2020 – Edition 8 – September 4

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.

Taking Lead
Anti-Viral Measures
ARSA Works
Legal Brief
ARSA on the Hill
Training
Membership
Resources
Industry Calendar

Taking Lead

How ARSA Works

By Brett Levanto, Vice President of Operations

In my first few months with ARSA in 2014, I helped Executive Director Sarah MacLeod put together a post for ARSA.org called “How We Stand.” The piece began with some feedback Sarah received after giving a training session. It was from a long time FAA inspector who admitted that his opinion of her – and her association – had evolved:

It’s funny that I used to think that you just…took pleasure in slamming the FAA. That opinion changed [after attending your training]. Now I know that you take pride in slamming the FAA, but only when [it] need[s] slamming or need[s] to be challenged, which of course is quite often. But as a result of your work the giant bureaucratic organization is forced to do the right thing, and this always yields support to repair stations as well as maintenance airmen. I applaud you and the staff of ARSA for the great work you do.

That quote – followed in the piece by a then-current example of the association’s persistence – helped birth a term that hotline readers have seen countless times since: ARSA Works.

Every month brings new confirmation the association has never stopped working. In ways big and small, from years-long efforts to quick clarifications, the team turns individual frustrations and into industry-wide relief.

In August, Sarah, Marshall Filler and the ARSA Board of Directors delivered a unique demonstration of how ARSA finds every way it can to stand up for its members. As you can read in this month’s ARSA Works section and explore in depth in the Legal Brief, the association has enlisted the pro bono efforts of its management firm – Obadal, Filler, MacLeod & Klein, P.L.C. – intervene to represent the interests of its part 121, 135 and 145 applicant and certificate-holding members who seek to obtain repairman certificates for qualified individuals.

That motion included a clear statement of ARSA’s representation of the industry’s interests: “For the last 35 years, [ARSA] has represented the worldwide civil aviation maintenance industry – from its global corporations to the small, independent businesses before international governments and their agencies.”

The specifics of the cases are well covered in this edition and you will be reading more about them in the coming months. As you do, I hope you will keep that statement in mind and remember the point made by that “evolved” inspector after Sarah’s 2014 training: ARSA works to get entrenched bureaucracies to do the right thing for the good of aviation certificate holders and the general public.

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Anti-Viral Measures

EASA Releases Virtual Classroom Guidance

To keep tabs on all of ARSA’s work related to the current pandemic, visit arsa.org/anti-viral-measures.

On Aug. 18, EASA released guidance for allowing virtual classroom instruction and distance learning. The agency document is part of its Return to Normal Operations (RNO) work stream 1. Developed with input from Aircrew, Air Operations, ATCO, Continuing Airworthiness and Cabin Crew stakeholders, the guidelines provides general principles for all EASA approval holders overseeing knowledge and training requirements.

The guidelines cover basic principles and related requirements for distance learning, virtual classroom instruction and training feedback. To review the complete document, click here.

International Aviation Policy Resources for Pandemic Response

Note: ARSA maintains the following links to COVID-19 information pages maintained by each of the civil aviation authorities below. To jump directly to updates from the FAA, EASA, the UK CAA, TCCA, ANAC Brazil and CASA, click the links in the headings below.

To provide ARSA with additional international resources, links or updates, contact Brett Levanto.

ICAO Information Portal
FAA
EASA
UK
TCCA
Brazil
Australia

TSA Addresses Security During Pandemic

To keep tabs on all of ARSA’s work related to the current pandemic, visit arsa.org/anti-viral-measures.

The Transportation Security Administration’s (TSA) Aviation Security Advisory Committee (ASAC) has released a white paper on the impact of the current global health emergency on the aviation insider risk landscape.

The paper, entitled “COVID-19-Related Aviation Insider Risk Considerations,” was developed in light of the massive disruptions to the aviation sector as a result of the pandemic. Of particular concern are potential insider risks created by pressure from mental, financial and other stressors. The report, which was prepared by ASAC’s Insider Threat Subcommittee, examines how the pandemic crisis may exacerbate the insider threat as well as ways to mitigate risk. Topics include:

• Leadership and Human Factors
• Threat Detection, Assessment and Response
• Aviation Worker Screening and Access Control
• Information Sharing

The document’s contents are not intended as formal recommendations or requirements, but rather as a starting point to evaluate security in light of coronavirus. To read the full white paper, click here.

