2021 – Edition 6 – July 2

the hotline 1984

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
Industry Calendar

Taking Lead

From the Heart

By Marshall S. Filler, Managing Director & General Counsel

Following a routine maintenance visit with a new doctor, and a referral to a cardiologist, I find myself scheduled for open heart surgery on July 8. My prognosis is excellent for the “routine major operation” (obviously a “routine major” assessment in the medical profession cannot be compared to a “major/minor” determination in the aviation business). In the meantime, I was cleared for a golf trip, bolstering my skills as ARSA’s resident golf advocate and my attitude for surgery and its recovery period.

In addition to improving my longevity, the surgery and its recovery requirements allows for a more definitive retirement strategy. Beginning this month, my two years of “part-tirement” will become full retirement from taking on private clients through the association’s management firm. I will continue to serve as ARSA’s managing director, general counsel, and board member, work to improve my golf game, spend time with grandchildren, and renew my enthusiasm for enjoying life. The increased blood flow should help!

Aiding the aviation community from the FAA Chief Counsel’s Office in 1973, to Capitol Hill, followed by private practice were rewarding experiences. My professional knowledge and understanding brought me to a leadership position in an association that supports the international maintenance industry. Remaining an ARSA team member allows the association to—

(1) Lead

ARSA brings together broad coalitions of industry groups and businesses to improve the international aviation community. Developing international agreements among the “big four” civil aviation authorities, investing in technical career development, refining regulatory standards, and improving global oversight will continue. The “little association that could” takes the lead on issues that others overlook, ignore or shy away from.

(2) Think

Critical thinking has become a catch phrase for the FAA; ARSA has always been an advocate of the practice. By investing in understanding the history and plain language of the regulations and business realities, the association serves its members and the industry by turning its knowledge into resources. To help bolster this knowledge, the association’s catch phrase is ASK ARSA FIRST! As the executive director continually asks, “Do you let the IRS do your taxes?”

(3) Stand

In facing both individual challenges and broad attacks on the industry (like congressional incursions into international business), ARSA will not give in to political pressure or appease those in power. When you do the same, I won’t say the association will be “behind you” but only because its job is to be out in front.

(4) Support

The association provides its members instant support through “Ask ARSA First”, however, more important to the entire industry are the regulatory compliance publications, career development and recruitment efforts, event coordination, legislative education and activism, and personal encouragement it offers companies and individuals.

While my professional role is changing, I am intrinsically linked to the association, which is managed by a law firm that bears my name. Sarah MacLeod, my life and law partner, Christian Klein, my other law partner, Brett Levanto and Kimberly Dimmick will always have the benefit of my counsel. In the continued evolution of the “Sarah Management System” under which the law firm and association operate, my professional and personal transition has been firmly and unmistakably planned and executed. Since she is not planning her retirement (yet), she will continue to ensure ARSA and its members are fully supported no matter who fills its executive roles.

While this transition is for my heart, my feelings for the international aviation industry, this association, its team, and members are straight from the heart.


Return to Top of Page

Anti-Viral Measures

Aviation Jobs Protection Program Applications Open

To keep tabs on all of ARSA’s work related to the pandemic, visit

On June 15, the U.S. Department of Transportation opened applications for the Aviation Manufacturing Jobs Protection (AMJP) Program. Submissions are due by 5:00 p.m. EDT on July 13.

Applications must be submitted online. For program information and application instructions, visit or the program website (click the DOT logo below). The agency has been regulatory communicating with stakeholders and posting updates to the AMJP website when key questions are asked or system improvements are made.

Note: ARSA will continue to provide relevant updates to throughout the application period and with follow up information as necessary.

ARSA encourages members to share experiences with the association via

Click the DOT Logo to go to the application process webpage.


SBA Pandemic Guidance Materials

To keep tabs on all of ARSA’s work related to the pandemic, visit

On June 24, the U.S. Small Business Administration Office of Advocacy hosted an online roundtable discussion to review new healthcare and general industry guidance for pandemic safety management.

