2019 – Edition 5 – June 7
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.
Attention to Detail
By Brett Levanto, Vice President of Operations
This month, an ARSA online training user queried Executive Director Sarah MacLeod after completing “What is Acceptable to the Administrator? – The Performance Rules of § 43.13.” He contacted the instructor to contest the answer to question 26 on the test administered after the session:
True or False: A repair station must prepare and follow a repair station manual that is acceptable to the FAA.
We confirmed the caller was right (the answer was wrong), corrected the session materials, updated the syllabus and course information, re-loaded the materials and sent a note to all past attendees highlighting the correction. This happens from time to time: Training participants contact us with an issue with a session and we make corrections.
This time, it got us thinking. The session was recorded in 2016 and accessed hundreds of times. Nobody else noticed the error? Did some recognize the incorrect answer but not report it?
“Attention to detail” is a requirement in aviation and a standard to which ARSA holds itself (many an intern or job applicant has proclaimed to have it…only to find, the quality lacking under the association team’s standard). The focus on details does not eradicate failure, it enhances the responsibility to watch for, report and correct mistakes at all phases of an operation or objective. We hold ourselves, our members, our partners and our governments to high standards, often providing immediate correction to deviations.
The training team works hard to get everything right every time a session is created and posted. It’s what attendees need and deserve. With the association’s library approaching 100 sessions and new content being developed (including the Human Factors series and sessions supporting use of ARSA’s model manuals), there will always be opportunities to find errors.
We invite you to keep us attentive to the details needed to stay “smart, current and out of trouble” in your business operations and compliance activities.
How is your attention to detail? Put it to the test with a training session. Attendees have the enduring privilege of contacting instructors with questions and comments, and your help might earn you benefits for future sessions. Click here to get started.
What’s the right answer to question 26? Click here so you can find out.
Association members, allies and industry colleagues must support ARSA’s current initiatives to improve aviation policy. Here’s your to-do list for June 2019 (click each page link for more information and instructions):
Help bring FTC’s “Nixing the Fix” initiative to bear on maintenance manual availability…
Urge SBA review of maintenance manual availability…
Seek exemption from “current” maintenance data requirement…
Industry Helps White House Celebrate Charlie
On May 20, ARSA joined 12 other aviation industry organizations in delivering a letter to the White House seeking the president’s recognition of Friday, May 24 as Aircraft Maintenance Technician Day. Four days later, the president issued a message remembering Charlie Taylor and commemorating those doing his work in the world right now.
The day is the birthday of Charles “Charlie” Taylor, who was a partner of Orville and Wilber Wright in the development of the first powered heavier-than-air aircraft and is now considered the father of the aviation maintenance profession. It has been celebrated for years most U.S. states and Congress as “AMT Day.” By observing the day through employee recognition activities and industry celebration events, aviation businesses, trade associations and community organizations have turned it into a platform for celebrating those working in maintenance today and stimulating interest in professionals of tomorrow.
The group’s letter, which was coordinated by the Aircraft Mechanics Fraternal Association (AMFA), urges President Trump to recognize the contributions of Taylor and every AMT who has followed him.
“It is the knowledge, skill and integrity of the men and women who are the ‘faces behind safety’ that ensure the United States remains a leader in providing and maintaining safe, airworthy aircraft,” the letter said. “Continuously raising the standards by which they measure themselves ensures the needed technical skills are passed onto each succeeding generation of AMTs.”
While ARSA and its allies seek presidential recognition for May 24, the association encourages all of its members to celebrate the day. Those that have activities of any kind are encouraged to share them with ARSA (contact Brett Levanto at firstname.lastname@example.org). The association often highlights member celebrations via its various communications and is always looking for great examples.
To read the letter, click here. For information about AMT day and Taylor’s legacy, read the updates below.
In addition to ARSA and AMFA, the following organizations signed the letter:
Aerospace Maintenance Council
Aircraft Electronics Association
Aircraft Owners & Pilots Association
Airlines for America
Aviation Mechanics Coalition
Aviation Technician Education Council
Helicopter Association International
National Air Carrier Association
National Air Transportation Association
Professional Aviation Maintenance Association
Regional Airline Association
MRO Network Podcast: ARSA’s Levanto Talks Celebrating AMTs Every Day
How did you recognize AMT Day? Contact ARSA to share your activities and refer to this month’s Membership section for ways to honor the profession every day.
Technician Shortage Costs $100 Million Per Month
ARSA’s 2019 Member Survey paints a picture of a thriving, international industry whose growth and vitality are being threatened by a chronic shortage of technical workers.
Eighty-six companies, representing a diverse cross section of the industry and ARSA’s membership, responded to the annual data-gathering exercise. Repair stations come in all shapes and sizes, from small, highly-specialized component shops with one location to large engine and airframe facilities with facilities spread across the country, or even the world. Reflecting that diversity, approximately half the respondents who provided revenue information did less than $10 million in business in 2018, while ten percent had revenues well over $1 billion. Most respondents (92%) were headquartered in the United States, but member companies headquartered in Costa Rica, France, German, Israel, Japan and the Netherlands also participated.
Profitability Increasing, Markets Growing
ARSA members report that business activity is strong and they are confident about the future:
- Fifty-seven percent said their unit margin/profitability increased in past two years; just 12 percent reported a decrease.
- Sixty-six percent expect revenues and markets to grow in the coming year; only four percent expect contraction.
- Sixty-eight percent expect to add positions and/or hire new workers in coming year; just one percent predicted layoffs.