ASAC was established in 1989 after the bombing of Pan Am flight 103. The panel 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.  ARSA Executive Vice President Christian A. Klein is the aviation maintenance industry’s ASAC representative.

For more ARSA resources related to aviation security and the TSA, visit arsa.org/security.

Repair Station Security Resources
Fact Sheet	Compliance Checklist
Online Training

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ARSA Works

Enough is Enough for Repairman Denials

On Aug. 27, ARSA took the unusual step of requesting the law firm of Obadal, Filler, MacLeod & Klein, P.L.C. (OFM&K) file a motion for leave to intervene in two cases before the National Transportation Safety Board. The association requested the law firm represent the interests of its part 121, 135 and 145 applicant and certificate-holding members who seek to obtain repairman certificates for qualified individuals.

The matters before the Board involve a repair station making recommendations supporting repairmen certificates for supervisors with approval for return to service duties. The FAA denied the recommendations.

“The denials were not based upon whether the individuals were qualified to perform the work appropriate to the job of supervisor set forth in the rules governing repair stations,” said ARSA Executive Director Sarah MacLeod, who is also managing member of OFM&K. “Nor were the denials based upon the individuals lacking the practical experience required. The FAA’s answer to the repairmen appellants was that an outdated advisory circular and equally stale internal guidance did not ‘allow’ such a rating. Ironically, the internal guidance upon which the FAA relies plainly states: Repairmen do not have a rating other than ‘Repairman.’”

The association has unsuccessfully sought changes to align the advisory circular and internal guidance with the regulations since the repair station rules changed in early 2000. When it became aware of the repairmen appealing their denials, it took the rare opportunity to seek judicial resolution of the long-standing mismatch.

“[Air agency and air carrier certificate holders] are required to ensure an individual holds the proper qualifications to be assigned certain jobs and/or duties,” ARSA’s motion said, explaining the connection between the specific cases and the broad aviation industry’s interest. The submission is the association’s most-recent action in a long-standing effort to correct an unsupported contention by the FAA that a repairman certificate is an unfit substitute for an individually held airframe and/or powerplant mechanic certificate. Correcting this governmental bias will protect rights of repair stations to manage personnel according to the plain language of the aviation safety rules.

To read the complete motion, click here.

Update: See how the story continues by visiting arsa.org/repairmen.

FAA Considering ARSA-submitted Repairman Task

On Aug. 25, ARSA received the FAA’s official initial response to the association’s draft repairman certificate tasking for the Aviation Rulemaking Advisory Committee (ARAC). The agency’s letter, delivered 494 days after the task was originally submitted for consideration, merely confirms the draft was reviewed and promises to “retain it for full consideration as plans unfold to structure and establish the task for ARAC.”

The 2018 FAA reauthorization law included a provision directing the administrator to task ARAC to recommend policy changes necessary to make repairman certificates portable from one employing certificate holder to another. ARSA proposed the ARAC repairman language in the FAA bill due to concerns that the current rules undermine workforce mobility, create inefficiency for certificate holders, employers and the FAA and fail to recognize the broad range of skills represented in the maintenance industry’s technical workforce. On April 19, 2019, the association followed through on the effort by delivering draft tasking language to Acting Administrator Dan Elwell.

To read all 145 words of the complete response, click here.

To learn more about ARSA’s work on repairman certificate issues, including the initial submission of the task in April 2019, click here.

ARSA Continues Maintenance Scholarship

On Aug. 19, ARSA announced the availability of its 2020 aviation maintenance technician student scholarship through Choose Aerospace.  The association has long supported the $1,000 award, which is available to current students and can be used to support tuition, fees, books, equipment or other costs associated with their aerospace education.

