2018 – Edition 3 – April 6
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.
State of the Association
By Basil Barimo, Chief Operating Officer, AerSale and ARSA’s 2018 President
Editor’s Note: ARSA President Basil Barimo delivered his “state of the association” address during ARSA’s annual membership meeting and breakfast, held on March 16 during the 2018 Symposium Week. The following is the text of Mr. Barimo’s prepared remarks, annotated with links to resources and information about activities as described in the text:
Good morning, I’m Basil Barimo, the chief operating officer of Aersale and ARSA’s 2018 president. I’ve been representing the interests of corporate, business and airline maintenance providers on ARSA’s board of directors since 2007. This is my first term as president and believe me when I tell you the polls say I’m doing a great job – an amazing, beautiful job!
Now, my role this morning is to update you on the “state of the association.” In part, this means reviewing some of the key work done by ARSA since my predecessor Warner Calvo gave this address at last year’s meeting. This is a good thing: I’m always awed by how much the association’s small team and its band of committed members gets done. What’s even more important, though, is to make clear how each of you needs to get – and stay – involved in that work.
Over the course of my career, I’ve seen every side of this industry: I’ve worked with manufacturers and maintenance providers, with an airline and even at another trade association. Everywhere, I continually ran into the simple truth that countless men and women go to work in aviation every day and that without their good service our world would be quite different. Unfortunately, the maintenance industry’s great work is routinely overlooked by the general public. The fact that the world can’t fly without us, as ARSA says, is a too-well-kept secret.
Considering how many people it takes to keep our industry moving forward, I would be remiss if I didn’t take a moment to recognize the volunteers with whom I work most closely: the association’s board of directors. I’m going to ask each of them to stand as I call their names and highlight which portion of the industry they represent. I ask that you be patient with them because I assure you this is their least favorite activity of the year.
ARSA’s Vice President Dave Latimer from HAECO Americas. Like me, Dave represents international companies that work on large aircraft. He’s been a director since 2004 and is one of ARSA’s great champions.
Dave is joined on my “cabinet” of executive officers by Ian Cheyne from BBA’s Dallas Airmotive. Ian is one of the board’s longest-serving members; he has been representing engine maintenance providers since 2002.
Alongside the current executive committee, I should recognize Warner Calvo of Coopesa and thank him for his service last year as ARSA’s 2017 president. For those of you who weren’t here for the member meeting, Warner – who represents international members – donned traditional Costa Rican attire during his address. I assure you I have no costume changes planned.
Now for the three Garys:
Gary Jordan of Jordan Propeller Service represents the general aviation segment of ARSA’s membership. He is joined in this effort by Gary Hudnall from Jet Center Medford in Medford, Oregon, who served his term as president two years ago. Gary Fortner of Fortner Engineering represents component maintenance, and we welcome him back to the symposium after he was forced to miss it last year for the first time in seventeen years.
The third Gary is joined in representing component maintenance, which makes up the vast majority of ARSA’s membership, by Jim Perdue of Sonico.
Chris Erickson from Erickson Aviation represents the rotorcraft industry.
And finally, join me in welcoming Terrell Siegfried to the board. Terrell is the new representative from NORDAM, having taken my place when I transitioned out of the company last year.
Take a look at this group of volunteer leaders. They provide a sounding board for the ARSA team, offering direction and helping to make sense of what matters to the industry. Join me in a round of applause to thank them for their work…
Alright, guys. You can sit down.
Since we’ve come together for ARSA’s main event – the ever-growing week of symposium-related activities – it’s fitting for me to first address how important ARSA events have become.
Of course, I can’t discuss an ARSA event without thanking all of our sponsors. This year, we continued our trend of record breaking support for the symposium. I’m so thankful for the commitment of these organizations, because it not only makes this meeting possible but gives us the resources to do even more beyond it.
You no doubt have noticed the addition of the “Executive to Executive” Briefings Day to this year’s symposium week: On Tuesday, I joined a small but important group of participants at meetings with the Departments of Commerce, State and Transportation. We made a stop at the FAA and visited Acting Deputy Administrator Carl Burleson. The day’s briefings provided us a chance to expand the industry’s reach and awareness into government offices that often didn’t even know about the impact their work can have on ours.
The addition of the “E2E” day was a careful decision: After the successful Strategic Leadership Conference last fall incorporated a similar – but more modest – schedule of meetings, ARSA’s team decided to incorporate the executive meeting into symposium with the addition of the new day. This is important, because it funnels even more time and resources into this week, turning it into the sole opportunity for us as members to “show up” on behalf of the association. It has made, and will continue to make, the symposium a more indelible part of the aviation industry’s calendar while freeing up staff time to focus on many other initiatives for the rest of the year.
We can help to make this transition work by committing to the expansion of symposium in the coming years. Being here now means that you’re already on the leading edge of the membership – active and committed to the health of ARSA. When you come back next year, bring colleagues, call suppliers, invite friends – be proactive in exposing this venue to new audiences. In addition to sponsorship commitments, speaker presentations and venue support, attendance is the single most important component of event management; it is quite literally the reason we are all here and a shared responsibility to grow it moving forward.
On the thought of growth, I’d like to highlight an important transition going on behind the scenes at ARSA’s offices: the move to a new association management software. This might seem like it’s a little too “in the weeds” for the general membership, but an AMS – or membership database – is the lifeblood of an association. Having accurate information about members and providing easy tools for managing relationships, not to mention providing services like training, publications, event registration and more, is the foundation of everything we do.
So, in the coming months, I ask you to be on the lookout for information about the new database. You will be asked to access your account on the new ARSA member portal. Through the portal, every member representative will be able to engage directly with the association and manage their relationship with it. This is a very important step, one that has required considerable time and resources and will be an ongoing project throughout the year. Help us to see it through by paying careful attention and taking action when required.
The work of ARSA is to support the maintenance industry. It is the “voice” for repair stations with regulators around the world and here in the United States with elected officials on Capitol Hill.
On the regulatory front, Sarah MacLeod and Marshall Filler remain steadfast leaders on behalf of the industry. In the past year, Sarah and Marshall have traveled the world in support of government and industry events, supporting the International Safety Conference, EASA’s Engineering & Maintenance Technical Committee, the quadrilateral Certification and Maintenance Management Teams (CMT/MMT), the Singapore Aerospace Quality Group, Helicopter Association International’s Rotor Safety Challenge and the FAA’s InfoShare event last October in San Diego.
Representing ARSA and its members in these venues is an incredibly important part of the association’s work. Showing up for and leading discussions with regulators, training sessions, panel presentations and industry networking raises the visibility of the repair station community and moves issues forward that matter to maintenance professionals. To help this work, I challenge each of you to think of places where the ARSA flag needs to be flown and then help provide the resources to make it happen. This year, we’re aggressively pursuing industry investment in travel, accommodations and other logistical needs to support these events. If you’re going to be at a conference or exposition, think about taking ARSA along with you – at the very least, ask a team member about bringing ARSA-related literature with you to share.
Focusing closer to home, it was a productive year for ARSA’s regulatory compliance and advocacy efforts.
The association worked intently through its active role on the Aviation Rulemaking Advisory Committee to take advantage of the regulatory reform tone set by the White House. In this effort, Sarah collaborated closely with other industry groups, including Airlines for America, to align the operators’ apparent needs with those of the maintenance providers.