Supporting Global Customer Base
Underscoring the importance of international business to repair stations, close to a quarter of respondents (22 percent) said they plan to seek new certifications from aviation authorities outside the United States in the next two years. Fifty-two percent of those companies plan to seek European Aviation Safety Agency approvals and 21 percent plan to seek approval from China’s Civil Aviation Authority. Respondents also indicated their intentions to seek approvals from the United Arab Emirates, Qatar, Indonesia, the Philippines, Mexico, Malaysia, El Salvador, Costa Rica and India. Fifteen percent of the U.S.-based companies participating in the survey said they operated repair stations outside the United States.
Government Business Having Big Impact on MRO
Government customers are also important to the repair station community. More than half of respondents (62 percent) reported during business with some federal, state or legal entity in the United States or overseas. Forty-six percent of respondents said they had military customers, 26 percent indicated they did business with other federal departments or agencies, 14 percent had state-government customers and eight percent performed work for local or municipal governments.
Technician Shortage is Biggest Concern, Costs Industry $1 Billion Per Year
While the business forecast is good and industry leaders are generally optimistic, as reflected in past ARSA surveys, the technician shortage is a major concern.
Ninety percent of U.S. survey respondents reported difficulty finding technician workers over the past two years, with 38 percent reporting “a lot of difficulty”. More than half the respondents (56 percent) identified “difficulty finding/retaining technical talent” as a risk to their company’s profitability, revenue or workforce forecast over the next five years. Other top risks/concerns included availability of maintenance information and manuals (51 percent), inconsistent enforcement and interpretation of rules by aviation regulators (41 percent) and regulatory costs and burdens (36 percent).
Underscoring the workforce challenge, more than two-thirds (71 percent) of U.S. companies reported vacant technician positions, a total of 4,615 openings. All those empty positions are having real consequences for repair stations and their customers. Three quarters of respondents (77 percent) report that it’s taking longer to complete work than it would if the company was fully staffed, more than half (58 percent) report increased labor costs due to overtime for current employees and/or additional training to cover knowledge gaps and 15 percent report turning down new business or customer opportunities due to the labor shortage.
|Annual Job Vacancy-Related Economic Losses to U.S. Repair Stations|
|Median Vacancies per Facility||2|
|Number of FAA-Certificated U.S. Repair Stations||4,028|
|Median Annual Revenue Per Employee from ARSA Survey||$176,389|
|Total Annual Economic Loss||$1,420,989,784|
|Average Revenue per Employee from CAVOK-Oliver Wyman Data||$116,597|
|Total Annual Economic Loss||$942,294,208|
Based on the survey data, ARSA projects the technician shortage is costing the U.S. aviation maintenance industry $118.416 million per month ($1.421 billion per year) in lost revenue. The figure was derived by multiplying the median vacancy rate of two positions per facility by 4,028 (the number of U.S.-repair stations certificated by the FAA) by the median annual per employee revenue derived from the survey ($176,389). A more conservative annual revenue-per-employee figure of $116,597 (derived by dividing 2018 U.S. maintenance, repair and overhaul (MRO) sector revenue by 219,045 MRO sector jobs, as reported by CAVOK-Oliver Wyman) still yields significant economic losses of $942.3 million annually.
Those figures underscore the importance of ARSA’s work to attract, retain and train maintenance technicians. Among other things, the association is a leading a coalition to secure funding for the new technician workforce development grant program created at ARSA’s urging by the 2018 FAA reauthorization law and promoting repair station careers through its public relations and regulatory activities.
Members Appreciate ARSA’s “Trusted and Reliable” Advocacy
Overall member satisfaction with the association high, with respondents giving the association an average grade of 4.43 on a five-point scale, with five being “very satisfied”. Survey participants said they appreciated ARSA’s “trusted and reliable” advocacy for the industry. “ARSA is the voice of our industry in D.C. and with foreign authorities,” one respondent said. “Without ARSA, many burdensome and unnecessary regulations would have been passed that would be costing the aviation industry millions without adding any value.” Others cited ARSA’s value as a source of knowledge, training and insights on regulatory and legislative topics. Respondents ranked the following as the association’s top five member benefits on a five-point scale (with five meaning “extremely valuable”):
- Access to ARSA’s expertise (regulatory and legislative) (4.6/5)
- Regulatory advocacy (4.49)
- Free regulatory compliance resources (4.17)
- Congressional advocacy (4.03)
- Dispatch and hotline newsletters (4.01)
“Thanks to all the members across the U.S. and the world who took the time to respond to our 2019 survey,” ARSA Executive Vice President Christian A. Klein said. “The data our members provide helps us tell the industry’s story and ensure our priorities are aligned with member needs.”
If you missed ARSA’s 2019 survey, there’s still a chance to make your voice heard. ARSA runs monthly “quick question” surveys to get input on hot topics. To see our latest “quick question” and share your views, go to arsa.org/qq-archive.
To see the publicly-released version of the survey results on ARSA’s website, visit arsa.org/survey2019.
Industry Illustrates the “Aviation Maintenance Profession”
On May 6, a coalition of 16 aviation industry associations jointly submitted comments to the FAA’s Draft Advisory Circular (AC) 65-30B, “Overview of the Aviation Maintenance Profession.” Led by ARSA, the group continued work begun in 2014 when the agency last released a draft version of the AC – which hasn’t been officially updated since 2001 – for comment.
As described by the FAA, the purpose of the AC is to provide information to individuals interested in careers in aviation maintenance. Considering intense focus on workforce and technical skills development issues, helping to produce a useful “overview” of the profession was an industry-wide imperative.
“As representatives of persons involved in the design, production, operations and maintenance of civil aviation products and articles, each organization supporting these comments depends on a vibrant pool of talented aviation maintenance professionals to ensure safety worldwide,” the group explained in its submission. It provided general guidance for crafting the AC as well as a “draft industry submission”; an updated version endorsed by each of the signatory organizations to be considered for FAA adoption.
The industry-provided draft was constructed based on the three points described for the agency by the group’s comments:
(1) Begin with skills.
(2) Show the breadth of the “profession.”