After completion of the roundtable, the SBA shared presentation materials utilized during the meeting:

(1) Andrew Levinson’s presentation on the new OSHA COVID-19 Emergency Temporary Standard.
(2) Lee Ann Jillings presentation on the new OSHA COVID-19 guidance for General Industry.
(3) Federal Register notices regarding new funds for Susan Harwood grants for Workplace Safety and Health Training on Infectious Diseases, Including COVID–19 grants for non-profit organizations to conduct training for employers and workers on infectious diseases, including COVID–19 safety and health hazards in the workplace (2021-13267.pdf ( and (

Roundtable meetings are open to all interested persons, with the exception of the press, in order to facilitate an open and frank discussion about small business-related issues.   Agendas and presentations are available to all, including the press.  Anyone who would like to receive roundtable agendas or presentations, or be included in the regular distribution, should forward such requests to  The purpose of these roundtable meetings is to exchange opinions, facts, and information and to obtain the attendees’ individual views and opinions regarding small business concerns.  The meetings are not intended to communicate or achieve any consensus positions of the attendees.

Want to enlist the SBA’s help rectifying ICA issues?

Visit to read more about ARSA’s work and submit your own comment using the association’s toolkit.



Return to Top of Page

ARSA Works

Association Panel Covers Global Issues

On June 23,  ARSA Vice President of Operations Brett Levanto participated in a panel discussion during ILS Connect Virtual 2021. Levanto joined colleagues from the Aircraft Fleet Recycling Association, the Aviation Suppliers Association and the Modification and Replacement Parts Association to explore key issues related to aftermarket growth and pandemic recovery.

During introductions, session moderator Mary Wanke reinforced the value of association support. Wanke noted how each organization on the panel works together in support of a complex network of businesses and aviation stakeholders. Through direct support, industry advocacy and expertise, ARSA and its allies push for improvement across the global aviation community.

The session moved along quickly. Jason and Michele Dickstein shared information about MARPA and ASA’s work related to part availability and installation under Chinese rules. Brent Webb spoke about expected issues related to expansive fleet retirements. Levanto fielded a question about availability of maintenance data and ongoing efforts related to instructions for continued airworthiness.

The resources referenced by Levanto are all available across

(1) ICA Issue Page:
(2) Petition for Rulemaking related to § 145.109(d):
(3) SBA Ombudsman Comment Kit:
(4) IATA-CMFI Commercial Agreement:

Though the group’s 45-minutes elapsed before further discussion – the event system kept attendees moving briskly between sessions at exactly the appointed time – Levanto had also prepared for questions related to career and workforce development matters. As the aviation emerges from pandemic disruption, global markets will once again depend on availability of technical talent. Though the topic did not make it into the panel, interested parties should review the following resources:

(1) Information about aviation workforce grant programs:
(2) ARSA-supported efforts of the Youth Access to American Jobs in Aviation Task Force:
(3) General association efforts on career and workforce development:
(4) Career pathway references on ARSA’s public information portal:

Founded in 1979, ILS has continued to expand and innovate the Aerospace Aftermarket platform. Its platform can be used to find, analyze, buy and sell parts and repair services and can be integrated into existing supply chain management systems. For more information about the company or its products, visit

Session Information

Industry Associations Panel – ASA, ARSA, AFRA and MARPA
Michele Dickstein, ASA
Brett Levanto, ARSA
Brent Webb, AFRA
Jason Dickstein, MARPA
Mary Wanke, Aerontii (Moderator)

Click the image to go to the ILS website for more information.


Follow Up on Youth Task Force Meeting

On June 9, the FAA held the third public meeting of the Youth Access to American Jobs in Aviation Task Force. ARSA specifically represents repair stations on the body while also pressing the interests of designers, manufacturers, operators and the broader maintenance community.

The meeting included updates from each of the Task Force’s four subcommittees as well as special presentations from the FAA’s social media team, United Airline’s Aviate Program and the U.S. Air Force Office of Diversity and Inclusion.

Meeting Materials

To download the presentations and reference documents used during the meeting, click here.

Public Viewing

Recordings of the livestreamed meeting are available on the FAA’s YouTube channel, with separate videos for the morning (9:00 a.m. to 12:00 p.m. EDT) and afternoon (1:00 to 2:00 p.m. EDT) sessions.


Click the recording links to jump directly to that point of the meeting via YouTube.

Topic Recording Link
Trends Subcommittee Update Click here
Funding Subcommittee Update Click here
Awareness Building Subcommittee Update Click here
Expanded Pathways Subcommittee Update Click here
Task Force Open Discussion Click here
FAA Social Media Approach Click here
United Airlines Aviate Program/Academy Click here
U.S. Air Force Approach to Developing the Workforce Click here

For information about the meeting or the task force in general, review the content on or visit the committee page on the FAA website. ARSA encourages industry members to support the effort by sharing workforce development thoughts, questions, needs or lessons learned to


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.