Sarah also helped the ARAC to be assigned and then accept a task to review and reconcile the regulations and guidance respecting part 145 repair stations. This is a very important effort, and one for which the FAA is forming an industry working group. ARSA will remain in the lead on our behalf, but it’s important for us to get involved in ensuring FAA guidance is consistent with the repair station rule.
Beyond the work done through ARAC, the association’s regulatory advocacy included clarifying “safety sensitive” functions for the sake of drug and alcohol testing requirements, continuing the industry-wide fight to resolve the outstanding parts documentation issues such as commercial parts and single release workscopes on aircraft, correctly defining the term “accountable” in the regulatory sense for the sake of limiting criminal liability and pursuing confirmation of a repair station’s right to replace 100 percent of an article while performing maintenance. On these issues and countless more, ARSA remains the first stop for aviation safety regulatory compliance issues.
A key development of the past year, though, is the expansion of ARSA’s reach beyond the aviation regulators. The association developed background resources and an advisory document to clarify issues relating to airworthiness and the duty-free importation of civil aircraft parts – an issue that was raised at last year’s symposium. It also has taken the lead for a small group of members trying to convince the White House and Department of Defense that the government should trust its own approvals when it comes to aviation safety.
While we must always be good shepherds of the association’s limited resources, finding these worthy causes outside the aviation community is another way ARSA can improve business for all its members. Just as we did during Tuesday’s “E2E” day, making the industry known outside of the FAA is a valuable use of time.
On the legislative front, ARSA is coming through one of its most successful years ever. When the FAA reauthorization process began last year, it was the first time in recent memory that no provisions hostile to contract maintenance were inserted into either the House or Senate versions of the bill. Make no mistake – that was because of ARSA and the association’s aggressive advocacy. Christian Klein worked tirelessly – and wore out at least one pair of shoes – making sure every congressional office involved in writing the bill understood there were repair stations and maintenance workers in their home states. That hard work paid off and, when it because clear that we weren’t targets in the FAA bill, it allowed Christian to play offense, getting a series of amendments submitted for consideration that would help on issues important to maintenance providers. Christian gathered support to get aviation maintenance included on a new Certification & Oversight Advisory Committee, asking the FAA to explore ways to enhance the value of repairman certificates, reinstating the right to voluntarily surrender a 145 certificate and directing the Government Accountability Office to study the maintenance workforce.
On this last topic – the technical workforce – ARSA has built itself into an industry leader. Hopefully, you’ve heard about the bill introduced by Senators Jim Inhofe, Richard Blumenthal, Maria Cantwell and Jerry Moran that would create a federal grant program to support collaborative efforts by industry, labor, academia and the government to foster aviation maintenance skills. I want to let you in on an open secret: ARSA wrote the bill. During the reauthorization process, Senator Inhofe’s office – the Oklahoman has always been a champion of aviation – was eager to “do more” in support of the maintenance workforce. Given the opportunity, the association’s legislative team offered the grant program as an option. In the process of developing the language, Christian got endorsements from 16 other industry groups, including multiple labor unions, for a bill that now has co-sponsors from both parties representing states from sea to shining sea.
There’s a long way to go before the grant program becomes law and that money becomes available. We need to get involved to help make that happen. There are 535 members of the House and Senate plus countless committee and leadership offices.
If our industry is going to prevail on the issues that affect the ability to work and succeed, your involvement is critical. We need your help to expand our scope and reach. When ARSA asks you to get engaged, please respond. Maintain contact with your congressional offices and invite elected officials to visit your facilities (ARSA’s staff is standing by to help). And, although for legal reasons only an election lawyer can explain, I can’t tell you directly to support ARSA PAC, I urge you learn more about it and why it’s so important to our legislative program.
As you think about all our legislative activities, I want you to remember one thing: The entire maintenance community has been ringing alarms about the workforce crisis for years, and ARSA is the first professional group to step up and do something. Our workforce bill is just a first step, but it shows what we can get done working together.
While these advocacy efforts gather a lot of attention and go a long way toward making our professional lives better, there is so much more that the association does on our behalf. Last year, my fellow board members and I accepted a new strategic work plan for the association focused on four key areas: membership, events, training and publications.
ARSA accomplishes an amazing amount on a shoe-string budget. We need to grow the association so we can continue our success and build on it. I know I’m preaching to choir about the benefits of membership, but we need to work together to grow this association. We need your help. Please do everything you can to support our efforts to recruit new members. Help us identify new companies to bring into the fold, provide testimonials about what ARSA means to you, and make sure people in your company understand the value.
It’s also important that I remind you about the association’s training program and model manuals and supplements. The resources made available through these programs provide the us with great tools in addition to supporting the association by generating both awareness and revenue. Sarah and Marshall are working to update the model RSQM and we’ve got plans in the works to collaborate with ARSA’s management firm on consulting services: They’ll hand you a template that has found favor with an awful lot of inspectors and then walk you through the process of making it your own. While this idea is still on the drawing board, you can help make it a reality by reviewing your current manual and considering if it might be time for an upgrade.
There are also a number of publications – advisories, forms, instruction documents – that are available for free to ARSA members. Like the E100 form for new articles developed as a tool for compliance with the U.S.-EU Maintenance Annex Guidance parts documentation requirements, these are resources born out of industry needs and produced for specific purposes. They are only available to YOU as ARSA members, so go get one if you haven’t already…but if a colleague at a non-member asks to see it tell them they can find it at arsa.org/join.
Our library of on-demand training programs continues to grow. There are sessions currently available on parts 21, 43, 65, 120, 145 and on and on. The training team – led by Brett Levanto – is going to continue churning out content and is beginning production of an updated series on Human Factors that will coincide with an update to ARSA’s Model Human Factors training program.
ARSA’s training strategy for the past several years has been “if you build it, they will come.” We’ve been pushing out content in order to get to a critical mass of session offerings, knowing that if all the basic regulatory issues are covered, anyone in the industry should find something they need once landing on the online training page.
As we near that critical mass, the time has come to get the word out – truly out – about these training resources. We’re working with the FAA to improve guidance for acceptability of regulatory, technical and professional training, in order to open new doors not just to ARSA but also to a number of industry organizations with useful knowledge to share. We’re going to expand the use of “subscriptions” by which companies can bundle-purchase training for use by their people. We’re also going to seek out opportunities to partner in the development of training: IF there’s something you need, ARSA could develop the class for you, register your people at normal online training prices (rather than higher costs for tailored session) and then make the recorded version available for general registration.
This is where you can help: Go to ARSA.org/training and look around. I’m sure you can find sessions that will help you and your people do their jobs, and I want you to consider how the content can be folded into your repair station’s training program and also what else might be useful. Talk to talk to Brett Levanto about it. Help make this growing store of information into your personal training resource.
Through all these updates, I’ve tried to highlight ways that you can get involved. Here’s my final, and most important, request: Communicate with ARSA. The association is at its best when it has a healthy back and forth with its members. Tell us what’s going on in your business. Share your needs. Alert others about issues with the government. Make regular use of the “Ask ARSA First” system by using the website’s contact functions.
You can also communicate by responding to the member survey, which has already collected great data since it opened last month but will remain open for just a little while longer in hope of collecting as much insight as possible. The invites were sent to the primary contact at every member organization – if you need help being sure you received and responded to it, ask Brett. NOTE: The member survey is closed, but ARSA will always accept input and feedback through its contact system. Stay tuned for the publication of survey results.