(3) Demonstrate career opportunities.
On this last point, the industry’s draft AC focused intently. It described the aviation maintenance profession as a field of five career pathways including noncertificated professionals, certificated repairmen, certificated mechanics, mechanics holding inspection authorization and transitioning military personnel.
“There is no single point of entry or career trajectory for aviation maintenance professionals,” the draft industry submission said. “Depending on knowledge, education, experience, skill and curiosity, individuals with an interest in the kinds of hands-on, intellectually-challenging and technically-skilled work performed in all manner of aviation maintenance facilities may begin or continue a career through any one of the ‘pathways’ described in this AC.”
While the agency deliberates over the industry’s comments, ARSA will work to utilize the content produced by the effort. Rather than wait for the official release of a new AC, the association and its allies can make good on their combined effort by helping get this updated “overview of the aviation maintenance profession” into circulation right now.
To help, download and read the full submission (click here). Then share it: Circulate to colleagues, educational partners, local schools, guidance counselors – help get it to “anyone interested in creating or advancing aviation careers.” (Contact ARSA for more information about workforce development resources.)
In addition to ARSA, the following organizations supported the comments:
Aerospace Industries Association
Aircraft Electronics Association
Aircraft Owners and Pilots Association
Airlines for America
Association of Women in Aviation Maintenance
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
National Business Aviation Association
Professional Aviation Maintenance Association
Regional Airline Association
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.
Is Enforcement Applicable?
By Sarah MacLeod, Executive Director
A recent conversation highlighted an interesting dilemma: Is part 43 always applicable when working on any aircraft?
The question then became, how the heck does the maintenance provider know the certificate history of the aircraft? To complicate further, how will the maintainer know the certificate history for an aircraft when working on a component? Does it really matter pragmatically? The maintenance provider should always use “methods, techniques and practices” acceptable to the FAA and do the work in such a manner as to return the article at least to its original (or properly altered) condition. Since part 43 will be followed regardless, what is the “real” issue?
Enforcement is the issue. When does the FAA’s jurisdiction attach to maintenance activities? Discerning the applicability of part 43 and its impact on compliance with the safety rules in general is vital for any airman, no matter what the tail number on the aircraft or the origins of its certificate.
Beginning with the basics, the country of “registry” controls aircraft maintenance. Part 43 governs maintenance of U.S. registered aircraft with an FAA issued airworthiness certificate. A 2011 legal interpretation helps explain the FAA’s jurisdiction:
The FAA has no jurisdiction to impose operations and maintenance requirements (e.g., plans for aircraft drinking water systems) for a foreign registered aircraft operated by a foreign carrier, because the FAA is neither the State of Registry of the aircraft, nor is the FAA the State of the Operator for the foreign air carrier.
When performing maintenance on aircraft issued airworthiness certificates, repair stations must adhere to requirements under part 145. Does the FAA have jurisdiction under part 145 over maintenance facilities who perform work on U.S. registered aircraft that do not have airworthiness certificates? A 2010 interpretation regarding articles to be installed on a foreign-registered aircraft considered the applicability of part 145 and its relationship to part 43.
“Nothing in the part 145 applicability section was even remotely intended to address maintenance or alterations of aircraft and parts of those aircraft not within FAA’s jurisdiction,” the agency said, referencing an earlier interpretation finding that the performance or signing off on work does not in itself require U.S. regulatory oversight. “It is our opinion that a repair station is not exercising the privileges of its certificate when it performs work for which part 43 is not applicable.”
In a 2015 letter exploring the limits of an experimental certificate further illustrates that the applicability of part 145 is based on the applicability of part 43 which does not apply to experimental aircraft. The letter answered the ultimate question regarding the ability of a certificated repair station to perform the work even if not rated to do so, noting that in many cases this is “the only viable option” for an owner/operator and that “[b]ecause part 145 specifically does not apply to certain experimental aircraft, neither does the prohibition in § 145.201(b) that no repair station may ‘maintain or alter any article for which it is not rated’.”
Now we return to our issue of enforcement. Understanding the applicability of part 43 must be done in the context of every rule governing operation and maintenance of the aircraft. Considering the applicability of part 43 to maintenance performed on experimental aircraft boils down to the specific technical task to be completed or component repaired in each individual case.
In the 2015 letter, the agency explained that part 91 applies to experimental aircraft and that no FAA regulations “would prohibit a certificated repair station from performing maintenance for an owner or operator who seeks to bring an experimental aircraft into compliance with §§ 91.411 and 91.413. Therefore, even though part 43 by its own terms does not apply to experimental aircraft, §§ 91.411(a) and (b) and 91.413(a) and (c), incorporate certain part 43 requirements.”
In 2010, the builder of a kit turbine-powered rotorcraft with an experimental certificate sought the ability to use an annual inspection under § 91.409(a) in lieu of the FSDO-approved maintenance program specified in the certificate’s operations limitations. The letter instructed that § 91.319 “prescribes specific operating limits that are applicable to all aircraft issued experimental certificates” and § 91.319(i) further authorizes the Administrator to issue other limits as necessary. The builder’s desire to use an annual inspection under § 91.409(a), (b), (c), or (d) for a turbine-powered rotorcraft in lieu of an inspection option under § 91.409(f) was not permitted because these inspections are performed under part 43 requirements. Section 91.409(c)(1) specifically notes it does not apply to “an aircraft that carries…a current experimental certificate.” The agency determined that an annual inspection cannot be used in lieu of the approved maintenance program.
Though part 43 may not be enforceable in all cases it may nevertheless be applicable. Section 91.407 prohibits anyone from operating any aircraft that has undergone maintenance until the work is approved for return to service.
