R01, 1985
Dassault Falcon Jet, Associate, 1999
Eastern Airlines Technic Co., Ltd., R04, 2017
Gyros Unlimited dba North Bay Aviation, R03, 2011
INAir Aviation Services Company, R02, 2003
JetRight Aviation Maintenance, R02, 2015
Liebherr-Aeropsace Saline, Inc., R04, 2006
LiveTV/Thales Avionics, Inc., R05, 2006
Lone Mountain Aircraft, R01, 2017
Lufthansa Technik AG, Corporate, 2001
Mid-Continent Instruments and Avionics, R04, 1998
Nelson Engineering Co., R02, 2013
Ohlinger Industries, Inc., R04, 2006
Omnigas Systems, Inc., R01, 2001
Papillon Airways, R03, 2011
Tailwind Inspection, Inc., R01, 2006
TAP Maintenance & Engineering, R06, 2008
Toledo Jet Center, LLC, R03, 2010
Turbine Controls, Inc., R04, 1988
Vanguard Aerospace, LLC, R01, 2016
Quick Question – Other Government Agencies?
For the first time in 2018, ARSA is hosting a day of Executive to Executive (E2E) Briefings as a component of its 2018 Annual Repair Symposium. E2E participants will spend March 13 moving between the Departments of Commerce, State and Transportation (including a stop at the office of the FAA’s Acting Deputy Administrator) in an effort to spread the word about the aviation maintenance industry’s needs in terms of regulatory, trade and business policy.
Help the association consider further outreach to different parts of the U.S. federal government. Answer this month’s “Quick Question”:
Note: The question is displayed in its own, embedded window. If the “Done” button is not visible on the screen, you must scroll within the survey window in order to submit your response.
For more information about this or any other question, contact Brett Levanto (firstname.lastname@example.org).
Click here to see what questions have been asked and answered…and keep a lookout for more.
A Member Asked…
Q: I have a question regarding subcontracted maintenance and drug testing: We have a component that requires specialized equipment for a honing operation. The only vendor with equipment capable of doing the complex machining is located in Switzerland and is not certificated by any National Aviation Authority. If we send it the component to accomplish the honing repair, what is our Drug and Alcohol testing obligation? 14 CFR part 120 seems to exclude both employees of our repair station and any contract employees performing safety sensitive functions outside the United States, but I’d like a second opinion.
My direct questions are:
(1) Must we perform pre-employment drug testing and enter the workers performing the honing operation in our drug testing pool, even though they are not performing the work in the United States?
(2) If drug testing is required, would we be within our scope of authority to send an operator with the component to perform the work ourselves at the foreign facility?
Based on my reading of §§ 120.123 and 120.227 work performed outside the United States is exempt from the D&A testing requirements. If that is the case, and we choose to send an operator anyway, are we obligated to remove him from the drug testing pool while he is overseas performing the work even if the assignment is temporary (4-5 days)?
A: The first question is easy: the D&A testing requirements only apply to work accomplished in the United States (at any tier in the maintenance contract) for air carriers and tour operators.
The second question is not as straightforward—and it can depend upon how the company has written or applies its anti-drug and alcohol policy/procedures.
A close look at the language in §§ 120.123(a)(1) and 120.227(a)(1), reveals the word “solely” is used. It is meant to cover the assignment of an employee to an overseas location. For example, some U.S. carriers will assign folks to be based in Heathrow to perform “line maintenance” on aircraft transferring through that location. When the assignment takes place, the individual will be removed from the testing pool since they are working “solely” outside the United States for an extended period of time.
On the other hand, when a safety-sensitive employee goes on vacation (even for several weeks or a month) they aren’t removed from the pool; rather, if their “number comes up” for testing, they are sent immediately upon their return from vacation.
To help you see how the agency looks at these two issues (well, kind of), here are two “FAQs” from the FAA website:
(1) Is an individual who performs a safety-sensitive function solely in a foreign country subject to testing under the employer’s Federal Aviation Administration (FAA) drug and alcohol testing program?
(2) Is an employer required to remove an employee from the random pool if the employee is on extended leave (e.g., 3-6 months) for reasons such as personal/family illness or military duty?
Finally, IF your policy says anything about how you are supposed to handle people being “assigned overseas” even temporarily, you need to follow that procedure. If your policy is silent, I would not pull a person from the pool if that person was on a temporary assignment outside the United States on a “work away” situation since s/he will be returning shortly to perform work in the United States and s/he was not tested while performing work “solely” outside the country.
Make ARSA’s Voice Your Own: Advertise
ARSA has a menu of advertising opportunities for arsa.org, the hotline and the ARSA Dispatch.
Take advantage of these great opportunities today to showcase your company, a new product or event. For more information go to arsa.org/advertise.
Stand Up for ARSA by Sponsoring in 2018
In order to provide world-class resources for its members, the association depends on the commitment of the aviation community. By sponsoring events and activities, supporters can help ARSA’s work on behalf of repair stations to endure.
Need a place to start? For information about opportunities, including sponsorship of the 2018 Annual Repair Symposium (click here for info), contact Vice President of Communications Brett Levanto (email@example.com).
ARSA strives to provide resources to educate the general public about the work of the association’s member organizations; should you need to provide a quick reference or introductory overview to the global MRO industry, please utilize AVMRO.ARSA.org.
AVMRO Industry Roundup
ARSA monitors media coverage on aviation maintenance to spread the word about the valuable role repair stations play globally by providing jobs and economic opportunities and in civic engagement. These are some of this month’s top stories highlighting the industry’s contributions.
You can explore these stories through ARSA’s Dispatch news portal.
MRO East Asia – Hanoi, Vietnam – March 7-8
ARSA Legislative Day & Annual Repair Symposium – Arlington, Virginia – March 15-17
ATEC Annual Conference – Arlington, Virginia – March 15-17
AEA International Convention & Trade Show – Las Vegas – March 26-29
MRO Americas – Orlando, Florida – April 10-12
MARPA EMEA PMA Aircraft Parts Conference – Dublin, Ireland – May 2-3
AP&M Europe – London – May 29-31
MRO BEER – Ljubljana, Slovenia – June 6-7
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