 Return to Top of PageARSA-onlinetraining

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.

NTSB and FOIA Exemption 5

By Christian A. Klein, Executive Vice President

Last month’s “Legal Brief” discussed ways to protect information submitted to the government; this month we delve into access to information in government hands when submitted by a party to a National Transportation Safety Board (NTSB) investigation.

First, some context: The NTSB is an independent federal agency given the power to investigate all civil transportation accidents. NTSB investigations are to be “fact-finding proceedings” aimed at determining the probable cause(s) of accidents and make safety recommendations; the NTSB does not determine “rights or liabilities” and final agency reports cannot be admitted in civil actions.

The Investigator in Charge (IIC) of an NTSB investigation may designate an entity as a party if it “…can provide suitable technical personnel…to assist the investigation.” Entities that become parties may generally not release information obtained during an investigation, cannot use their party status to “prepare for litigation or pursue other self-interests” and may not be represented by anyone who represents claimants, insurers or who occupies a legal position.

Following a 2011 sightseeing helicopter accident in Hawaii, the tour operator and FAA became parties to the investigation. Because the helicopter and engine manufacturers were French companies, France’s Bureau of Enquiry and Analysis for Civil Aviation Safety (BEA) became an accredited representative. The BEA in turn assigned technical advisors from the two French companies to assist, under the ultimate control of the NTSB’s IIC.

After the NTSB completed its investigation, families of the accident victims sought related documents from that agency. For procedural reasons, the agency treated the case as a Freedom of Information Act (FOIA) request. FOIA is the federal law under which the public can obtain certain records in the government hands. The law includes numerous exceptions that limit the release of, among other things, “inter-agency or intra-agency memorandums or letters which would not be available to a party … in litigation with the agency” (Exemption 5).

While the NTSB provided some documents, it refused to hand over others citing Exemption 5. The federal district court determined that the documents sought – communications among the NTSB, the operator and the two French manufacturers – were not internal agency documents subject to Exemption 5. The NTSB appealed.

In a case of “first impression” (federal circuit courts have never dealt with the issue before) the U.S. Court of Appeals for the Fifth Circuit determined that FOIA Exemption 5’s “consultant corollary” applied.  The “consultants corollary” deems as “intra-agency” certain communications with, or documents produced by, outside experts who aid in agency decision making. Exemption 5 exists, the court reasoned, to protect the deliberative process within an agency and ensure that persons in an advisory role could express opinions freely without fear of publicity. Inasmuch as a purpose of an NTSB investigation is not to assign blame but to determine the probable cause(s) of an accident in an objective and dispassionate forum, the application of Exemption 5 to the facts of the case aligned with that objective.

Having found that the records passed the “consultant corollary” test and were therefore intra-agency records, the Court of Appeals remanded the case to the district court to determine if the records satisfied the second part of the Exemption 5 test (i.e., that they are of a type that would be exempt from discovery by an opposing party in litigation against an agency).

The Appeals Court’s decision provides some peace of mind to parties to NTSB investigations; however, it limits the information available to entities that cannot be or are not parties. The bottom-line is that if an entity has an interest in the outcome of investigation, and has technical capabilities to offer, it should request “party status.” Although information provided and derived from the internal deliberative process may not be releasable or be used in litigation—the knowledge obtained through the process is valuable.

To learn more about the accident investigation process, visit the NTSB website.  The agency also provides training for the transportation community.


Return to Top of Page

ARSA on the Hill

Model Grassroots Engagement

Aviation Safety Products President Todd Mathews has learned relationships on Capitol Hill are important for his business’ success. Forced by inaction from the FAA, Mathews reached out to his representative and senators. As part of the conversations, congressional staffers were invited to visit his facility for an in-person look at what his company does.

The first to take him up on his offer was Andrea Wiggins, northeast Georgia outreach representative for Sen. Raphael Warnock (D). Warnock, a new senator, is a member of the subcommittee with jurisdiction over the FAA and has more than 19,000 constituents who work at repair stations.