The bottom line is the enforceability of part 43 is dependent on other regulations. Maintenance on specific components for experimental aircraft may incorporate certain sections of part 43, such as required inspections for altimeters or transponders under §§ 91.411 and 91.413 or the keeping of maintenance records and applicable forms.
In its 2015 interpretation, the FAA said, “[t]he exclusion of experimental aircraft from part 43 has consequences throughout our regulations.” Part 145 is applicable to the extent that part 43 applies to any aircraft with an airworthiness certificate. When operators and maintenance providers choose to follow part 43 when not applicable, they should always be aware of when compliance is required.
An operator or maintenance provider may choose to hold themselves to a part 43 standard, though it may not always be enforceable.
Sarah MacLeod is managing member of Obadal, Filler, MacLeod & Klein, P.L.C. and a founder and executive director of the Aeronautical Repair Station Association. She has advocated for individuals and companies on international aviation safety law, policy and compliance issues for 30 years.
ARSA on the Hill
Workforce Funding, Overbearing Oversight & Administrative Delay
By Christian A. Klein, Executive Vice President
We are a few steps closer to securing funding for the new aviation maintenance workforce grant program.
As a refresher, ARSA Is leading a coalition that helped enact legislation as part of last year’s FAA bill to provide grants of up to $500,000 to companies, schools and governmental entities that work together to address the maintenance technician shortage. With the program authorized, the next step is to secure funding for the grant program as part of the FY 2020 appropriations process (for more about the process, see “Legal Brief: Guarding the Hen House” in the March 2019 edition of the hotline).
The FY 2020 Transportation, Housing & Urban Development and Related Agencies appropriations (T-HUD) bill (T-HUD) reported by the House Appropriations Committee on June 4 included full funding ($5 million) for both the maintenance technician program and a parallel program for pilot education.
“The Committee supports increasing the strength and number of aviation professionals who are well-trained and can be relied upon to make air travel safe and efficient,” the committee report accompanying the bill said. “To that end, the Committee provides $5,000,000 for the aviation maintenance technician development program and $5,000,000 for aviation workforce development program.”
While committee passage of the funding bill is an important step forward for the grant program, we’re still a long way from money being distributed. The T-HUD bill must be voted on by the full House of Representatives and the Senate has yet to even release its version of the bill, let alone vote on it at the subcommittee and full-committee level. Adding to the challenge is that the entire appropriations process has become less predictable in recent years. It’s not outside the realm of possibility that negotiations and partisan squabbling over the T-HUD and other funding bills could drag out beyond the end of the current fiscal year on Sept. 30 (the collapse of last year’s negotiations led to the longest partial government shutdown in U.S. history).
The appropriations process aside, before any grants can be made, the FAA and the Department of Transportation must also establish a process for receiving applications and awarding funds. ARSA and its allies believe the executive branch should be working to set up the program now and begin accepting applications so money can be doled out as soon as its appropriated.
The creation of the program and progress we’ve made so far underscore how effective ARSA, its members and its allies can be on Capitol Hill when working together to address a common problem. A new ARSA analysis suggests that the technician shortage is costing repair stations $100 million per month in lost economic activity. Concerned ARSA members are requested to contact Congress in support of grant program funding. ARSA’s Workforce Legislation Action Center makes it quick and easy!
|Tell Congress to Make Aviation Workforce a Priority
ARSA’s signature legislative victory in 2018 was convincing Congress to create a new grant program help repair stations recruit and train aviation maintenance technicians. Our priority now is getting the program funded … and we need your help. ARSA has completely revamped our grant program action center to help you learn more about the issue and urge your members of Congress to appropriate the money we need. It’s quick and easy. Take a second now the tell your elected represents to make aviation workforce a priority!
737 MAX Policy Fallout Still Unclear
Lawmakers on Capitol Hill are continuing to investigate Boeing and the FAA in the wake the two recent 737 MAX accidents. The relationship between industry, regulators and the decades-old system of delegating responsibility for some certification tasks have come in for particular scrutiny.
Acting FAA Administrator Dan Elwell defended his agency at a May 14, 2019 House Transportation & Infrastructure hearing at which members expressed concerns about the agency’s oversight. However, lawmakers pulled no punches. “The committee’s investigation is just getting started and it will take some time to get answers, but one thing is clear right now: The FAA has a credibility problem,” House Aviation Subcommittee Chairman Rick Larsen (D-Wash.) said.
Lawmakers posed questions about why the FAA had waited so long to ground the 737 MAX, pilot training on the new aircraft and delays in implementing software updates to prevent the Max’s maneuvering characteristics augmentation system from activating based on bad data.
The House T&I Committee is apparently planning another hearing on issues related to the Max on June 19 (although the committee hasn’t formally released details about the upcoming hearing).
Whether, when and how Congress might address its concerns through legislation remains an open question. Lawmakers completed a comprehensive FAA bill late last year that authorized funding for the agency through FY 2023. Under ordinary circumstances, it would be unusual for Congress to take up another broad FAA bill so soon after reauthorization.
For ARSA’s part, facts and data, not emotion, should be the basis of aviation policy. The recent and tragic accidents in Ethiopia and Indonesia notwithstanding, industry and regulators have together achieved a remarkable safety record (43,000 flights and 2.6 million airline passengers per day in the United States, with just one fatality in the last decade). Ultimately, the need for additional legislation will depend on the outcome of the various reviews and investigations being conducted by the FAA and Congress. Lawmakers must wait until the facts are in before tinkering with a system that’s made air travel the safest form of transportation.
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.
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Dickson FAA Nomination Vote Delayed
The Senate Commerce, Science & Transportation Committee has delayed a vote on Steve Dickson’s nomination to head the FAA pending the outcome of a committee inquiry about claims of retaliation against a whistleblower at Delta during Dickson’s tenure as the company’s vice president for flight operations. Information about the case emerged after the committee held a May 15 nomination hearing at which senators praised Dickson, a former pilot and senior Delta executive, as a good choice to head the agency.