Overall, Choose Aerospace and its partners will provide $25,000 worth of scholarships, textbooks, training systems and testing fee credits to educators and future airmen.  ARSA is a steering committee member of the organization, which is a partnership of aviation stakeholders committed to growing a diverse, qualified technical workforce. For more information about scholarships, including both application information and donor opportunities, visit www.chooseaerospace.org/scholarship.

In addition to ARSA, donors include:

AAR
Aircraft Mechanics Fraternal Organization
Aircraft Technical Book Company
Association for Women in Aviation Maintenance
Aviation Supply and Academics
Aviation Technical Services
Aviation Technician Education Council
AVOTEK
CertTEC
Envoy Air
Nida Corporation
Piedmont Airlines
PSA Airlines
United Airlines

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.

To view the list, click here.

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Legal Brief

Editor’s note: This material is provided as a service to association members for educational and informational purposes only. It does not constitute legal or professional advice and is not privileged or confidential.

Taking Leave

By Sarah MacLeod, Executive Director

In August, I delivered a rare opportunity to ARSA’s Board of Directors: Use the pro bono efforts of ARSA’s management firm – Obadal, Filler, MacLeod & Klein, P.L.C. (OFM&K) – to intervene before the National Transportation Safety Board (NTSB) in the appeals of multiple repairman certificate denials.

The problem started fifteen years ago when the part 145 rule changed but the guidance material for issuance of repairmen certificates required by part 121, 135 and 145 certificate holders remained affixed to the old standards.

After numerous attempts by the association to change the guidance material, the issue came to a head when a part 145 repair station member recommended three qualified individuals to receive “supervisor” repairmen certificates with approval-for-return-to-service authorization. Those certificates were denied because “FAA guidance” does not allow such a rating, even though internal guidance plainly states: “Repairmen do not have a rating other than ‘Repairman.’”

When the part 145 member queried the association on the proper regulations to cite when requesting a repairman certificate for qualified individuals, the draft letter from the association’s model forms was provided. When the agency’s denial was issued, the member was given information on how the applicants could appeal the action, which the employer and applicants bravely followed.

Repair stations and the individuals they recommend as repairmen applicants do not have to be qualified to fully understand the legal procedures, so intervention by the association was offered and ARSA’s volunteer leaders enthusiastically supported that step.

On Aug. 27, the firm that also manages ARSA filled a motion for leave to intervene; if the motion is granted, the next step is to submit further motions that should bring the matter to a close quickly.

The facts do not seem to be in dispute—the applicants’ recommendation by its employer set forth the required information–

• The job is supervisor.
• The job and the qualified individual are needed under 14 CFR part 145.
• The qualified individual is being recommended by that certificate holder.
• The individuals are qualified, i.e., have the skills and knowledge, to perform the “job” for which they are employed.

The result of any legal wrangling should be that NTSB will remand (i.e., send back) the original denials with directives to issue the certificates and to the FAA to align its guidance with the rules! (There goes my optimism.) If that doesn’t happen, there are always appeals!

Reviewing the motion may be a useful exercise; it covers the issues succinctly and lays out how ARSA Works and it is a quick read.

MOTION FOR LEAVE TO INTERVENE

Pursuant to 49 C.F.R. § 821.9(a) of the National Transportation Safety Board’s (NTSB’s) Rules of Practice, the Aeronautical Repair Station Association (ARSA) files this Motion for Leave to Intervene and become a party in the above-referenced matters.

In support of its motion, ARSA states:

It represents the interests of 14 C.F.R.^[1] part 119 and 145 certificate holders and applicants.

The interests of those entities are intrinsically linked to the requirements for, and the recommendation for and use of repairmen certificates.

ARSA’s interests are not adequately represented by the pro se individuals that appealed the denial of their repairmen certificates.

The granting of this Motion for Leave to Intervene will not unduly broaden, delay or impede the proceedings.

(A) Interests Represented

For the last 35 years, the Aeronautical Repair Station Association (ARSA) has represented the worldwide civil aviation maintenance industry—from its global corporations to the small, independent businesses before international governments and their agencies. The membership includes persons and individuals that have applied for and/or hold air agency certificates under part 145, as well as air carrier certificates issued under part 119.

