2020 – Edition 5 – June 5
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.
By Brett Levanto, Vice President of Operations
This winter, ARSA conducted its 2020 member survey to gather intelligence on issues facing the international aviation maintenance community and its economic outlook. The annual survey responses are used to improve the association’s services and the data supports advocacy on behalf of the global aviation industry.
The 2020 survey (which closed in early March) produced a clear “snapshot” of the maintenance community; unfortunately, this year’s results reflect a world long-since left behind.
ARSA is in daily contact with members around the world, so we have good insights about how the pandemic-related economic disruptions are affecting individual companies. However, we don’t have as comprehensive a picture of what’s happening industry wide.
That’s why we’re taking the unusual step of conducting a second member survey this year. The topics covered in our new survey are the same as those we asked this winter, with special questions related specifically to the pandemic. The data you provide about how your company has been affected and responded to the disruptions will help ARSA set priorities and advocate for the industry on Capitol Hill and with regulators.
The survey is open to anyone willing to invest ten minutes sharing information. It asks for a company name so we can cross-reference against responses to the February edition and to remove duplicate responses. Giving your time (especially if you responded the first time around) will provide ARSA with the data to enhance its knowledge and advocacy and provide tools for the survival and recovery of the aerospace industry.
Presidential Order Directs Agency Focus on Relief
To keep tabs on all of ARSA’s work related to the current pandemic, visit arsa.org/anti-viral-measures.
On May 19, President Trump signed Executive Order 13924, “Regulatory Relief to Support Economic Recovery.” Describing the impact of the current pandemic on American businesses and workers – closures, furloughs and layoffs resulting in 36 million new unemployment claims made over the previous eight weeks – the president directed the U.S. government to rejuvenate the nation’s “economy as well as its health.”
“Just as we continue to battle COVID–19 itself, so too must we now join together to overcome the effects the virus has had on our economy,” the executive order said. “To aid those efforts, agencies must continue to remove barriers to the greatest engine of economic prosperity the world has ever known: the innovation, initiative and drive of the American people.”
In general, EO 13924 directs U.S. federal agencies to:
- Address economic emergency by rescinding, modifying, waiving, or providing exemptions from regulations and other requirements.
- Identify and address regulatory standards that may inhibit economic recovery, particularly for small businesses.
- Provide compliance assistance before pursuing enforcement on issues stemming from efforts to manage economic distress.
- Maintain fairness in administrative enforcement, notably by being prompt, fair and bearing the burden of proof.
The principles of the executive order, though focused on emergency relief, are those ARSA would hold out as the foundation of good government oversight in any economic environment. As such, not only does the president’s direction offer the association and its members direction in seeking right action from the FAA and other oversight bodies during the current crisis, it should continue to do so through and beyond recovery.
To access Executive Order 13924, click here.
Re-live the FAA’s Virtual Aviation Safety Town Hall
To keep tabs on all of ARSA’s work related to the current pandemic, visit arsa.org/anti-viral-measures.
On May 14 at 2:00 p.m. EDT, the FAA successfully hosted a virtual “Aviation Safety Town Hall.” The two-hour session was kicked off by a recorded introduction by U.S. Secretary of Transportation Elaine Chao and included two separate panel discussions addressing safety crisis management (moderated by FAA Administrator Steve Dickson) and safety risk management through the current pandemic and into future operations (moderated by FAA Flight Standards Executive Director Rick Domingo.
A recording of the event is available via the FAA’s YouTube channel and is embedded below.
The FAA is also planning its next town hall, which will focus on general aviation. Details for that event will be released as they become available.
ARSA Urges Congress to Expand Repair Station Access to COVID-19 Relief
To keep tabs on all of ARSA’s work related to the current pandemic, visit arsa.org/anti-viral-measures.
As Congress gears up for the next round of coronavirus relief legislation, ARSA has weighed in with lawmakers on the maintenance industry’s priorities.
In a statement submitted to leaders of the Senate Commerce, Science and Transportation Committee in conjunction with a May 6 hearing on COVID-19’s impact on the aviation industry, ARSA said that despite assistance for the maintenance industry provided by the CARES Act business conditions for repair stations remain dire and thousands of jobs are at risk.