Dickson was nominated by President Trump to serve as FAA administrator on March 19. If confirmed, he will replace Dan Elwell, who has served as acting administrator since January 2018 (and is now the longest-serving acting administrator in FAA history).
Mutual Recognition Effort Continues at CABA Meeting
On May 16, the Certification Authorities for Bilateral Agreements and Certification Policy (CABA) met with industry representatives to discuss the latest policy initiatives affecting the four regulatory authorities (FAA, EASA, TCCA and ANAC) of the Certification Management Team (CMT). Several trade associations attended the meeting including ARSA (represented by its Managing Director & General Counsel Marshall Filler), GAMA, AEA, ASD, AIAC and AIAB. Various regulators specializing in certification policy matters from the four agencies also participated.
The CABA is one of the Certification Authority Groups (CAG) that reports to the CMT on certification policy and procedures. In contrast, the product-specific CAGs focus on the applicable airworthiness standards, guidance and policy pertaining to particular kinds of type-certificated products.
Notwithstanding the current political climate and concerns raised about the FAA’s delegation system in the wake of the 737 MAX 8 accidents, industry urged the authorities to continue making progress to effectively implement CMT strategy to bolster maintenance of interagency confidence and implement risk-based validation principles. Essential to accomplishing these objectives is the development of criteria and guidance for managing safety emphasis items (SEI) and the need for effective scalable processes to manage work plans for non-basic projects. A workplan defines the level of involvement by the Validating Authority (VA) whereas basic projects can either be accepted outright by the VA or are handled by a streamlined validation process (i.e., no technical involvement by the VA).
Generally, the more SEIs the greater the level of involvement by the VA. The current efforts are all about balancing a civil aviation’s authority’s legal right to make its own findings of compliance with the safety value of conducting another technical assessment. The belief among industry and the CMT members is the authorities can continue reducing the number of redundant technical determinations in the certification arena by applying risk-based, systems safety principles.
Keeping it Simple at FAA Global Leadership Event
On May 7, the FAA hosted industry members for the first day of its 6th Annual Global Leadership Meeting in Washington, D.C.
The event included a full day of panels discussions, “chats” and presentations covering the agency’s global engagement. The agenda included both general content covering worldwide strategy and initiatives as well as regional panel discussions, each with a specific focus determined by key regional needs:
(1) Strategic Engagement and Leadership at ICAO
Thomas Carter, U.S. Ambassador, ICAO
Don Ward, U.S. Air Navigation Commissioner, ICAO
Carl Burleson, Acting Deputy Administrator, FAA [Moderator]
(2) Chat with the Administrator
Dan Elwell, Acting Administrator, FAA
Bailey Edwards, Assistant Administrator for Policy, International Affairs and Environment, FAA [Moderator]
(3) Opportunities for Innovation: Asia Pacific Region
Mimi Dobbs, Director, Asia Pacific and Global Harmonization, MITRE Corporation
Nancy Graham, President, Graham Aerospace International
Alissa Lee, Country Manager, East Asia and Indo-Pacific Regions, U.S. Trade and Development Agency
Winsome Lenfert, Deputy Associate Administrator for Airports, FAA
Carey Fagan, Director, Asia Pacific Region, Office of International Affairs, FAA [Moderator]
(4) Resilience and Recovery: Disaster Preparedness and Response in the Western Hemisphere
Melvin Cintron, Director, ICAO North America, Central America and Caribbean Region
Katherine Dueholm, Director, Office of Caribbean Affairs, U.S. Department of State
Javier Venagas, Director, Civil Air Navigation Services Organizations, Latin America and Caribbean Office
Nari Williams-Singh, Director General of Civil Aviation, Jamaica and Chair, Caribbean Aviation Safety and Security Oversight System
Christopher Barks, Director Western Hemisphere Region, Office of International Affairs, FAA [Moderator]
(5) Priorities & Engagement: Opportunities in Africa, Europe, Middle East Region
Walter L. Desrosier, Vice President, Engineering & Maintenance, General Aviation Manufacturers Association
Keith Glatz, Vice President, International Affairs, Airlines for America
Susan Walsh, Director, Commercial & International Programs, Pratt & Whitney
(6) U.S. Global Leadership
Will Ris, Former Senior Vice President of Government Affairs, American Airlines
Wayne Schatz, Associate Deputy Chief of Staff for Operations, U.S. Air Force
Brian Wynne, President and Chief Executive Officer, Association for Unmanned Vehicle Systems International
Bailey Edwards, Assistant Administrator for Policy, International Affairs, and Environment [Moderator]
The key theme from the day’s discussion was the need for “data driven decision making” and intense scrutiny of procedures and processes at both the agency and stakeholder levels. In his “chat” during the morning session, Acting Administrator Elwell pushed back on breathless media reports regarding the FAA’s purported loss of standing as an international leader. He noted that leadership was not about timing of an action, i.e., being first to ground an aircraft, but taking action based on deliberate, fact-based critical analysis.
“We don’t rest on our laurels and I think the world needs to know that,” Elwell said, highlighting the FAA’s need to continually improve.
From the industry perspective, this need for critical analysis was brought into focus by U.S. Ambassador to ICAO Thomas Carter. Carter described the dizzying flow of information, pages of reports and analysis and lineups of industry experts seeking assistance from the air navigation commission. This constant demand for attention makes it nearly impossible for commissioners to parse needed details.
“Keep it simple,” Carter implored industry members communicating with ICAO. Through a broader lens, this guidance is instructive for any engagement with the any government or stakeholder body. Assist in data-driven decision making and critical scrutiny by providing clear input and direct requests. Perfect a question before asking and participate in the process of answering.