(B) Interests are Intrinsically Linked

The eligibility requirements for repairmen applicants are intrinsically tied to part 145^[2] air agencies and part 119 air carriers.^[3] These certificate holders are required to ensure an individual holds the proper qualifications to be assigned certain jobs and/or duties. In addition to technical skills and knowledge, these specific jobs and duties require the individual to hold an appropriate certificate issued under part 65, subpart D or E. The air agency or air carrier and individual may choose to meet those requirements by the certificate holder recommending the qualified individual. Properly recommended individuals become immediately eligible to apply for and be issued a repairman certificate under part 65, subpart E.

Since the petitioners would not qualify to apply for the repairmen certificates without the recommendation of the part 145 employer,^[4] the regulations provide ARSA with an abiding and legitimate interest in the matters before the Board.

(C) ARSA’s Interests Not Adequately Represented by Petitioners

The repairmen applicants that petitioned the Board to review the Federal Aviation Administration’s denial of the requested certificates are highly competent and fully qualified individuals in the required technical skills and regulatory compliance matters for the position they hold for the air agency employer.

These individuals are not experts in or even familiar with the legal proceedings into which they have entered. ARSA submits that its knowledge of the regulations at issue and the legal proceedings are not adequately represented by the pro se petitioners.

(D) Granting the Motion Will not Expand or Impede the Proceedings

By granting this motion, the regulations that ensure the repairmen applicants were properly qualified to be issued the certificates will not be broadened, nor will the facts that must be reviewed.

ARSA submits that its knowledge of the pertinent regulations, guidance and legal proceedings will ensure that the proceedings are not impeded; rather, granting this motion will ensure that the appeals fully consider the appropriate roles of regulations and guidance, and which takes precedence in the event of a conflict.

Respectfully submitted,
Marshall S. Filler
Counsel for the Aeronautical Repair Station Association

[1] All citations are to Title 14 Code of Federal Regulations unless otherwise noted.
[2] See, 14 C.F.R. §§ 145.153, 145.157 and 145.159.
[3] See, 14 C.F.R. §§ 121.378 and 121.709; see, also, 14 C.F.R. §§ 135.435 and 135.443.
[4] See, 14 C.F.R. § 65.101(a)(4).

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ARSA on the Hill

Your Election Opportunity

By Christian A. Klein, Executive Vice President

The past two years have been the most successful in the history of ARSA’s legislative program.

Working together, the association and its members shaped the massive 2018 FAA reauthorization law, creating a new multimillion-dollar program to support maintenance technician workforce development.

We (at least so far) have prevented the enactment of H.R. 5119, the anti-repair station bill that would undermine global regulatory cooperation on maintenance issues.

Most recently, we ensured the CARES Act provided billions of dollars in relief for the maintenance industry.

Much of this success is attributable to the fact that ARSA and a handful of its members have cultivated a small cadre of allies on Capitol Hill who understand how repair stations impact the economies of their states and districts. But long-term success depends on expanding the number of lawmakers who understand our industry’s importance. There’s no better time to do that than during an election year. Here are some things you can do now to ensure we’re positioned to be as influential in the next Congress as we have been in this one.

Vote!

Voting is the most basic way to affect the workings of government. If you think of politics as a game of chess, voting is your opportunity to decide what pieces are on the board. This year not only is the White House up for grabs, but so is every House seat and one-third of the Senate.

Voting means more than showing up on election day; it takes preparation and planning. Specifically, you have to be registered and you have to know where to show up. The internet has resources to help you do both. One of the best places to start is on the U.S. Election Assistance Commission website, which provides links to voter registration information for each state (including registration deadlines), as well dates for the primary elections in which each party’s candidates are chosen. From that website you can jump to your states’ election department website, where you’ll be able register to vote (if your state allows online registration) and find information about where to cast your ballot.

Educate Yourself

Now that you know how and where to vote, the next step is to decide which way to cast your ballot. To identify the congressional candidates for your state and district, go to Ballotpedia.org. If you don’t already know which congressional district you’re in, go to Govtrack.us and enter your address.

Once you have the candidates’ names, you can easily find their websites using Google or another search engine. If you’re researching an incumbent member of Congress, go to their congressional website and then to the press release or media page to get a sense of their priorities. Most campaign websites will also have a page describing the candidate’s positions on issues.