In addition to the annual member survey, you’ll likely have noticed the circulation of monthly “quick questions,” which ask one or two questions about specific topics of interest. They run through the weekly Dispatch and monthly hotline newsletters (if you’re not getting one or both, let Brett know immediately) and take less than a minute to answer. Help us collect these specific data points for the sake of ARSA’s work on your behalf.
While all of those means of communication will be available to you once you leave this room, I challenge you to use this meeting to get things started. In a moment, I’m going to open the floor for questions. When I do, raise your hand, then ask a question, share an issue, provide feedback, anything. The board and professional team are here to listen and respond. Get involved in making ARSA work for you.
Before I do that, I want to thank you all for making this year’s symposium so successful.
I expect to see you – and the additional colleagues and contacts you convince to come along – at next year’s meeting: Mark your calendars for March 19, 20, 21 and 22 of 2019.
Also, in addition to the names I’ve already said, I want to thank Caroline Kneip, Jennifer Kitching and Kimberly Dimmick, who are always working behind the scenes to support ARSA administratively. Looking around this room, I can say quite easily that none of us would be here, for one reason or another, without Caroline, Jennifer and Kimberly’s good work.
I hereby adjourn the 2018 annual membership meeting.
All That Happened
The 2018 Executive to Executive Briefings, Legislative Day & Annual Repair Symposium kept participants busy from March 13-16.
If you were a participant…
Access the 2018 Symposium Digital Companion, a web page set up specifically for participants that includes the agenda as well as event logistical information. Presentation materials, references and other resources have also been included. The page is laid out to load cleanly on a smartphone, so you can carry it around and refer to it from your maintenance shop or living room.
To access the digital companion, visit http://arsa.org/symposium-2018. The page is password protected to ensure use is limited to registered attendees; to get the password, refer to the attendee prep emails or the event materials provided at symposium.
If you are an interested observer…
Review the content below to see what happened. Click on a linked item for more information.
March 20, 2018 @ 11:13 a.m.
Symposium Week Photos:
A curated selection of the images taken by the ARSA team has been uploaded to the association’s Flickr account. Take a look to put faces and images to the descriptions of what happened during Symposium Week:
March 16, 2018 @ 12:00 p.m.
An awful lot happened this week:
ARSA’s first-ever set of “Executive to Executive” Briefings helped expand the maintenance community’s reach in the nation’s capital.
Once again, Legislative Day attendees wore out their shoes on Capitol Hill — one participant tallied more than 19,000 steps — connecting elected officials to the business of aviation safety.
The panels and professional sessions of the Annual Repair Symposium, member meeting and breakouts continue to be the repair station industry’s most valuable two days of substantive content.
The attentive engagement and support of this year’s participants made the event a great success. If you weren’t able to be here and work alongside them, make sure you checkout everything that was done and said.
Whether you were here this week or not, it’s already time to look ahead to 2019. Mark your calendar for year’s symposium activities from March 19-22, 2019.
March 15, 2018 @ 1:30 p.m.
ARSA Honors Jennifer Weinbrecht with Its Weston Award (See hotline piece below)
March 14, 2018 @ 2:00 p.m.
ARSA Recognizes Inhofe for Legislative Leadership (See hotline piece below)
March 14, 2018 @ 1:05 p.m.
New Aviation Maintenance Industry Report Shows Hopeful Economic Projections, Hard Workforce Truths (See hotline piece below)
See from the perspective of @ARSAWorks and its legion of twitter followers during #ARSASymposium18…
New Aviation Maintenance Industry Report Shows Hopeful Economic Projections, Hard Workforce Truths
According a new report, the global aviation maintenance industry will continue to expand its worldwide economic footprint over the next decade. The projections, released on March 14 during an industry event hosted by ARSA, show that expanding global markets and technical enhancements to civil aircraft fleets will drive growth across the maintenance and parts manufacturing sectors.
According to the 2018 Global Fleet & MRO Market Assessment, prepared for ARSA by consulting firm Oliver Wyman, the global air transport maintenance industry employs more than 380,000 people across nearly 5,000 firms that will produce $77.4 billion in market activity in 2018. In the United States, more than 4,000 civil aviation maintenance businesses employ nearly 185,000 people and generate $44 billion in economic activity.
The report was released at a Capitol Hill briefing conducted as a part of ARSA’s annual Legislative Day, an event that has become a highlight of the transportation policy community’s spring calendar. Steve Douglas, former director of the FAA’s aircraft maintenance division and vice president for Oliver Wyman’s CAVOK division, presented this year’s report.
By 2028, the global maintenance market is forecast to surpass $114 billion dollars in annual activity, based on the firm’s projections. As seen in previous reports, maintenance-related revenues are projected to fare well even when a series of alternative scenarios are considered against the baseline forecast. Should air carriers be forced to weather economic turbulence in the next decade, their likely delayed introduction of new aircraft and further dependence on legacy fleets would stabilize spending on maintenance, repair and overhaul services.
However, a looming problem – one that has been recognized by ARSA and the industry for years – is made clear by the report: the desperate need to find and retain a new generation of maintenance technicians. According to Oliver Wyman’s projections, the demand for aircraft mechanics will outstrip the available supply by 2022. By the end of the reports decade-long projection, there will be 10 percent fewer mechanics in the workforce than needed by the industry.
“We can now point to 2022 as the year of reckoning,” said Brett Levanto, ARSA vice president of communications. “Seeing clear analysis showing that a shortfall of aviation maintenance talent in the very near future needs to move us to action now. Many in the industry, including ARSA, have been piecing together a plan for this issue for years. Our first big hurdle was to clearly and directly tell the story, now that we’ve done that it’s time to take action.”
Levanto noted the association’s stepped-up efforts on workforce development issues, which were particularly evident in early March when Sens. Jim Inhofe (R-Okla.), Richard Blumenthal (D-Conn.), Jerry Moran (R-Kansas) and Maria Cantwell (D-Wash.) introduced an ARSA-supported bill to establish a new pilot program to train maintenance professionals, help veterans transition to civilian careers and recruit new technicians. “There are many who have been talking about the [aviation maintenance] workforce crisis for a long time. It’s nice to be part of a group that’s doing something about it – and to have [the Oliver Wyman data] to underscore our urgency,” Levanto said.
The report’s executive summary, as well as a fact sheet illustrating U.S. state-by-state employment figures, is available below. All of ARSA’s available data resources can be found at: arsa.org/news-media/economic-data.
2018 Global Fleet & MRO Assessment
by CAVOK, a division of Oliver Wyman
ARSA Honors Jennifer Weinbrecht with Its Weston Award
Weinbrecht began working for the Mentor, Ohio-based repair station in 1985 – the company’s third employee – and has supported its growth into an international component maintenance provider employing more than 400 people. Weinbrecht utilized her personal attention to detail and deep understanding of both the governments’ rules and CRT’s business needs in ensuring the company operated efficiently while meeting the requirements of multiple international aviation authorities.
“We say that our company’s philosophy is ‘trust and fairness,’” said Rich Mears, CRT president, reflecting on Weinbrecht’s selection as Weston Award winner. “It’s hard to imagine someone who embodies those values better than Jennifer. She always focused on doing things the right way. She took care of her people and thought about growing future talent. There are many here in Mentor who owe their careers to Jennifer’s good work – and plenty more all over the world who owe their safety in the air to her.”