In making the case for additional relief for the maintenance industry, ARSA cited Oliver Wyman CAVOK (OW) projections that a dramatic drop in aircraft utilization will result in global maintenance, repair and overhaul (MRO) spending dropping by more than 50 percent in 2020, from a pre-pandemic forecasted level of $91.2 billion to $42.3 billion in the post-pandemic world. In the United States, demand is expected to fall 43 percent.
Repair station workers are highly trained, and it takes years to gain the necessary expertise to be an effective technician. ARSA and its members are concerned that if the industry loses a substantial portion of its workforce, repair stations will lack the capacity to support the nation’s civil and military fleets as aviation activity returns to normal levels. This, in turn, will pose long-term risks to both the efficiency of the aviation system and to national security.
ARSA is therefore urging Congress to:
- Improve repair station access to federal relief by directing the Small Business Administration (SBA) to immediately increase the small business size standard for all North American Industry Classification System (NAICS) codes applicable to aviation maintenance industry companies to at least 1,500 (and, ideally, to 3,000) employees. (The industry’s main small business size standard is currently $35 million in annual revenues, so PPP access is limited to companies that have 500 or fewer employees. Increasing the size standard would give more maintenance companies access to the PPP.)
- Temporarily exempt companies covered by those NAICS codes from SBA’s affiliation rules for purposes of accessing pandemic relief. (The affiliation rules have prevented even small companies with private equity backing from tapping into the PPP).
- Give air carrier maintenance contractors and subcontractors not located at airports access Air Carrier Worker Support (ACWS) resources. (The CARES Act requires most contractors and subcontractors to be located at airports to access ACWS assistance.)
- Provide significant additional resources for both the Paycheck Protection and ACWS programs.
- Refrain from imposing unnecessary restrictions and requirements on companies seeking access to relief.
- Create temporary tax incentives and grant programs to encourage business investment in worker training, equipment and facilities and air carrier investment in maintenance.
- Resolve the uncertainty surrounding the tax treatment of PPP loans. (The IRS has recently raised questions about the deductibility of business expenses paid using PPP funds.)
Another issue not raised in ARSA’s letter to the Commerce Committee is the problem of airlines not paying their bills for past work. It is bad optics from a public relations standpoint for the airlines to be taking taxpayer money and then stiffing small business vendors. Airlines would likely respond that the various programs are very specific and restrictive about how relief money may be used (i.e., payroll, benefits, etc.). ARSA is therefore exploring the possibility of amending the CARES Act to clarify that paying external vendors is an acceptable use of ACWS funds.
However, obtaining additional relief is likely to be a challenge in the current political environment. The negative publicity surrounding the PPP (large companies getting access, administrative issues, etc.) has clearly soured members of both parties on the PPP and members of Congress on both sides of the aisle seem disinclined to expand eligibility. Expanding access to the ACWS may get more traction as it does not make sense to discriminate against airline maintenance contractors and subcontractors based on location (on-airport vs. off-airport).
Another complicating factor is that whereas ARSA and other aviation trade associations were at the front of the line requesting assistance at the outset of the CARES Act debate, lawmakers are now receiving pleas for relief from businesses in every sector of the economy, making it less likely (though not impossible) that there will big bailout packages for specific industries.
ARSA welcomes suggestions for other near- and long-term relief proposals to help the maintenance industry weather what is likely to be a long period of uncertainty. To share your ideas or get more involved in the association’s advocacy, please contact ARSA Executive Vice President Christian Klein at firstname.lastname@example.org.
To read ARSA’s full statement, click here.
FAA Exemptions, Deviations and Other Virus Related Information
Note: ARSA has been posting guidance, exemptions and other resources to arsa.org/faa-strategy as they become available. Review below to see new content.
In response to requests from Airlines for America (A4A) and the National Air Transportation Association (NATA), the FAA has granted extensions to the following exemptions from training requirements of parts 121 and 135:
CAAC Updates “Simplified Approval Process for OEM’s MROs”
A member was kind enough to point out temporary guidance issued by the Civil Aviation Administration of China (CAAC) regarding its “Simplified Approval Process for OEM’s MROs.”
While, unfortunately, the process only applies to “OEM MROs,” it will help the owners and operators obtain services from approved maintenance organizations of other nations.
The document is accessible through a link on one of CAAC’s websites fsop.caac.gov.cn/indexEn.jsp.