Your decision about how to cast your ballot will likely be influenced by a number of factors. The candidates’ political party affiliation may be one, but party label doesn’t tell the whole story. Consider other things like character, temperament, experience, values and their track-record (if they’ve held public office before). You may be a lifelong Republican, but it may turn out that your Democratic representative or senator is one of our closest allies on workforce development issues. Alternatively, you may be a Democrat, but the Republican incumbent in your state or district may be working with us on regulatory issues.

Another consideration is who else is supporting or opposing the candidates. For example, if the candidate has received significant support from labor groups, he or she is more likely to side with unions against contract maintenance.

Engage!

Where the candidate stands on the issues that matter most to your company’s success should also affect your vote. But many of the issues that impact the maintenance industry are somewhat esoteric and candidates’ positions may not be spelled out on their websites. Often getting a sense of whether a candidate will be “with us” or “against us” on key issues requires a bit more effort and research.

The good news is that ARSA can help. Think of us as your onramp to engagement. I’m always happy to speak with members about their candidates. Often, I’ll be able to provide a sense of whether your incumbent senator or representative stands and the likelihood that he or she will be an ally in the future.

ARSA can also help facilitate a direct conversation between you and the candidate. While the pandemic has made it harder to meet in person, it’s made it easier to connect electronically. With candidates spending less time traveling from place to place, they have more time for conference calls and online meetings (which the association can help arrange).

Don’t keep what you learn to yourself. Share the information with your employees and colleagues (both within your company and at others in your area). As a business leader, you’re a trusted resource. Leverage that fact and help shape the way the people you interact with think about the candidates.

One of the best ways to engage and get a candidate’s attention is to support their campaign, whether financially or by volunteering. You’re not buying their support, but you will be more likely to get access and an opportunity to make your case in person. Be mindful of federal election laws. Remember that direct contributions to candidates must be from your personal (i.e., not corporate money) and there are other rules. More information is available on the Federal Election Commission’s website.

ARSA PAC

And while we’re on the topic of campaign contributions, don’t forget ARSA PAC. It’s a special account funded entirely by personal contributions from maintenance industry leaders that we use to help elect candidates who share our positions and philosophy about government. ARSA PAC allows the maintenance industry to speak with a single voice in the political process.

Unfortunately, federal law prohibits us from asking for your support in article like this (we need your permission to ask for a contribution). But you can learn more about the PAC and give us that consent on the ARSA website. And if there’s a candidate you want us to consider supporting, reach out.

You are the backbone of ARSA’s legislative program. Our success depends not just on your engagement in the lead up to the election but also on your participation in events like ARSA’s Annual Legislative Day in March and your response to our requests to communicate with Congress and participate in member surveys.

If you’ve been active for ARSA, thank you. If not, just think how much more successful we’ll all be if you are.

Don’t know where to start? Just email me at christian.klein@arsa.org.

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Training

Part 65 – Getting a Repairman’s Certificate

This session reviews the requirements of 14 CFR part 65 subpart E, which concerns aviation repairmen. It presents the language of part 65 in the context of parts 121, 135 and 145 as well as agency guidance regarding the management of repairman applications. Throughout, the session connects and compares the repairman’s requirements to those of the mechanic’s certificate issued under part 65.

Instructors: Sarah MacLeod & Brett Levanto

Click here to register and get access for 90 days.

This is the third session on part 65 the association has made available (see the other two below). Want all three? Click here to purchase together and save.

Other Sessions on Part 65 (Click title to see more)...

Registration for an ARSA-provided training session includes:

• Unlimited access for 90 days to the recording.
• 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.

What training do you need? Contact ARSA to let the association know and help get it developed.

Part 145 – Friends in Certificated Places

This session provides an overview of business and aviation safety requirements associated with the personnel requirements of 14 CFR part 145.

Instructor: Sarah MacLeod

Click here to register and get access for 90 days.

Note: The slides included in this session’s materials PDF have been corrected to update the description of repairman certificate eligibility on slides 18 and 20. Please ensure you are accessing the most recent version when utilizing these materials.