ARSA’s team often directly experienced Weinbrecht’s professional focus. She unfailingly participated in association events, was a fixture at training sessions and professional development activities and a guaranteed resource whenever the maintenance industry needed support.
“Jennifer represents the essential philosophy behind the Leo Weston award,” said Sarah MacLeod, ARSA executive director. “She never accepted an answer that wasn’t the right one. She never lost focus on her commitment to the community, whether across the aviation industry or within her small corner of Ohio. She never gave anything less than her best. Frankly, the only good thing about her retirement is we can finally give her [the Weston] award – otherwise this is a dark day for aviation because she will be missed.”
The Weston Award is celebrated regularly as part of ARSA’s Annual Repair Symposium. It was first bestowed on Leo Weston himself and honors individuals who embody his commitment to aviation safety. As an FAA official, Weston was instrumental in ARSA’s founding by advocating for the creation of an organization to represent the interests of maintenance providers. He remained an inspiration to the association and its members across his long career dedicated to the public good.
Weinbrecht is the 11th person recognized by ARSA as part of Weston’s legacy.
ARSA Recognizes Inhofe for Legislative Leadership
ARSA has recognized Sen. Jim Inhofe (R-Okla.) as its 2018 Legislative Leadership Award recipient. The presentation was made during a March 14 luncheon held on Capitol Hill in conjunction with the association’s annual Legislative Day.
Inhofe, a member of the Senate Committee on Commerce, Science and Transportation and an avid private pilot, has long worked in support of the aviation industry at large. He is also a longtime champion of the aircraft maintenance community and on March 7 introduced legislation aiming to address the persistent challenge repair stations face finding and retaining technical talent.
“Sen. Inhofe’s commitment to maintenance reflects both his personal passion for aviation and our industry’s footprint in Oklahoma, where we collectively employ more than 12,000 people and contribute more than $1.3 billion to the state’s economy,” said Terrell Siegfried, assistant general counsel for Oklahoma-based NORDAM, Inc., in his introductory remarks during the event. “In fact, according to ARSA, Oklahoma has the highest per capita percentage of workers in the aviation maintenance industry of any state.”
The workforce bill, co-sponsored by Sens. Richard Blumenthal (D-Conn.), Jerry Moran (R-Kansas) and Maria Cantwell (D-Wash.) would establish a new pilot program to train maintenance professionals, help veterans transition to civilian careers and recruit new technicians. Grants of up to $500,000 per year would be available to business or unions, schools and governmental entities that partner to pursue creative solutions to one of the aviation community’s most pressing strategic challenges. The concept was developed by the legislators in coordination with ARSA and has the support of 17 aviation industry groups as well as the National League of Cities.
“Sen. Inhofe is a rare breed of elected official who really understands aviation,” said Christian A. Klein, ARSA executive vice president. “The maintenance industry – in many ways because of its excellent safety and reliability record – is too-often hidden from the public view. We need leaders who recognize the importance of maintenance, can communicate its value and will take action when the 200,000 men and women working in the sector need help. It’s great to have a champion like Sen. Inhofe and to be able to recognize his work through ARSA’s Legislative Leadership award.
ARSA Offers EASA Objective Criteria for Assessing Part Criticality
On March 30, ARSA submitted comments to the EASA notice of proposed amendment (NPA 2017-19) regarding “installation of parts and appliances that are released without an EASA Form 1 or equivalent.” The association commended the agency’s effort but called out the NPA’s unnecessary complication of the rules and suggested a simpler, internationally-harmonized approach for assessing part criticality.
“This [NPA] aims to introduce more proportionate and efficient requirements in the airworthiness field, in particular to introduce commensurate manufacturing requirements for new spare parts and appliances,” EASA stated in its executive summary. “The requirement mandates that parts and appliances to be installed during maintenance need to be accompanied by [an EASA] Form 1 to attest manufacturing in accordance with Annex I (Part 21) to Regulation (EU) No 748/2012, which is considered, in certain cases, disproportionate.”
The NPA proposed giving the design approval holder responsibility to assign a criticality level for each aircraft part based on the safety consequences posed by the part’s potential failure. Should the DAH not make this assignment, the most-stringent level would become the “default.”
In its comments, ARSA noted support for the NPA’s intent and offered a simpler alternative to EASA’s proposal. The association noted that the agency’s proposed definitions for part criticality were different from those included in the approved design and that the DAH would be given full discretion for assessment. ARSA’s comments instead urged the adoption of three categories of parts – based on objective, design-based criteria – for use in determining required documentation for installation during maintenance or modification activities.
In the cover letter accompanying the comments, which were entered into EASA’s comment response tool, Managing Director and General Counsel Marshall S. Filler summarized the submission: “ARSA believes it has proposed a workable solution that (1) requires a Form 1 for all critical parts as defined in the design rules, (2) for non-critical parts, makes issuance of a Form 1 discretionary with a Part-21 subpart G or subpart F manufacturer, (3) for non-critical parts allows another document to be used in lieu of a Form 1 if it states that the article was produced under a Part-21 inspection system or quality system as applicable, and (4) allows maintenance providers to install parts that are not described above if they can establish a link to an approved design.”
To read the complete comments, including the regulatory language specifically suggested by ARSA, click here.
To see all of ARSA’s work related to parts documentation in the context of the U.S.-EU Maintenance Annex Guidance, visit arsa.org/mag.
The Future is Here for AFS & AIR
On March 5, the Federal Register published the FAA’s final rule on the functional reorganizations of both the Aircraft Certification Service (AIR) and Flight Standards Service (AFS). The rule is the result of ongoing efforts by each organization involving both government personnel as well as ARSA and other industry stakeholders.
Attendees at the 2018 Annual Repair Symposium will get updates from the agency on each initiative:
As part of a longer-term strategy, AIR underwent a “holistic” process to review, update and improve its certification strategy, management systems and organization to realign into a functional structure.
As part of a larger effort to overhaul culture and improve efficiency/responsiveness, AFS reorganized into function-based structure (rather than geography):
- Four directors.
- Eight deputy directors.
- Twenty-eight division managers.
- Regional structure replaced by four functional organizations: Air Carrier, General Aviation, Standards, and Foundational Business.
To review the final rule, follow the link below to the Federal Register:
Final Rule: Aviation Safety Organization Changes
Docket #: FAA-2018-0119
Effective date: 03/05/2018
The FAA Aircraft Certification Service (AIR) and Flight Standards Service (AFS) have reorganized to align with functional organization design concepts. The AIR reorganization included eliminating product directorates and restructuring and re-designating field offices. The AFS reorganization included eliminating geographic regions, realigning headquarters organizations, and restructuring field offices. Currently, various rules in the Code of Federal Regulations refer to specific AIR and AFS offices that are obsolete after the reorganizations. This rule replaces specific references with generic references not dependent on any particular office structure. This rule does not impose any new obligations and is only intended to eliminate any confusion about with whom regulated entities and other persons should interact when complying with these various rules in the future.
The Government Comes to You – Regulatory Roundtable in Atlanta
The U.S. Small Business Administration (SBA) Office of Advocacy recently announced a new date for its ongoing “regulatory roundtable” series on April 10 in Atlanta, Georgia. During the event, 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 Atlanta (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 in Atlanta, use the following links to register. For those who can’t, get active and submit an input form now:
Tuesday, April 10
GTRI Conference Center, 250 14th Street, NW, Atlanta, GA 30318
To see the day’s schedule and to register, click here.