ARSA ASAC Participation Connects Repair Stations to TSA
On May 19, ARSA Executive Vice President Christian A. Klein participated in a closed-door session of the Transportation Security Administration’s (TSA) Aviation Security Advisory Committee (ASAC). Klein serves as the maintenance industry’s representative to the committee, a position established in 2014 after the association lobbied for its inclusion in the Aviation Security Stakeholder Protection Act (H.R. 1204).
Established in 1989 after a terrorist attack on Pan Am flight 103, ASAC provides advice to the TSA administrator on aviation security matters, including the development, refinement and implementation of policies, programs, rulemaking and security directives pertaining to aviation security.
Participating in ASAC provides ARSA and its members with insights into TSA’s activities impacting aviation security and the opportunity to help shape policy. ASAC holds four quarterly meetings each year, all but one of which are closed to the public due to the sensitive nature of the issues discussed. Aside from providing ASAC members with insights about emerging security risks, the meetings provide a forum in which to discuss and debate policy recommendations developed by ASAC working groups. Among other issues, ASAC has been active in helping to shape TSA’s “Insider Threat Roadmap” released in May 2020.
ARSA resources regarding repair station security rules (including a fact sheet and compliance resources) are at arsa.org/security as well as in the “Training” section of this edition. Members with questions about TSA-related issues should contact the association.
Transatlantic Engagement Continues Remotely
On May 5, ARSA Executive Director Sarah MacLeod participated in a virtual meeting of EASA’s Engineering & Maintenance Technical Committee (EM.TEC). The session was held in lieu of the body’s originally scheduled gathering in Cologne, Germany.
The EM.TEC is one of several EASA stakeholder advisory bodies (similar to the FAA’s Aviation Rulemaking Advisory Committee) that meets twice yearly to discuss current issues primarily affecting the European maintenance industry, but also touching on international issues. Despite constraints on travel and physical proximity, the group was able to continue its work remotely (another example of the power – in period of crisis as well as normal operations – of the connectivity tools ARSA has been pressing the FAA to embrace since 2018).
The meeting was mainly to update members on several white papers and other matters that were being addressed outside the current crisis. It was mentioned several times that the international situation was bringing advancements that had positive ramifications for future use and collaboration between the public and the aviation safety agency.
The association will continue to engage with stakeholder groups and regulators regardless of policy or practical limitations on in-person meetings.
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.
Old Habits Die Hard – Revisiting EASA Acceptance of FAA Repair Data Under TIP Rev. 6
By Christian A. Klein, Executive Vice President
Constant improvement is the hallmark of the aviation sector. Unfortunately, even when a better or more efficient way of doings things comes along, old habits die hard. One example is the reluctance of some European operators to embrace opportunities associated with Revision 6 to the FAA-EASA Technical Implementation Procedures for Airworthiness and Environmental Certification (TIP Rev. 6), and its predecessors.
When EASA was first established in 2003, it required all major and minor repair designs to be approved by the agency for use on articles subject to its State of Registry (SOR) jurisdiction. EASA took this position even though several EASA Member States had previously entered into bilateral aviation safety agreements with the FAA that contained broader repair data reciprocity provisions. To maintain reciprocity, the FAA took a similar approach although it was more receptive to expanding mutual acceptance in this area. Shortly after EASA became official, ARSA met with its officials in Cologne, urging modification of this policy because it was not based on safety concerns and was costly, burdensome and impractical.
In September 2004, EASA agreed to automatically accept, on U.S. State of Design products and articles only, all FAA-approved and acceptable repairs designed by the type certificate holder and minor repairs designed by other entities IF they were included in a previous bilateral agreement between the FAA and an EASA Member State (i.e., prior to EASA’s formation in 2003).
As the authorities continued to build confidence in each other’s regulatory systems, the mutual acceptance of repair data was expanded to include major and minor repairs on all articles other than critical parts. If the parts were critical, EASA would only accept FAA-approved data if the repairs were designed by the type or supplemental type certificate holder.
TIP Rev. 6 eliminated the critical parts provision and today we have nearly 100 percent repair data reciprocity between the FAA and EASA. In theory, this eliminates the regulatory burden for U.S. repair stations and their European customers and gives those customers more choices for maintenance. However, differences between how the U.S. and European regulatory systems treat repair data has led to confusion on whether and when the FAA data are considered approved by EASA. The purpose of this article is help clear up that confusion. (Note that this article deals only with EASA acceptance of FAA data. Review TIP Rev. 6 for information about FAA’s parallel acceptance of EASA data.)