Other Sessions on Part 145...

Registration for an ARSA-provided training session includes:

• Unlimited access for 90 days to the recording (registrants may contact ARSA directly with questions or comments).
• A copy of the presentation and all reference material with links to relevant resources and citations.
• Upon completion of the class as well as any test material, a completion certificate.

The association’s training program is provided through Obadal, Filler, MacLeod & Klein, P.L.C., the firm that manages ARSA. To go directly to OFM&K’s online training portal, visit PotomacLaw.inreachce.com. To learn more about the association’s training program and see course availability, visit arsa.org/training.

Regulatory Compliance Training

Test your knowledge of 14 CFR Part 65 – Airmen Other than Flight Crewmembers [Complete].

Click here to download the training sheet.

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Membership

Overhauling ARSA’s Membership Procedures

For much of 2020, ARSA’s team has been overhauling its procedures for managing the “life” of each association member organization. In addition to updating communications scripts, contact record requirements and finance processing options, ARSA is changing its membership database. This means that as of the hotline’s publication, the ARSA online portal is now closed.

For the most part, the change will require little of association members – many will not even notice – but any interested contacts should note the following key points:

(1) Member contacts will no longer need to access a members-only portal in order to access resources or process payments. ARSA is closing the member portal and ensuring all needed information is available through arsa.org or direct contact with team members.

(2) Invoicing and membership renewal reminders will be delivered via email from arsa@arsa.org, beginning 90 days before the member company’s renewal date.

(3) Member inquiries and questions will now be submitted via arsa.org/contact (no login required).

Stay tuned for further updates. If you need assistance, particularly with open invoice payments, during the transition period, please contact ARSA.

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.”

In August 2020, the association’s management firm sought to intervene before the NTSB to represent the interests of its part 121, 135 and 145 applicant and certificate-holding members who seek to obtain repairman certificates for qualified individuals. Those certificates were denied because “FAA guidance” does not allow such a rating, even though internal guidance plainly states: “Repairmen do not have a rating other than ‘Repairman.’”

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 (brett.levanto@arsa.org).

To learn more about ARSA’s work on repairman certificates, click here.

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 August:

New Members

Pearl River Community College, EDU

Renewing Members

Aero-Mark MRO, LLC-dba Certified Aviation Services, R02, 2015
Aerotron AirPower, Inc. dba Fokker Aerotron, R04, 1990
Aircraft Lighting International, R01, 2018
Aircraft Systems Division of Com-Jet Corp, R03, 2011
Airframe Components by Williams, Inc., R02, 2003
Arista Aviation Services, LLC, R04, 2018
Aviation Repair Solutions, Inc., R02, 2006
C J Aviation, Inc., R02, 2017
CorpAir Supply Company, Inc. dba AVMATS, R02, 2001
Cox Airparts, LLC, R01, 2012
CrossPoint Testing and Inspection, R01, 2019
Eagle Creek Aviation Services, R04, 2016
E.U.A. Air Support, Inc., R01, 2003
F&E Aircraft Maintenance (Miami) LLC dba FEAM, R06, 2012
Flight Deck Specialists, Inc., R01, 2002
General MRO Aerospace, Inc., R03, 1989
Gulfstream Aerospace Corporation, Corp, 1999
HEICO Aerospace Corporation, Corp, 1992
Jordan Propeller Service, Inc., R02, 2002
Marvel-Schebler Aircraft Carburetors, LLC, R02, 2011
Millennium International, R02, 2013
National Flight Services, Inc., R03, 1991
NFF Avionics Services, Inc., R01, 2010
Pacific Turbine Brisbane, R03, 2018
Paz Aviation, Inc., R02, 2016
Regional Avionics Repair, LLC, R02, 2006
S & T Aircraft Accessories, Inc., R02, 2003
Tech-Aire Instruments, Inc., R01, 2012
Unicorp Systems, Inc., R03, 2003
Unipak Aviation, LLC, R02, 2003

A Member Asked…

Q: My question is in regards to 14 CFR part 65, specifically § 65.101(a)(5) that indicates that the individual applying for a repairman certificate must have at least 18 months of practical experience in the procedures, practices, inspection methods, materials, tools, machine tools, and equipment generally used in the maintenance duties of the specific job for which the person is to be employed and certificated.