Final Documents/Your Two Cents
This list includes Federal Register publications, such as final rules, Advisory Circulars and policy statements, as well as proposed rules and policies of interest to ARSA members.
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.
Thank You So Little
By Sarah MacLeod, Executive Director
In a recent legal interpretation, the FAA provided a perfect example of why one must always read the plain language of the regulation or statute (law). It is also a demonstration of why guidance material to both agency employees and the general public is untrustworthy.
The sentences that drew attention are contained in a legal interpretation of the Pilot Records Improvement Act (PRIA). The questions presented regarded the plain words of the statute versus the language contained in an advisory circular.
“Regarding your questions about FAA guidance documents, Advisory Circular (AC) 120-68G and all past versions of that AC are agency guidance documents that provide operators with methods for achieving compliance with the requirements of PRIA and examples. Although our office does not interpret guidance documents, we note that, in instances where guidance is inconsistent with a regulation or statutory provision, the regulation or statute controls.”
So in other words, the “methods for achieving compliance” are flawed, they can be and are “inconsistent with a regulation or statutory provision.” The agency’s offices of primary responsibility may or may not provide a valid or viable method of compliance in the FAA’s internal and external “guidance” documents. The office of chief counsel does not “interpret” those documents; rather “the lawyers” rely solely on the regulations and statutes. Therefore, day-to-day oversight can be (and in this case is) based upon inappropriate, incomplete and incorrect “guidance.” According to the legal interpretation, the myriad information contained on the agency’s website regarding the PRIA contains incorrect, incomplete and inaccurate information.
Well, thank you so very much, that really helps the agency and the public achieve compliance.
ARSA on the Hill
A Big Month
By Christian A. Klein, Executive Vice President
March 2018 will go down as one of the most important months in the history of ARSA’s legislative program. Almost a year of hard work culminated with the introduction on March 7 of legislation originally proposed by ARSA to confront the technician shortage. Days later, ARSA members stormed Capitol Hill for the association’s 2018 Legislative Day to build support for the initiative.
The bill (S. 2506) introduced by Sens. Jim Inhofe (R-Okla.), Richard Blumenthal (D-Conn.), Jerry Moran (R-Kansas) and Maria Cantwell (D-Wash.) would create a new aviation workforce development grant program. The legislation authorizes $5 million per year to be distributed in grants of up to $500,000 to support apprenticeships, scholarships, veteran transitions to civilian jobs, career outreach to students and populations under-represented in the industry and other innovative programs to attract and retain workers.
Importantly, to be eligible a grant application would have to be submitted jointly by an aviation company or union, a school and a local government entity. Rather than simply throwing money at a problem or forcing solutions down industry’s throat, the bill encourages innovation and local collaboration with the goal of finding new and better ways to develop the aviation workforce
“Our aviation industry needs skilled workers and the aviation maintenance industry provides high-paying, high-skilled jobs across the country,” Sen. Inhofe said. “Aviation is an economic multiplier, connecting local communities and cities in support of commercial activity and generating tourism revenue. We can’t afford to let these skilled jobs go unfilled.”
“This bill will make it possible to close the skills gap by incentivizing businesses, labor groups, educational institutions and local governments to develop innovative ways to recruit and educate the next generation of America’s aviation workforce. I applaud the efforts of the Aeronautical Repair Station Association and their member companies like AAR and NORDAM for their continued advocacy for aviation maintenance issues before Congress,” Inhofe said.
With the bill now introduced, ARSA is managing the lobbying effort to enact it into law. Earlier this month, the association coordinated a letter in support of the bill from 17 leading aviation industry organizations representing manufacturers, operators, maintenance providers and labor groups; the National League of Cities, FedEx and Boeing also support the effort. ARSA is setting up congressional meetings for industry lobbyists aimed at adding cosponsors to the Senate bill and getting a parallel version introduced in the House.
The overarching goal is to add the bill as an amendment to the FAA reauthorization bill expected to move through Congress this summer. Congress recently passed another short-term FAA extension, giving itself until Sept. 30 to put a new long-term aviation funding and policy blueprint in place. Prospects for a long-term FAA bill have improved significantly now that House Transportation & Infrastructure Committee Bill Shuster (R-Penn.) and Senate Commerce Committee John Thune (R-S.D.) have backed away from controversial provisions to privatize air traffic control and reform pilot training requirements. It’s possible that an FAA bill could be on the House floor by May.
Note: For a refresher on the ARSA-supported measures in the House and Senate versions of the FAA bill, see the “box score” in the update below on Congress’ extension of the agency’s authorization.
Here’s How You Can Help
ARSA may be a highly effective advocate for the industry on Capitol Hill, but our resources are also extremely limited. Your participation in our advocacy effort on the workforce bill could mean the difference between it becoming law and lingering in legislative limbo. If you agree that the technical skills gap is a threat to the aviation maintenance industry’s growth, here’s what you can do to support our efforts:
- Pick up the phone, call the Capitol Switchboard (202-224-3121) and follow the prompts to be connected your senators’ offices.
- When you’re connected, identify yourself as a constituent and ask to be connected to the legislative assistant (LA) who handles aviation issues.
- Introduce yourself to the legislative assistant with your name, title, company and city where your facility is located.
- Explain that you work for an aviation maintenance company and that you’re calling about S. 2506, the bipartisan aviation maintenance workforce bill sponsored by Sens. Inhofe, Blumenthal, Moran and Cantwell.
- Explain how your company is being affected by the technician shortage in the aviation industry and that S. 2506 would help address the problem.
- Say that you’d like the senator to cosponsor S. 2506.
- Also ask the LA for his or her email address so you can follow-up.
- Then send them this note and cc email@example.com:
Thanks again for taking the time to discuss S. 2506 with me today. The legislation would address a critical issue facing the U.S. economy: the aviation maintenance industry skills gap. Specifically, it would create a new grant program to incentivize collaboration between business, labor, schools, and government to come up with innovative ways to build our nation’s aviation technical workforce. I hope that Senator SENATOR’SNAME will cosponsor this important bill.
Thanks in advance to everyone in the industry who will work with ARSA to help move this legislation forward. If you have questions or want to get more involved in this effort, please don’t hesitate to call me at 703.739.9543 or email firstname.lastname@example.org.
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.
Congress Passes What Will Hopefully Be Final FAA Extension
Buried deep in the 2,149 page, $1.3 trillion appropriations bill signed by President Trump on March 23 was a provision extending the FAA’s operating authority through Sept. 30. The extension gives Congress six months to reauthorize the agency by enacting a new, multiyear FAA budget and policy bill.
The extension comes amid increased optimism that an FAA reauthorization process that has dragged on for years may finally be approaching conclusion. Both the House Transportation & Infrastructure and Senate Commerce Committees (which have jurisdiction over the process) passed bills last spring. However, the effort has been stalled over disagreements about privatizing air traffic control (in the House) and providing more flexibility for pilot training (in the Senate). With those issues resolved, there’s growing confidence that both chambers will move forward in the near future. While only minor modifications will be required to the Senate bill, the House bill will require substantial changes to compensate for the removal of ATC privatization language. Even so, there’s speculation that a bill could be on the House floor as early as late April.