Wiggins toured ASP’s facility on June 8, met employees, learned more about Georgia’s maintenance industry and the work performed by Todd’s company. Armed with a better understanding of the regulatory challenges ASP was facing, Warnock’s office reached out to the FAA to inquire on the status of the ASP’s request. While it may not solve the issue, the visit is a model for how companies can use legislative branch relationships to push for fair treatment from other parts of the government.

The first step in leveraging the power of your representatives and senators is to get on the radar screen.  The best way to do that is to extend an invitation to visit your company.  After more than a year of pandemic-related isolation, representatives, senators and their staffs are desperate for opportunities to engage in person with constituents and hear first-hand how businesses that drive the local economy are faring.

ARSA makes the congressional visit process is easy.  Aside from providing draft invitation letters, the association can help connect you with the right people to set up a visit. We also provide sample agendas and briefing materials to help make the meeting as productive as possible.

Investing time now in extending your company’s influence can have positive consequences in the future.  The association’s team is standing by to help you take your engagement to the next level during Congress’s upcoming summer recess.  Just Ask ARSA and we’ll get the ball rolling.

From humble beginnings with Eastern Airlines to flying with a charter operator before working in an aircraft interior department and then finally beginning Aviation Safety Products, ASP’s team has developed a well rounded understanding of aviation.  Learn more at


Keeping FAA Open

On June 22, House Transportation & Infrastructure Committee Chairman Peter DeFazio (D-Ore.) and a bipartisan group of senior committee members reintroduced legislation to ensure FAA continues operating during government shutdowns.

The Aviation Funding Stability Act was first introduced in 2019 following the 2018-2019 shutdown when most safety inspectors were furloughed and some FAA employees (especially air traffic controllers) worked without pay. The legislation reintroduced in June authorizes the FAA to draw from its Airport and Airway Trust Fund (AATF) during a funding lapse and allows the entire agency to operate at current funding levels for up to 30 days with no action on the part of Congress.

Given the disruptions the shutdown caused for our members (FAA employees unavailable to process approvals and EASA certificate renewals), ARSA was an early supporter of the legislation. During the 116th Congress, H.R. 1108 picked up 303 cosponsors while 13 senators from both parties signed onto a companion bill (S. 762) introduced by Sen. Jerry Moran (R-Ks.). Strong bipartisan support bodes well for enactment this time; headwinds are a packed agenda and opposition from some members of the appropriations committees.


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.


Return to Top of Page


Make ARSA Training Work for 2021

ARSA’s online training program represents its most-valuable benefit to the aviation industry: knowledge gained through training and experience. The association’s team has turned its decades of work on behalf of aviation maintenance into more than 80 hours of on-demand content.

While sessions are available for registration at any time – ARSA member discounts available – companies can also incorporate the association’s training into their regular programs:

(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.

Click here to go directly to the training platform (operated by ARSA’s management firm) and begin reviewing available sessions.

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 (

Price: One-hour sessions are $75 for ARSA Members and $150 Non-Members. Classes with special pricing are indicated on this page. (Member prices provided to certain associations through reciprocal arrangements. Sessions will often be available at lower prices through bundles, coupons and other special opportunities.)
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.
*Only registered participants are eligible to receive a completion certificate for each session. Certificates are delivered automatically via email after the completion criteria – usually viewing the session and submitting an associated test – are met.
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, which is not part of ARSA's website.

Complying with Part 145 – “Soup to Nuts” (Four Hours) Instructor: Sarah MacLeod Description: Specially recorded with a hand-picked audience for interactive discussion, this session thoroughly reviews 14 CFR part 145, discusses the application of the rule and overviews some practical implications of obtaining and maintaining a repair station certificate. Pricing Note: This is a four-hour session and is $300 for members and $600 for non-members. Click here to register and get access for 90 days.

Sessions Accepted for IA Renewal Credit Eight of ARSA's on-demand training sessions have been accepted by the FAA for Inspection Authorization renewal credit under 14 CFR § 65.93. Each session is currently available for registration and immediate access:Click here to purchase all eight sessions (plus one required prerequisite) at a “bundled” discount – let ARSA take care of your IA renewal requirements this year. Click here to purchase all eight sessions (plus one required prerequisite) at a “bundled” discount.

The following general subject areas are covered by sessions currently available in ARSA's training library. Search these and other topics directly via the online training portal (click here to get started).