Let’s say I would like to be an inspector. Is it safe to say that I must have 18 months of practical experience in the procedures, practices, inspection methods, materials, tools, machine tools, and equipment generally used by inspectors? Or am I interpreting the eligibility requirements incorrectly?

A: Let’s get you on the right slalom course, then we can get you through the correct gates in the right order:

You do not need a repairman certificate to do inspections under the repair station certificate, the individual assigned those duties, responsibilities and authorities by the repair station needs to be qualified under section 145.155, which includes being:

• Thoroughly familiar with the applicable regulations in this chapter and with the inspection methods, techniques, practices, aids, equipment, and tools used to determine the airworthiness of the article on which maintenance, preventive maintenance, or alterations are being performed.
• Proficient in using the various types of inspection equipment and visual inspection aids appropriate for the article being inspected.
• Able to understand, read, and write English.

If the job position the repair station assigned includes the duties, responsibilities and authority to either supervise (§ 145.157) or approve work for return to service (§ 145.153), one of the qualifications for persons required to direct maintenance and/or to oversee persons unfamiliar with their tasks and/or to approve work for return to service for the repair station is to hold an appropriate part 65 certificate, that is either a repairman or mechanic certificate.

When a repair station recommends an individual for a repairman certificate, the air agency certificate holder must ensure the person is qualified under § 65.101. That section, as you note, requires the employer to ascertain (usually through the assessment made under the Training Program Manual and reference to the duties, responsibilities and authorities set forth in the RSQM for the position) whether the individual is:

• Specially qualified to perform maintenance on aircraft or components thereof, appropriate to the job for which he is employed.
• Employed for a specific job requiring those special qualifications.

After which the employer completes the Employment Summary (since inspectors, supervisors and persons authorized to approve work for return to must be on the Repair Station Roster). Based upon that information, the employer recommends the employee for certification.

The evaluation by the employer should determine that the person has at least 18 months of practical experience in the procedures, practices, inspection methods, materials, tools, machine tools, and equipment generally used in the maintenance duties of the specific job. If the person does not, the employer would ensure the individual completed training through the FAA-approved Training Program Manual procedures since that should certainly qualify as formal training that is acceptable to the Administrator.

Member questions should be submitted directly to the association’s team via arsa.org/contact.

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

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 (brett.levanto@arsa.org).

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Resources

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.

Anti-Viral Measures

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

H.R. 5119 – Contract Maintenance Under Attack

Help combat a bill introduced in the U.S. Congress that would disrupt the global aviation industry.

Industry News Roundup

ARSA monitors media coverage on aviation maintenance to spread the word about the valuable role repair stations play globally by providing jobs and economic opportunities and in civic engagement. These are some of this month’s top stories highlighting the industry’s contributions. You can explore these stories through ARSA’s Dispatch news portal.

Industry Calendar

the hotline is the monthly publication of the Aeronautical Repair Station Association (ARSA), the not-for-profit international trade association for certificated repair stations. It is for the exclusive use of ARSA members and federal employees on the ARSA mailing list. For a membership application, please call 703.739.9543 or visit arsa.org/membership/join. For information about previous editions, submit a request through arsa.org/contact. This material is provided for educational and informational purposes only. It does not constitute legal, consulting, tax or any other type of professional advice. Law, regulations, guidance and government policies change frequently. While ARSA updates this material, we do not guarantee its accuracy. In addition, the application of this material to a particular situation is always dependent on the facts and circumstances involved. The use of this material is therefore at your own risk. All content in the hotline, except where indicated otherwise, is the property of ARSA. This content may not be reproduced, distributed or displayed, nor may derivatives or presentations be created from it in whole or in part, in any manner without the prior written consent of ARSA. ARSA grants its members a non-exclusive license to reproduce the content of the hotline. Employees of member organizations are the only parties authorized to receive a duplicate of the hotline. ARSA reserves all remaining rights and will use any means necessary to protect its intellectual property.

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