Before looking at the specific language of the TIP Rev. 6 regarding repair data reciprocity, it is important to understand some basic definitions. While the TIP includes a relatively detailed definition of the term “major repair”, “minor repair” is defined by exclusion. TIP Rev. 6 (Sec. 1.13.37) defines “major repair” to mean:
a repair that, if improperly done, might appreciably affect weight, balance, structural strength, performance, power plant operation, flight characteristics, or other qualities affecting airworthiness; or a repair that is not done according to accepted practices or cannot be done by elementary operation.
Sec. 1.13.40 defines “minor repair” simply as “a repair other than a major repair”.
With regard to EASA’s acceptance of FAA repair design data, sec. 220.127.116.11 of TIP Rev. 6 states that:
(a) EASA shall accept data used in support of major repairs regardless of the SoD of the product, part or article, if:
(1) EASA has certificated/validated the product or article;
(2) The FAA is the Authority of the SoD for the repair design data; and
(3) The FAA repair design data approval is substantiated via an FAA letter, FAA Form 8110-3, FAA Form 8100-9, FAA Form 337 or a signed cover page of a repair specification.
(b) EASA shall also accept data used in support of minor repairs when:
(1) EASA has certificated/validated the product or article;
(2) The FAA is the Authority of the SoD for the repair design data;
(3) The repair design data has been provided by the U.S. TC, STC, [Parts Manufacturer Approval (PMA)], or [Technical Standard Order Approval (TSOA)] holder; and
(4) For minor repairs from other than the U.S. TC, STC, PMA, or TSOA holder, the determination that data are acceptable (under 14 CFR part 43) has been made by a U.S. maintenance organization under the FAA’s authorized system.
Note: An EASA approved maintenance organization must use EASA Part 21 for the approval of repair data for use on an EU-registered aircraft, unless the data for a minor repair has been previously used to repair an N-registered aircraft.
(c) In these circumstances, repair design data are considered to be EASA-approved following its approval or acceptance under the FAA’s system. This process does not require application to EASA or compliance findings to the EASA certification basis.
When determining whether FAA major repair data is automatically acceptable to EASA, answer the following questions:
- Has EASA certificated or validated the product or article? Lists of EASA approved products are available at easa.europa.eu/document-library/product-certification/type-certificates/easa-product-lists for type certificates and www.easa.europa.eu/document-library/type-certificates/supplemental-type-certificates for supplemental type certificates. If the answer is yes…
- Is the FAA the authority of the SoD for the repair data? In other words, were the data developed under the auspices of FAA’s regulatory system? If yes…
- Have the data been substantiated through one of the following?
- A letter from the FAA
- FAA Form 8110-3
- FAA Form 8100-9
- FAA Form 337 or
- A signed cover page of a repair specification
If the answers to all the foregoing questions are yes, the FAA data are automatically accepted by EASA.
For minor repair data, ask yourself the following:
- Has EASA certificated/validated the product or article? (Use the links above to check.) If yes…
- Is the FAA the authority of the SoD for the repair data? In other words, was the data developed under the auspices of FAA’s regulatory system? If yes…
- Was the repair design data provided by the U.S. TC, STC, PMA or TSOA holder? If yes, the data is accepted by EASA. If no…
- Was the data determined to be acceptable under 14 CFR part 43 by a U.S. repair station pursuant to appropriate FAA procedures? If yes, the FAA data are automatically accepted by EASA without further showing.
Aviation regulations are complex and operating within multiple regulatory systems only adds to the difficulty. ARSA is proud of the work it has done (and continues to do) to identify opportunities – such as repair data acceptability – to make life easier for members and their customers. As ARSA does its part, the industry is left to understand the dispensations provided and to use them to improve efficiency.
ARSA on the Hill
By Christian A. Klein, Executive Vice President
While the last few weeks on Capitol Hill have been less frenzied than March and April (at least for aviation interests) it is still a busy time. As lawmakers debate whether and how to provide additional relief for pandemic-related economic disruptions, ARSA has been hard at work on the maintenance industry’s behalf.