Carter also provided a moment of levity, riffing on a familiar office quip by noting that “[At ICAO], the meetings will continue until morale improves.” The joke was ironic, of course, coming during a presentation at an industry-government collaboration meeting, but fit in the flow of the day’s discussion and purpose, which was further underscored by Elwell: system safety depends on useful collaboration.
The event continued with a government attendee-only day of discussions on March 8 (click here to see the agenda for Day Two). There is no website or publicly-available resource for the conference, for more information contact ARSA.
FAA Renews IA Acceptability for Eight ARSA Training Sessions
On May 28, the FAA renewed acceptance for Inspection Authorization renewal credit under 14 CFR § 65.93 of eight hours of ARSA on-demand training. Each session is now eligible through May 2021 for IA renewal credit and is currently available for registration and immediate access:
ICA – The Basics
IA Course Acceptance: C-IND-IM-170830-K-010-002
This session provides an overview of the regulatory basis for ICA, including what documents are considered ICA and the obligations of design approval holders to prepare, furnish and otherwise make them available under 14 CFR § 21.50(b). It also covers the related regulations that apply to operators and maintenance providers regarding the use of ICA and their availability. Finally, it shows how the FAA has interpreted some of the more important ICA requirements in Order 8110.54.
ICA – Case Study: Testing Your Knowledge
IA Course Acceptance: C-IND-IM-170830-K-010-001
This session tests the participants’ knowledge of the ICA regulations in Title 14 CFR and FAA guidance by presenting several hypothetical case studies. Each one will focus on one or more of the significant ICA regulatory principles.
Major/Minor – Major Pain Over a Minor Issue
IA Course Acceptance: C-IND-IM-170830-K-010-003
This session reviews the regulations that govern the terms “major” and “minor” in the world of civil aviation repairs and alterations. Learn the regulatory facts and how to train your FAA inspector so this minor issue doesn’t become a major pain in the derrière.
Part 21 – Overview
IA Course Acceptance: C-IND-IM-170830-K-010-004
This session provides an overview of the aviation safety regulations governing design and production of civil aviation products and articles as well as airworthiness certification of civil aircraft.
Part 65 – Getting a Mechanic’s Certificate
IA Course Acceptance: C-IND-IM-170830-K-010-005
This session reviews the requirements of 14 CFR part 65 subpart D, which concerns aviation mechanics. It walks through the requirements for an individual to apply for a mechanic’s certificate, then defines the privileges and limitations bestowed on that individual by his or her certificate. Finally, it covers the enhancements to a mechanic’s privileges produced by obtaining Inspection Authorization.
Recordkeeping for Mechanics
IA Course Acceptance: C-IND-IM-170830-K-010-006
This session defines the regulatory responsibilities of the operator versus the maintenance provider in creating and maintaining maintenance records, including how obligations can be shifted by contract, but not under aviation safety regulations. It also covers maintenance recordkeeping regulations; the documents essential to making airworthiness determinations.
Regulations Impacting the Purchase of Aircraft Parts
IA Course Acceptance: C-IND-IM-170830-K-010-007
This session reviews the civil aviation regulations in Title 14 Code of Federal Regulations that impact the purchase of civil aviation parts, as well as other requirements that should be considered.
What is “Acceptable to the Administrator”? – The Performance Rules of § 43.13
IA Course Acceptance: C-IND-IM-170830-K-010-008
This session provides an overview of the regulations that use the language “acceptable to” the Federal Aviation Administration and how to determine what makes something acceptable to the agency.
More accepted training…
In addition to these eight sessions, ARSA has current FAA acceptance for three other hours of training from its Human Factors series:
Registration for an ARSA-provided training session includes:
- Unlimited access for 90 days to the recording made available after the live session is complete.
- A copy of the presentation and all reference material with links to relevant resources and citations.
- A certificate upon completion of the class, as well as 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.
Getting to the Point
The ARSA training team values your time and energy.
In an effort to minimize the time and steps required to browse, search, find and register for the association’s training sessions – there are now more than 70 hours available in the library for immediate on-demand viewing – the training page has been redesigned. Users needing logistical or administrative information can still find it, but it’s now a lot faster to jump directly into searching the session library on the online training platform (which is outside of ARSA.org).
Jump to the page (and bookmark it!) or review the various training resources by starting right here:
Government employees: Contact ARSA directly for auditing opportunities.
Registration: Registration and payment may be processed directly through the training platform/course catalog (free account creation required).
Technical questions and assistance: Click here for FAQ and technical support from training platform vendor.
Refunds: No refunds are granted for ARSA training sessions. When classes are canceled, registrants can choose from future courses of equal value. If a registrant is unable to attend a live session, their registration allows access to the on-demand, recorded version of the webinar.
IA Approval: A number of ARSA training sessions have been accepted for Inspection Authorization (IA) renewal credit. These sessions are denoted on their registration page with their FAA course acceptance number (in red).
Benefits: Registration for an ARSA-provided training session includes:
- Access to the live class session on the scheduled date (if applicable).
- Unlimited access to the on-demand, recorded version of the webinar to be made available after the live session is complete (or at time of purchase, for on-demand classes).
- A copy of the presentation and all reference material with links to relevant resources and citations.
- A certificate* upon completion of the session as well as any required test material.
OFM&K Training Portal: All of ARSA's training sessions are provided through OFM&K's training portal. As the training provider of choice for ARSA and a trusted resource for the aviation community, the firm's training materials represent a vital tool for entities pursuing regulatory compliance and business success. All of the courses are administered via PotomacLaw.InreachCE.com, which is not part of ARSA's website.