The maintenance industry has a significant stake in the outcome of the FAA bill debate. In addition to providing financial resources for the agency and making changes to help improve the quality of FAA’s oversight, the legislation contains various amendments sought by ARSA, including ones to restore voluntary surrender for repair station certifications and add aviation maintenance as a stakeholder to the FAA’s new Certification & Oversight Advisory Committee. ARSA is also working to include several provisions to address the technician shortage in the industry, including language to enhance the value of repairman certificates and another to create a new aviation maintenance workforce development grant program.
It’s going to be a busy spring for ARSA and its members on Capitol Hill. To learn more about support ARSA’s lobbying on the aviation maintenance industry’s behalf, contact ARSA Executive Vice President Christian A. Klein at email@example.com.
FAA Bill Maintenance Amendments Box Score
Refresh your memory on the status of the measures supported by the association through the reauthorization process.
|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.), Richard Blumenthal (D-Conn.), Jerry Moran (R-Kan.) & Maria Cantwell (D-Wash.) have introduced independent bill to be considered for inclusion in FAA legislation.|
ARSA-Supported Bill Takes Aim at Aviation Maintenance Skills Gap
Legislation introduced on March 7 by a bipartisan group of U.S. senators aims to address a major threat to the long-term health of the U.S. aviation maintenance sector: the persistent technician shortage.
The bill authored by Senators James Inhofe (R-Okla.), Richard Blumenthal (D-Conn.), Jerry Moran (R-Kansas) and Maria Cantwell (D-Wash.) would establish a new pilot program to train maintenance professionals, help veterans transition to civilian careers and recruit new technicians. Grants of up to $500,000 per year would be available to business or unions, schools and governmental entities that partner to pursue creative solutions to one of the aviation community’s most pressing strategic challenges.
“We’re extremely grateful that Senators Inhofe, Blumenthal, Cantwell and Moran have taken up this cause,” Christian A. Klein, ARSA executive vice president, said.
“If there’s one issue keeping ARSA’s members awake at night, it’s where to find the next generation of technical talent. This bill is an important step in the right direction. It will incentivize local cooperation to develop new aerospace professionals and help veterans and others transition to careers in this high-tech, growing industry,” Klein said.
The aviation maintenance industry employs more than 275,000 American workers, contributes $44 billion to the U.S. economy and helps ensure the safety of civil aircraft operating world-wide. The industry’s global footprint is expected to grow from around $77 billion to more than $114 billion over the next decade.
However, a shortage of technical workers could make it difficult for U.S. firms to capitalize on those opportunities. Oliver Wyman’s CAVOK Division, a leading aviation consulting firm, projects that demand for technicians will outstrip supply beginning in 2022. Data from ARSA suggests that the impact is already being felt: More than 80 percent of respondents to ARSA’s 2018 member survey report difficulty finding qualified technicians and more than two thirds of responding companies have unfilled positions. As a result, companies say it is taking longer to complete work for customers, that their companies are not adding new technical capabilities and in some cases are turning down new business.
“Our aviation industry needs skilled workers and the aviation maintenance industry provides high-paying, high-skilled jobs across the country,” Sen. Inhofe said. “Aviation is an economic multiplier, connecting local communities and cities in support of commercial activity and generating tourism revenue. We can’t afford to let these skilled jobs go unfilled. This bill will make it possible to close the skills gap by incentivizing businesses, labor groups, educational institutions and local governments to develop innovative ways to recruit and educate the next generation of America’s aviation workforce. I applaud the efforts of [ARSA] and their member companies like AAR and NORDAM for their continued advocacy for aviation maintenance issues before Congress.”
Given the scale of the threat to the industry, 17 leading aviation industry organizations, representing all segments of the aviation industry joined a letter coordinated by ARSA in support of the bill and delivered to the sponsoring senators on March 5.
“The U.S. aviation industry is a diamond in the crown of our economy. Working together, manufacturers, operators, maintainers, labor organizations, schools and workers have built an industry that provides unprecedented mobility for people and goods. Your legislation will help ensure our member organizations have the technical professionals they need to grow, compete globally, and, most importantly, continue to ensure the safety of civil aviation aircraft,” the organizations said.
ARSA is now working with its members and allied organizations to build support for the legislation and get it enacted this year, likely as part of the Federal Aviation Administration reauthorization bill.
In addition to ARSA, the following industry organizations signed on to the March 5 support letter:
Aerospace Industries Association
Aerospace Maintenance Council
Aircraft Electronics Association
Aircraft Mechanics Fraternal Association
Aircraft Owners and Pilots Association
Airlines for America
Aviation Suppliers Association
Aviation Technician Education Council
Cargo Airline Association
General Aviation Manufacturers Association
Helicopter Association International
Modification and Replacement Parts Association
National Air Carrier Association
National Air Transportation Association
Professional Aviation Maintenance Association
Regional Airline Association
To review the bill, click here.
To see ARSA’s other updates related to technical workforce development, click here.
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.
Recapping the IG’s “Friendly Visit” to Symposium
By Kevin F. George, Aviation Safety Audits Project Manager, U.S. Department of Transportation
On March 15, DOT Inspector General Calvin Scovel, III delivered a speech on the IG office’s work on aircraft repair stations at ARSA’s Annual Repair Symposium in Arlington, Virginia. Executive Director Sarah MacLeod invited Cal to be the keynote speaker at the event, which is part of the association’s work to improve aviation safety and security and shape public policy through collaboration with the FAA and other world regulators.
Cal began by noting that the U.S. aviation system, which handles more than 30,000 flights a day, has a remarkable safety record and that the aircraft maintenance professionals play an important role in ensuring the nation’s aircraft are maintained appropriately and operate safely. He explained that OIG’s auditors and investigators also work tirelessly to improve the performance and integrity of DOT’s programs and ensure a safe, efficient and effective national transportation system. Cal reminded the group that we do not audit air carriers or repair stations. Our focus is on the FAA, and we visit air carriers and repair stations to assess how, when and where the agency conducts its oversight role.
Cal then took the audience on a stroll down memory lane by recollecting the last 20-plus years of OIG’s work on repair stations:
In a 2003 report, for example, we called for the FAA to adopt a risk-based approach to repair station oversight because inspectors cannot realistically visit all repair stations in the world every year.
In 2008, we identified inconsistencies in how air carriers defined heavy aircraft maintenance repairs; as a result, the FAA—with ARSA’s help—developed a more uniform definition that helped improve its oversight of all repair stations. This is a clear example of the importance of effective FAA and industry cooperation in aviation safety matters.
In 2013, we reported that while the FAA had made progress, its oversight system was not yet truly “risk based” because repair stations were not always inspected based on risk. Inspectors continued to conduct their oversight annually at many foreign repair stations whether there was risk or not.
He also spoke about our 2015 review of the U.S./EU aviation safety agreement; aviation authorities in 18 European countries now perform direct oversight and certification of repair stations on the FAA’s behalf. This reciprocal agreement also permits FAA inspectors to conduct oversight of EU-certificated repair stations in the United States. But most important, it allows the FAA to more effectively use its scarce inspector resources where they are needed the most.
Next Cal focused on an issue that is the “bread and butter” of the aviation industry: ensuring that aircraft are maintained safely. That means keeping a watchful eye out for unapproved parts, which pose serious risks to aircraft when they enter the aviation supply chain. Our 2017 report identified multiple inaccuracies in the FAA’s database of unapproved parts. Furthermore, the FAA does not take action to confirm that airlines and repair stations actually remove unapproved parts from the supply chain. In fact, as AIG Matthew Hampton told the House Subcommittee on Aviation in February, we are currently investigating 65,000 unapproved Boeing parts that were for sale on eBay and found their way back into the supply chain.