Expanding Access for Repair Stations
The association is continuing its efforts to expand access to the various relief programs created by the Coronavirus, Aid, Relief and Economic Security (CARES) Act. While many maintenance companies have been able to tap into the Paycheck Protection (PPP) and Air Carrier Worker Support (ACWS) Programs, some companies have fallen through the cracks because of size, ownership structure and/or because they aren’t located on an airport. ARSA has proposed legislative language to address these concerns and is continuing to work with House and Senate offices to build support. An additional concern is the fact that almost two months after the CARES Act was signed into law, some companies are still waiting for ACWS grants and loans. ARSA is encouraging lawmakers to weigh in with the Treasury Department to encourage swifter action.
Protecting the Maintenance Workforce and Keeping Skills Sharp
Workforce is central theme of all our relief efforts. Through its work on the CARES Act and its implementation, ARSA has been trying to protect as many maintenance jobs as possible. Aside from concerns about the economic wellbeing of employees, association members have voiced concerns about losing talented technicians it has taken years to train and not having sufficient capacity when air travel returns to normal levels.
With that in mind, the association has been working with allies and leading member companies to include additional workforce development resources in any future relief bill. Specifically, we are proposing to double funding for this year and next for the technician recruitment and training grant program created by Sec. 625 of the 2018 FAA reauthorization law and to force the FAA to update its antiquated rules governing technician schools (14 CFR part 147). Taken together, those two proposals could help schools and companies work together to sharpen the skills of those already in the industry and train a new generation of technicians.
New Bill to Support At-Risk Aviation Maintenance, Manufacturing Jobs
ARSA is also supporting new legislation proposed by Sens. Jerry Moran (R-Kan.) and Mark Warner (D-Va.) that would provide additional relief to aviation manufacturers and repair stations. S. 3705 would establish a public-private partnership program to preserve aviation manufacturing and maintenance jobs. Under the temporary initiative the federal government would provide up to 50 percent of total compensation for at-risk employee groups at manufacturing and maintenance companies as long as a company commits to continuing their employment. A primary objective of the bill is to ensure experienced workers will be safeguarded and available to contribute as the industry recovers.
HEROES Act with Anti-Foreign Repair Station Provision is DOA in Senate
The House of Representatives took the first step towards the next round of comprehensive relief legislation this month when it passed the HEROES Act (H.R. 6800). While ARSA believes additional relief is necessary, concerning provisions in the HEROES Act reflect long-standing economic priorities of House Democrats unrelated to the coronavirus. A case in point is Sec. 190503 of the bill, which would retroactivity limit the ability of airlines that have received CARES Act relief from expanding use of repair stations outside the United States. Aside from setting a terrible precedent that Congress can and should impose retroactive terms on agreements between businesses and the federal government, the provision would also invite retaliation against the 1,400 U.S. repair stations that serve a global customer base. On May 29, ARSA delivered a letter opposing Sec. 190503 to Senate Leaders; click here to read it. Senate GOP leaders have said the HEROES Act is dead on arrival.
Divergent Priorities Increase Uncertainty
Rather than rushing to enact another trillion-dollar package, Republicans in the Senate have expressed their desire to proceed more slowly and deliberately to better understand the impact of the CARES Act and what additional relief is necessary. While Democrats have emphasized economic assistance to individuals and states, Republicans are focused on encouraging those currently receiving unemployment to get back into the workforce and creating protections from coronavirus-related lawsuits. ARSA has joined with the U.S. Chamber of Commerce in supporting legislation to protect businesses – particularly those deemed essential that have remained open during the pandemic – from frivolous lawsuits.
When and whether there will be another relief bill is still anyone’s guess, but ARSA will continue its work. To get involved in the association’s legislative activities, please contact me at email@example.com.
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.
ARSA Discounts Online Training During COVID-19 Response
The ARSA team continues to be heartened by the growing list of businesses and service providers offering additional benefits to the public as the world responds to the spread of COVID-19. Since some of the association’s members have indicated that personnel development and training will be paramount during the period of upcoming business uncertainty, the team has issued a 50 percent discount on all price levels for ARSA online training sessions.
This discount is valid for every individual session purchase and will apply automatically at checkout. Multiple sessions can be purchased at once and the entire “cart” amount will be discounted, but “bundles” of similar classes (denoted on individual class pages as “special offers”) will not be additionally discounted; this 50 percent reduction exceeds the savings of any bundle, so please independently select each course in which you are interested and then follow the appropriate steps to check out.
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 (firstname.lastname@example.org).
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.
What training do you need? Contact ARSA to let the association know and help get it developed.