Audit Activism & Prophylactic Lawyering
Drug & Alcohol Testing
Instructions for Continued Airworthiness
Parts 21, 43, 65, 145 (and others)
Public Aircraft"Going Global" - International Regulatory Law
Recordkeeping – "Finishing the Job with Proper Paperwork"
The Fourth Branch of Government (Administrative Agencies and Procedures)
Self Disclosure Programs and Practices
(1) Subscription. Make up-front, bulk purchases of training hours. The details of each subscription can be customized, including focus on specific subject areas (e.g., human factors) or options for specially-priced session access after the initial hours have been used.
(2) “Championing” a session. Guarantee a certain number of attendees for training in a particular topic that will also be made available for general registration. Variations include open registration for a live session (i.e., company personnel participate at the same time as general registrants) or a company-specific live event for which a recorded version (not including any company-specific information) is made available for on-demand registration.
(3) Tailored training. Contract ARSA's management firm Obadal, Filler, MacLeod & Klein, P.L.C. to produce or modify training specific to your organization. The team can then re-record it (or offer it as a separate live session) for ARSA’s training program. Tailored programs are priced differently from ARSA’s hourly rate and are administered by OFM&K, which allows for a client engagement and related attorney-client privilege for all discussion.For more information about ARSA's training program, review the menus below. If you have questions or would like to learn more about ways to integrate ARSA training into your own program, contact Vice President of Operations Brett Levanto (email@example.com).
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 the FAA – Stopping the Buck
The FAA Safety Team’s website (www.faasafety.gov) provides instruction and resources for aviation industry personnel. As an example of the resources available through the agency, this month’s edition of the hotline spotlights free government training on the failure to follow procedures.
Description: While aviation maintenance personnel are fully aware of the consequences of failing to follow procedures – and have likely received training on this issue – FFP continues to be one of the leading safety issues in aviation maintenance. FFP is not a technical issue – it is about attitude and commitment. This course is designed to help aviation maintenance personnel to better understand and appreciate how an organization’s culture affects safety with respect to FFP by focusing on the culture of procedure following.
Regulatory Compliance Training
Test your knowledge of 14 CFR §§ 65.103 & 65.105 – Repairman certificate: Privileges and limitations; Display of certificate (Repairman).
The Good Example – CRT’s S.O.A.R. Program
In early May, Component Repair Technologies (CRT; ARSA member since 1994) welcomed candidates and parents to the Student Opportunities in Aviation Repair (S.O.A.R.) program taking place in June. The open house included a facility tour, a S.O.A.R. program overview and served as “signing day,” commending the students for choosing to enter the workforce directly after high school graduation.
Students from across the Northeast Ohio region will join the CRT team from June 3-27, providing them with exposure to lucrative career paths in visual & dimensional inspection, non-destructive testing, welding, machining and industrial maintenance. These career paths represent a small sampling of the opportunities available to CRT employees as they learn, grow and gain knowledge in the business.
“We are excited to welcome these 16 recruits and their families to the CRT team. Many have already been in our facility through tours with their high school and are eager to be a part of the work we do in aviation; now we look forward to showing the parents why their kids committed to the S.O.A.R. program,” said John Gallagher, CRT human resources manager.
“We have been developing partnerships with area districts so we can directly reach kids and teach them about the value of a career in manufacturing. It has been great to talk to students, show them around our facility, and see them begin to understand that there are exciting and truly viable options after high school other than college,” said Kristin Conteen, marketing and community relations specialist.
During the four-week program students will “learn while they earn” by working in an entry level position, job shadowing, attending life skills programs and seeing the Lake County area during scheduled outings to extracurricular events. At the end of the four weeks, eligible students will be extended offers to stay onboard with CRT and begin a career path in their chosen area of expertise.
There are many ways to follow CRT’s good example and ARSA encourages members to get active in support of its workforce-development initiatives. In particular, repair stations should encourage Congress to fund the association’s workforce grant program – visit arsa.org/legislative/grant-program-action-center to learn how.
|Component Repair Technologies, Inc. (CRT) is an FAA certificated repair station specializing in gas turbine engine component repairs for air, land, and sea. Our wide variety of processes and skilled employees have positioned us as leaders in the aviation, industrial, and marine turbine component repair industry. CRT has built a reputation for quality and responsive service by providing precision turbine engine component inspection, repair and overhaul services for the world’s leading turbine engine manufacturers and major airlines since 1985. Visit componentrepair.com for more information.|
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 May:
New Members (Member Category)
Parker Hannifin Corporation, R06
Earp Aviation Repairs LLC, R01
Renewing Members (Member Category, Member Since)
AeroKool Aviation Corporation, R04, 2017
Aerospace Quality Research & Development 145, LLC, R01, 2006
AgustaWestland Philadelphia Corp., R04, 2012
Aircraft Tooling, Inc., R02, 2004
Coopesa, R.L., R06, 1996
Fleet Support Services, Inc., R01, 2013
Hancock Enterprises Inc., R01, 2020
Jet Aviation Specialists, LLC, R03, 1999
L. J. Walch Co., Inc., R03, 1985
Metro Aviation, Assoc, 2003
Pac West Helicopters, Inc., R02, 2009
Pacific Aero Tech, LLC, R04, 1994
Piedmont Propulsion Systems, LLC, R03, 2011
Performance Repair Group, R02, 2013
R.W. Raddatz, Inc., R02, 2004
Shoreline Marine, Inc., dba Safetech – Humble, R02, 2002
SkyWest Airlines, Assoc, 2010
Timberline Helicopters, Inc., Assoc, 2013
Triumph Airborne Structures LLC, Corp, 2003
Twin Manufacturing Co., dba TWIN MRO, R04, 1993
AMT Day – What Did/Can/Will You Do?
Charles Taylor, the Wright Brothers’ mechanic and father of aviation maintenance, was born on May 24, 1868. Now – 151 years later – we celebrate him with every safe arrival.