Cal concluded by stating that while we don’t have any new audit work planned for repair stations, we have a few ongoing projects that may be of interest to the aircraft maintenance industry—air carrier maintenance, aircraft registry and the aviation drug abatement program.
The Office of the Inspector General conducts audits and investigations on behalf of the American public to improve the performance and integrity of DOT’s programs to ensure a safe, efficient, and effective national transportation system. To learn more and access reports and advisories, visit www.oig.dot.gov.
HeliExpo Training Follow Up – Continue Your Education
From Feb. 25 to March 1, ARSA’s great regulatory minds were at HAI HELI-EXPO 2018 in Las Vegas, Nevada.
Marshall S. Filler and Sarah MacLeod, the association’s foremost experts in regulatory compliance (and managing members of the firm of Obadal, Filler, MacLeod & Klein, P.L.C.) lead both professional education courses and rotor safety challenge sessions at HAI HELI-EXPO.
Though Filler and MacLeod are known for their zealous advocacy on behalf of maintenance organizations, their long experience with compliance issues makes these kinds of training and information sessions substantially valuable to any aviation professional.
Now that the event is over, participants in the OFM&K-provided professional education sessions should access the link provided at the end of the training slides to download course materials. Attendees at the ARSA-provided Rotor Safety Challenge sessions should contact ARSA for information about materials and other sessions.
Much of the material presented by MacLeod and Filler at HELI EXPO is available through ARSA’s online training program. To review the library of available courses and register for immediate access to on-demand sessions, click here. You also may review the session information below for links to related classes.
Professional Education Courses - Provided by OFM&K
Drug & Alcohol Testing Programs: Regulatory Basics to Business Needs
This course reviews the drug and alcohol testing requirements in Titles 14 and 49 of the Code of Federal Regulations (CFRs). It will also provide guidance on setting up these programs, including instruction on how safety sensitive functions are defined, as well as information about avoiding many common testing program mistakes that can subject companies to enforcement action.
Marshall S. Filler
This course provides instruction on the statutory provisions and FAA guidance governing public aircraft operations. It covers the basic requirements for an aircraft to be operated as a public aircraft, what constitutes an eligible governmental function, and the practical implications of using the same aircraft to conduct both civil and public operations. It also discusses the FAA policy regarding operations conducted under contract for a government entity.
Regulatory Comprehension for Maintenance
Marshall S. Filler and Sarah MacLeod
This course covers the FAA’s authority, process for promulgating rules, and organization, then walks through the general requirements in Title 14 of the Code of Federal Regulations to explain how its various components are linked together in a “regulatory chain” that must be comprehended by aviation businesses.
Rotor Safety Challenge Sessions - Provided by ARSA
Building a Positive Relationship with the Government
Feb. 27, 2018 – 8:30 a.m. to 9:30 a.m.
This session provides a road map for building a positive relationship with civil aviation authorities. It begins by describing the rules that should always be considered when engaging with aviation safety regulators, then provides instruction on how to introduce your company and maintain consistent contact — not just when there’s a problem. The session concludes by providing strategies for maintaining a professional relationship with regulators.
Best Practices in Maintenance Recordkeeping
This session explores the regulatory responsibilities of creating and maintaining maintenance records. It will help participants to define:
- Regulatory responsibilities of the operator versus the maintenance provider in creating and maintaining maintenance records
- How obligations can be shifted by contract but not under aviation safety regulations
- Maintenance recordkeeping regulations, the documents essential to making airworthiness determinations.
Couldn’t make it to Las Vegas? The association provides plenty of opportunity for you to learn from its experts. Click here to check out the constantly-expanding library of ARSA online training.
FAA Provides Follow Up on Written Questions from China IPA Training
Update: On March 20, the FAA provided responses and follow up information to all questions submitted in writing during the live session. A PDF document containing these responses has been uploaded into the session materials available through the training platform (this document contains no information regarding who asked each question, in order to protect participant privacy). Participants in the live session may access this document by going to their account page on PotomacLaw.inreachce.com. New registrants will get access to this material along with the session recording.
On Jan. 17, ARSA hosted an online training session led by FAA personnel on the Implementation Procedures for Airworthiness (IPA) established under the Bilateral Aviation Safety Agreement between the United States and China. This session mirrored the presentation delivered to FAA staff in November 2017, focusing on the use of the IPA when the FAA is acting as the certifying authority. It was intended to provide industry with the background and major concepts of the agreement, and highlight specific areas relevant to CAAC validation of U.S. products.
The on-demand version of the session is available for registration and immediate access (registrants for the live session also get access to the recording for 90 days).
Tom Groves is a Supervisory Aerospace Engineer in the FAA’s Aircraft Certification Service Transport Standards Branch. He is currently working on temporary assignment with the International Division, providing technical expertise to support development of high-priority bilateral agreements such as the EASA TIP and the IPAs with both China and Brazil.
Daniel Commins is a Foreign Affairs Specialist in the FAA’s Aircraft Certification Service International Division. As the focal point for AIR’s international engagement with China, he manages the bilateral relationship and manages projects such as IPA development and other bilateral activity.
(1) FAA – CAAC IPA Status and Background
(2) FAA – CAAC IPA Change Management Plan
(4) FAA – CAAC IPA Key Validation Concepts
(5) Validation Process Overview – FAA as the Certifying Authority
Aviation industry professionals and stakeholders with interest in the FAA’s administration of international aviation agreements.
Special Session Price: $30 (ARSA Members and Non-Members)
Registration for this ARSA-provided training session includes:
- Unlimited access to the recording for 90 days.
- A copy of the presentation and all reference material with links to relevant resources and citations.
The association’s training program is provided through Obadal, Filler, MacLeod & Klein, P.L.C., the firm that manages ARSA. To go directly to OFM&K’s online training portal, visit PotomacLaw.inreachce.com. To learn more about the association’s training program and see course availability, visit arsa.org/training.
Regulatory Compliance Training
Test your knowledge of 14 CFR § 65.20 – Applications, certificates, logbooks, reports, and records: Falsification, reproduction, or alteration.
A Word from Our Newsletter Sponsors
From time to time, ARSA provides a mechanism for sponsors of its Dispatch and hotline newsletters to reach readers directly through sponsored “blast” emails. Allowing this advertising option gives companies a chance to directly show their support of the association and provide useful information and resources to readers.
While receiving this message, ARSA subscribers and members should be assured that:
(1) The frequency of special “blast” messages is kept to a minimum. This maintains the special focus provided to advertisers sending the messages and prevents “overload” in readers’ inboxes.
(2) Advertisers are not provided direct access to newsletter subscription lists. Messages are constructed and distributed through ARSA’s partner Multiview, which oversees its periodicals.
(3) ARSA team members review and approve all messages prior to distribution.
For questions about ARSA’s advertising options, including ways to stand up for the association through your company’s support, contact Vice President of Communications Brett Levanto (firstname.lastname@example.org).