FAA Extends ARSA Training IA Acceptability into 2023
In early 2020, the FAA informed ARSA of a 24-month extension to the expiration dates for each of the association’s online training sessions found acceptable for Inspection Authorization renewal credit under 14 CFR § 65.93. The original eight IA renewal sessions produced by ARSA will now remain acceptable until 2023:
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 14 other hours of training from its Human Factors series: arsa.org/human-factors-training.
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.
Repair Station Security
While ARSA represents maintenance industry interests before the TSA (see this month’s update in the “ARSA Works” section), the association provides a number of security-related resources for its members.
Repair Station Security Resources
|Fact Sheet||Compliance Checklist|
ARSA, ATEC Participate in Compliance Webinar Hosted by HAI (Recording Available)
On May 14 at 4:00 p.m. EDT, ARSA Executive Director Sarah MacLeod and VP of Operations Brett Levanto joined the Aviation Technician Education Council’s Crystal Maguire for a discussion hosted by Helicopter Association International. A recorded version of the session is now available.
HAI@Work Webinar – Maintenance & Training Compliance During A Global Pandemic
|Date & Time:||Recording Available On Demand|
|Description:||Join us this week as we discuss how maintenance and training personnel can continue operations regardless of limitations on personal engagement imposed by the current crisis. Our guests this week are Sarah MacLeod and Brett Levanto from the Aeronautical Repair Station Association (ARSA) and Crystal Maguire from the Aviation Technician Education Council (ATEC).|
Regulatory Compliance Training
Test your knowledge of 14 CFR § 1.1 – Definitions and Abbreviations [definition of “person”].
Industry Leaders Voice ARSA’s Value
In support of its ongoing membership recruitment and retention efforts, ARSA has released a new video featuring leading association members discussing the aspects of the association they consider most valuable.
The brief (90 second) video was produced by Hothouse Media using footage and interviews with industry leaders filmed during the 2020 ARSA Annual Conference. The video provides perspectives on all aspects of ARSA’s activities, including regulatory advocacy and compliance, congressional lobbying, training and industry workforce development support.
Featured in the video are:
- David Latimer, senior vice president of regulatory compliance at HAECO Americas
- Randall Darling, Jr., quality manager at Component Repair Technologies, Inc.
- Manny Palomo, compliance director at Continental Aircraft Support, Inc.
- Scott Gellerman, director of quality control at Lynden Air Cargo, LLC
- Scott Jacob, director of quality control at Columbia Helicopters, Inc.
- Brian Tyminski, CEO of Compressed Gas Systems
- George Jimenz, director of quality control at HEICO Aerospace Corporation
- Brett Levanto, vice president of operations, ARSA
To put the video to use, go to arsa.org/membership, where it can be found along with complementary information and resources for getting value out of the association. Share it with colleagues, friends and contacts at other organizations. Spreading the word about ARSA helps bolster its good work and could even save you money.
AMT Day 2020 – Still Celebrating Charlie
Charles Taylor, the Wright Brothers’ mechanic and father of aviation maintenance, was born on May 24, 1868. Now – 152 years later – we celebrate him with every safe arrival and continued commitment to good work (regardless of the state of the world).
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, 2020. While some companies known for big celebrations scaled back plans in light of social distancing requirements and other impacts of current social and health issues, anyone who observed the day in any way is encouraged to share 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.
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.
The Mechanician: A Brief History of Charles E. Taylor
Produced by the Mechanical Dragons, this short documentary reviews Charles Taylor’s life and his role in one of the world’s greatest engineering breakthroughs: the birth of heavier-than-air flight. Click here to open the video.
2019 MRO Network Podcast: ARSA’s Levanto Talks Celebrating AMTs Every Day
Asking Again – A New Survey for 2020
ARSA is conducting this survey to gather information about the impacts of pandemic-related economic disruptions on the maintenance industry. In addition to helping the association focus its resources, your responses will help support advocacy for repair stations. Some of the questions are the same as those included in ARSA’s 2020 Member Survey earlier this year, but many are related specifically to the pandemic.
Please complete this survey even if you completed the 2020 member survey.
The survey has 23 questions and should take between 10 and 15 minutes to complete. Responses are confidential and are reported only in an aggregate format. Open-ended responses will not be attributed to you. If you have any questions, please contact ARSA at email@example.com.
Note: The survey below is in an embedded window and you may need to scroll down within the window complete and submit all items.