In 2008, a congressional resolution dedicated the date in honor of Taylor, establishing National Aviation Maintenance Technician Day. While the “holiday” doesn’t get anyone out of work (there are no days off from aviation safety), it’s important to celebrate the commitment, integrity and skill of every aircraft mechanic and all those who support them – this is Taylor’s legacy and our shared responsibility.
Hopefully all ARSA members did something to recognize May 24, 2019. Those that had celebrations or activities of any kind are encouraged to share them with ARSA (contact Brett Levanto at firstname.lastname@example.org). The association often highlights member celebrations via its various communications and is always looking for great examples.
If nothing special was done on May 24, here are some ways to celebrate AMTs on any day:
(1) Talk with fellow technicians, colleagues and friends about how they became technicians. Ask what inspires them about the work. If you hear a great answer, send it to ARSA.
(2) Plan a visit to a local school or invite students to tour your facility. Show off for a day, maintenance work is interesting an important. Take some pictures and send them to ARSA.
(3) Hold a screening (or send around) the association’s short documentary “You Can’t Fly Without Us – The World of Aviation Maintenance.”
(4) Support industry events, particularly those that showcase the talent and skill of technicians. This year’s Aerospace Maintenance Competition just wrapped up in Orlando, check out the highlights of the event and see how you can get involved next year.
(5) Hot off the press: Send the industry-drafted “overview of the aviation maintenance profession” to your local elementary, middle and high schools, then offer to come talk with students about the industry.
No matter how you celebrated AMT Day, it’s a small bit of well-deserved recognition. Thank you for your hard work, dedication and support.
The world can’t fly without you.
Quick Question – Repairman Applications & Employment
In 2018, ARSA helped the U.S. Congress consider the value of repairman certificates. Section 582 of the law reauthorizing the FAA instructed the administrator “assign to the Aviation Rulemaking Advisory Committee the task of making recommendations with respect to the regulatory and policy changes, as appropriate, to allow a repairman certificate issued under section § 65.101 of title 14, Code of Federal Regulations, to be portable from one employing certificate holder to another.”
Exploring and supporting the value of repairman’s certificates is a key part of the association’s effort to grow the workforce of the future. It provides a career pathway for skilled, but non-certificated persons, to serve the aviation maintenance community. Help the association in this effort by responding to this month’s “quick question.”
Note: The question is displayed in its own, embedded window. If the “Submit” button is not visible on the screen, you must scroll within the survey window in order to submit your response.
If the embedded survey does not appear/load, open the survey independently by visiting: https://www.surveymonkey.com/r/qq-repairmen.
Click here to see what questions have been asked and answered…and keep a lookout for more.
For more information about this or any other question, contact Brett Levanto (email@example.com).
A Member Asked…
Q: I’m am trying to get technicians to stop using “in accordance with” (I/A/W) when completing a maintenance record entry. From a regulatory standpoint what is the main issue for not using I/A/W? I want to give the workforce a good reason to stop other than, “Because I said so.”
A: The bottom-line reason is that IAW is not required nor expected by the regulations. Section 43.9, the maintenance record rule, requires a reference to data acceptable to the administrator, usually that is a reference to the applicable maintenance manual. One should always know and follow the regulations, not “I think” or “I was told” or “we have always done it that way.”
The more compelling reason from an individual technician’s point of view is that the job is not always done exactly as stated (in accordance with) in a maintenance manual or service bulletin. Those instructions are just ONE way, not always the only or best way to accomplish a task or step. If you asked any experience technician whether that maintenance manual had every single step needed to do the job right, the answer would be no – the next question is why do you state that it was done in accordance with something that you didn’t or couldn’t follow?
If they have to fumble around to answer that simple question, it can equate to “falsifying a record” when asked by an aviation safety inspector or customer in a bad mood or who doesn’t know the industry or what actually has to be done. The personal exposure to accusations of either bad maintenance or falsification may be the light switch that brightens the dull bulbs who wish to use IAW when in fact, their own knowledge and other methods, techniques and practices have to be used to get the job done right.
Hope that helps—if not, I would be happy to do the cross-examination of someone that wants to use IAW. Six months after they completed the work, I would ask them if they accomplished every single step and line in the manual referenced—I will bet dollars to donuts that the answer would be “I don’t know” to most of the steps, particularly the ones that may not even apply since an inspection allowed the person to skip half the steps or go to another portion of the manual entirely.
Note: In lieu of “I/A/W”, ARSA suggests using “REF” as in “reference to data acceptable to the administrator” as described in § 43.9. This practice avoids the complications described in this response.
Immediately after the distribution of this hotline, a reader demonstrated great “attention to detail” by contacting ARSA to describe his own alternative to “I/A/W.” Considering his submission, the association recognized the value in providing an alternative along with its explanation of why to avoid “I/A/W.”
Member questions should be submitted through the inquiry system run through ARSA’s new online member portal. Members can use their portal access to submit inquiries by logging in through arsa.member365.com/sharingnetwork.
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 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, contact Vice President of Operations 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.
Since its inception, ARSA has worked to ensure that basic safety information (i.e., Instructions for Continued Airworthiness [ICA], including component maintenance manuals [CMM]) is made available at a fair and reasonable price to operators, maintenance providers, and any other person required by 14 CFR to comply with those instructions. ICA Issue Page
On June 23, 2016, citizens of the United Kingdom voted to withdraw from the European Union in a national referendum. As the process of making that withdrawal happen drags on. This page is provided as a resource for the aviation maintenance community regarding the transition. Brexit Resource Page (Updated)
Every year, more people are flying. The expansion of the global middle class and improvements in technology have opened aviation markets – for passengers and cargo – to a broader public than ever before. As the the flying public gets larger, more men and women are desperately needed to keep the world safely in flight.
See what ARSA has asked and what’s been answered and participate in the conversation about what’s going on in the aviation maintenance world.
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.
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.
© 2019 Aeronautical Repair Station Association