A Reminder: Don’t Let Technology Keep You From ARSA
Thanks to spam filters, firewalls and quarantines, it can sometimes be difficult for organizations like ARSA to get messages into your inbox. To ensure you have access to every newsletter, alert and update, ensure that the following domains are on your “safe list”:
To know what to look for:
Weekly: The Dispatch newsletter is distributed every Wednesday.
Monthly: The hotline newsletter is distributed the first week of each month.
Various: Member alerts are distributed as necessary – usually the association sends two or three each month.
To learn more about ARSA’s communications efforts – including how to advertise – visit arsa.org/news-media. For assistance with technical issues, consult your organization’s IT department/assistant as necessary.
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 March:
New Members (Member Category)
Renewing Members (Member Category, Member Since)
Advanced Composite Structures Florida, LLC, R01, 2015
AerSale, Inc., R04, 2011
Air-Cert, Inc., R01, 1990
Aircraft & Component Technical Services, R01, 2009
Aircraft Component Repair, Inc., R03, 1987
Alpha Aircraft Services of America, R01, 2012
Aviation Avionics & Instruments, Inc., R03, 2012
Aviation Instruments Repair Specialists, R03, 1994
Barfield Precision Electronics, LLC, R04, 1996
C&S Propeller, LLC, R01, 2016
Carpe Diem Aviation Technical Services of Missouri, Inc., R02, 2012
Cobalt Aero Services, R01, 2012
Continental Aircraft Support, Inc., R03, 2004
Delta TechOps, Corporate, 2002
Gables Engineering, Inc., Associate, 1995
JAS Services/Team J.A.S., R01, 2004
Jet Aviation Specialists, Inc., R03, 1999
NAASCO Northeast Corporation, R02, 2002
PAS MRO, Inc., R01, 2013
Rapco, Inc., Associate, 1990
SkyWest Airlines, Associate, 2010
Tarrant County College, Educational, 2017
The Giles Group, Affiliate, 2013
Windsor Airmotive Westchester Division, R04, 1995
Quick Question – International Regulatory Cooperation
Support for international regulatory cooperation – pursuit of reasonable, reciprocal acceptance between and among regulatory agencies – is a key part of ARSA’s global support for the repair station community. Help the association lead discussion regarding international collaboration by sharing where your company would value new bilateral (or multilateral) aviation safety agreements:
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 (email@example.com).
Click here to see what questions have been asked and answered…and keep a lookout for more.
A Member Asked…
Q: The repair station ordered and received some parts from an authorized distributor of an “OEM.” The parts are not going to be installed on an EASA-registered aircraft. They were received with a COC with the following disclaimer:
“Unless accompanied by an FAA 8130-3 tag or equivalent certification provided by a duly authorized MANUFACTURER representative, this part was manufactured to an industry or aerospace OEM standard which may have dual use. Therefore, MANUFACTURER is not offering these parts for installation on an FAA type-certificated product unless the installer has FAA type-certificate approval, or other regulatory approval, to authorize the part and or next higher assembly airworthiness.”
My question is whether or not I as a part 145 repair station have the authority to install these parts and issue an FAA Form 8130-3 for the assembly? The parts only came with the paperwork supplied by the “authorized” distributor. The repair station can test the assembly per the component maintenance manual after replacing the parts. Is what is presented here sufficient to support issuing an approval for return to service?
Any insight you could provide would be much appreciated.
A: According to section 21.9, no person may produce an article when it knew or should have known that the part was reasonably likely to be installed on a type certificated aircraft without an approval. Additionally, section 3.1 applies to any person that makes a record (including sales documents) on a part “that may be used on a type-certificated product” without assurance that the part is airworthy under section 3.5(d).
So, IF the part(s) you are attempting to obtain is/are sold by a part number that “may be used” on a type certificated aircraft, the disclaimer on the certificate of conformity cannot eliminate the manufacturer and/or the seller responsibilities under either part 3 or 21. While the FAA may not enforce those regulations, it certainly cannot ignore them when it comes to an installer making its own determination of “airworthiness”.
The installer looks first at the definition of maintenance in section 1.1, which includes the replacement of parts. Then it turns to section 43.13, which requires the use of manufacturer’s manuals and service information, including associated IPLs and service bulletins. Paragraph (b) of that section requires the use of material of such a quality that the article being worked on is returned to at least its original (or properly altered) condition.
A maintenance provider must ensure the part is what it purports to be and is in a good condition through identification information, visual and other inspections no matter what paperwork comes with the article. Even parts with FAA Form 8130-3s from production approval holders can be “unairworthy” if manufactured or packaged incorrectly, damaged in shipment, or an airworthiness directive has been issued that prevents installation.
When the article (part) arrives with no production approval holder paperwork, the installer has to determine whether it is the correct part for the correct application—this is done partly through reviewing paperwork against the type or production approval holder’s (manufacturer’s) maintenance instruction, IPL and/or service bulletin, visual inspections, installation verification and testing. See, both ARSA’s E-100 form and the form for part or material substitution evaluation (both free to members) to help determine the nature and extent of the process needed to ensure the part you are buying and installing meets an approved design and is in a condition for safe installation (definition of airworthy in section 3.5). Those documents also provide the regulations and advisory material that allow a repair station to make a reasoned determination of eligibility for installation despite or in spite of the paperwork or lack thereof that accompanies a part.
2018 Member Survey – Thank You
The association is grateful for the time, effort and insight of the 125 respondents to this year’s member survey. This participation is vital to ARSA’s work on behalf of the maintenance community.
The survey team is currently analyzing response data. Stay tuned to ARSA’s newsletters and the data and advocacy page to see how the association makes use of survey responses in conjunction with its annual economic data and other special reports.
Didn’t get a chance to respond but want to share some thoughts? Submitted a response but have thought of more to say? Click here to contact ARSA and share your thoughts.
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 (firstname.lastname@example.org).
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 Americas – Orlando, Florida – April 10-12
Civil Avionics International Forum – Shanghai, China – April 17-18
MARPA EMEA PMA Aircraft Parts Conference – Dublin, Ireland – May 2-3
PBExpo – Ft. Lauderdale, Florida – May 16-17
AP&M Europe – London – May 29-31
EBACE – Geneva – May 29-31
MRO BEER – Ljubljana, Slovenia – June 6-7
RAA Summer Seminars – New Orleans, Louisiana – June 10-12
2018 FAA-EASA International Safety Conference – Washington, D.C. – June 19-21
the hotline is the monthly publication of the Aeronautical Repair Station Association (ARSA), the not-for-profit international trade association for certificated repair stations. It is for the exclusive use of ARSA members and federal employees on the ARSA mailing list. For a membership application, please call 703.739.9543 or visit arsa.org/membership/join. For information about previous editions, submit a request through arsa.org/contact. This material is provided for educational and informational purposes only. It does not constitute legal, consulting, tax or any other type of professional advice. Law, regulations, guidance and government policies change frequently. While ARSA updates this material, we do not guarantee its accuracy. In addition, the application of this material to a particular situation is always dependent on the facts and circumstances involved. The use of this material is therefore at your own risk. All content in the hotline, except where indicated otherwise, is the property of ARSA. This content may not be reproduced, distributed or displayed, nor may derivatives or presentations be created from it in whole or in part, in any manner without the prior written consent of ARSA. ARSA grants its members a non-exclusive license to reproduce the content of the hotline. Employees of member organizations are the only parties authorized to receive a duplicate of the hotline. ARSA reserves all remaining rights and will use any means necessary to protect its intellectual property.
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