If the embedded survey does not appear/load, open the survey independently by visiting: https://www.surveymonkey.com/r/ARSA-2020Impacts.
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:
Fargo Jet Center, R04
AeroRepair Corp., R03, 2012
A.O.G. Reaction, Inc., R02, 1993
Aviation Safety Products, R01, 2013
Eastern Airlines Technic Co., Ltd., R04, 2017
Precision Aircraft Services, R02, 2018
IAR Technical Services LLC, R03, 2017
L. J. Walch Co., Inc., R03, 1985
Metro Aviation, Inc., Assoc, 2003
NAASCO Northeast Corporation, R02, 2002
Pennsylvania State University, R01, 2016
QAI Aerospace, R02, 2012
Southwest Aerospace Technologies, R01, 2019
Spirit AeroSystems, Inc., R04, 2005
Toledo Jet Center, LLC, R03, 2010
Twin Manufacturing Co., dba TWIN MRO, R04, 1993
A Member Asked…
Q: We need a little help—
(1) A company-owned article is maintained by its repair station.
(2) The article is placed into company stock with an approval for return to service on an FAA Form 8130-3 (airworthiness release) and a teardown report describing the work performed, awaiting sale.
(3) The article is subsequently removed from stock and a sub-assembly is removed to support a customer-owned article. This removal changes the results of the final ATP.
(4) When a replacement for the sub-assembly becomes available it is replaced on the original article, which is subsequently tested (ATP).
(5) The article is returned to stock with a new 8130-3 and teardown report describing the work performed, awaiting sale.
This process could happen repeatedly on multiple articles or even the same article multiple times.
(1) Is the original airworthiness release (FAA 8130-3, item 2) still valid?
(2) If it is not valid, does it have value as part of the article’s history?
(3) Is it acceptable to issue the article with multiple approvals for return to service on FAA Form 8130-3s?
The reasons we ask is this recently happened, and we do not have details in the inventory management procedures for such situations. Before we develop them, we want to ensure we get the right regulatory basis.
A: The answer to all three questions is basically the same. Each action of maintenance requires a maintenance record – § 43.9(a).
Ironically, removal is not in the definition of maintenance (see, § 1.1), but replacement is considered such an action and would require a maintenance record. Section 43.9(a)(4) states that the signature certifies approval for return to service for the work performed. Thus, as long as the record’s description of work perform continue to be valid, the approval for return to service remains valid for that work scope.
For example, if the top assembly was “overhauled” and each item in it was appropriately checked, repaired or replaced and tested, the removal of the “sub-assembly” would presumably only “disturb”, or “invalidate, the limited areas necessary for the removal. The replacement and the test of the entire assembly would confirm that fact.
Generally, previous maintenance records continue to be valid, until the work is repeated or superseded. As long as the technical aspects of the process for obtaining replacement parts from inventory can be confirmed by the maintenance record’s description of work performed, and storage or handling guidelines are copesetic, the regulations are covered.
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.
For the use of its members and the larger aviation community, ARSA is maintaining this page as a resource for pandemic-related updates on policy initiatives and business needs. It is the association’s central point of communication on the topic
Help combat a bill introduced in the U.S. Congress that would disrupt the global aviation industry.
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.
|Farnborough Air Show Cancelled||7/20-24/2020||Farnborough, UK|
|MRO Americas||9/1/-3/2020||Dallas, TX|
|ATEC Annual Conference||9/13-16/2020||Fort Worth, TX|
|FlightGlobal Big Data Americas||9/29-30/2020||Seattle, WA|
|Business Aviation Convention & Exhibition (NBAA-BACE)||10/06-08/2020||Orlando, FL|
|MARPA Annual Conference||10/21-22/2020||Orlando, FL|
|MRO Europe||10/27-29/2020||Fira Barcelona Gran Via, Spain|
|MRO Middle East Summit & Expo||3/1-3/2021||Dubai, UAE|
|ARSA Annual Conference||3/9-12/2021||Washington, DC|
|HAI Heli-Expo||3/22-25/2021||New Orleans, LA|
|FAA Aviation Safety Infoshare||4/20-22/2021||St. Louis, MO|
|MRO Beer||6/2021||Istanbul, Turkey|
|RAA 45th Annual Convention||9/25-28/2021||Phoenix, AZ|
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.
© 2020 Aeronautical Repair Station Association