Aircraft Parts

Audit Activism & Prophylactic Lawyering

Drug & Alcohol Testing

Human Factors

Instructions for Continued Airworthiness

Parts 21, 43, 65, 145 (and others)

Public Aircraft"Going Global" - International Regulatory Law

Grassroots Advocacy

Recordkeeping – "Finishing the Job with Proper Paperwork"

The Fourth Branch of Government (Administrative Agencies and Procedures)

Self Disclosure Programs and Practices

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 To learn more about the association’s training program and see course availability, visit

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


What Have We Learned?

Regardless of our best hopes, there will be no “return to normal” from the pandemic. That isn’t necessarily a bad thing, if we make good on the lessons learned from a year of ongoing disruption.

Session Recorded on March 11 during ARSA’s 2021 Annual Conference.

P.J. Anson, CEO, STS Aviation Group
David Kelly, Vice President of Strategy & Marketing, HAECO Americas
William Morris, General Counsel & Executive Vice President, Wencor Group
Brian Prentice, Partner, Oliver Wyman

Christian A. Klein, Executive Vice President, ARSA (Moderator)

The discussion can be accessed via the online training platform utilized by ARSA.

Click here to access the session.

Click here to review all content available from the Conference.

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 To learn more about the association’s training program and see course availability, visit


Effective Comments and the Fourth Branch of Government

Certificate holders must be adept at dealing with the government. Maintenance providers need to understand the administrative agencies overseeing the industry and recognize how and when to engage in the process in order to better the system. The four sessions in the “fourth branch of government” training series are now available on demand. Purchasers can bundle all four together or focus in on either the administrative agencies themselves (two sessions) or the rulemaking process (two sessions).

The Rulemaking Process – Overview
This session provides an overview of how federal agencies make regulations that have the force and effect of law. Specifically, it reviews the agencies that must follow the Administrative Procedure Act, the procedures governed by the Act as well as other methods by which an agency can obtain recommendations from the public on its rulemaking activities and mandates.
Click here to register and get access for 90 days (multiple bundles available)

The Rulemaking Process – Effective Comments
This session provides methods for submitting effective comments on FAA rulemaking proposals and on other documents that are posted for feedback from stakeholders.
Click here to register and get access for 90 days (multiple bundles available)

Administrative Agencies & Their Powers
This session reviews why federal administrative agencies are created and how they use their powers to regulate activities within their jurisdiction. The course will also cover the basic procedures agencies must follow to create or revise regulations.
Click here to register and get access for 90 days (multiple bundles available)

Administrative Agencies – The FAA & NTSB
This session reviews the creation and powers of the two agencies most prominent in civil aviation – the Federal Aviation Administration (FAA) and the National Transportation Safety Board (NTSB).
Click here to register and get access for 90 days (multiple bundles available)

Registration for an ARSA-provided training includes:

  • Access to the on-demand, recording for unlimited viewing over 90 days.
  • 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 To learn more about the association’s training program and see course availability, visit


Regulatory Compliance Training

Test your knowledge of 14 CFR §§ 11.31, Direct Final Rules.

Click here to download the training sheet.


Return to Top of Page


Quick Question – The AMJP

Aviation Jobs Protection Program Applications Open

On June 15, the U.S. Department of Transportation opened applications for the Aviation Manufacturing Jobs Protection (AMJP) Program. Submissions are due by 5:00 p.m. EDT on July 13.

For program information and application instructions, visit or the program website (click the DOT logo below). To assist the association in supporting industry applications – and keeping tabs on the government’s administration of the program – please answer this month’s “quick question”:

If the embedded survey does not appear/load, open the survey independently by visiting:

Note: The survey below is in an embedded window and you may need to scroll down within the window to see/click the “Submit” button.


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 (

Click the DOT Logo to go to the application process webpage.


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 June:

New Members

Sierra Air Services dba Interjet West, Inc., R01
Vibrant Corporation, R02

Renewing Members

Aerospace Engineering Group, S.L., R03, 2014
Aeroworx, Inc, R02, 2010
Air Transport Components, LLC, R03, 2015
F&E Aircraft Maintenance (Miami) L.L.C , R06, 2012
IAR Technical Services LLC, R03, 2017
Lynden Air Cargo, LLC, Assoc., 2000
Marvel-Schebler Aircraft Carburetors, LLC, R02, 2011
MTU Maintenance Hannover GmbH, R06, 2007
NFF Avionics Services, Inc., R01, 2010
Pac West Helicopters, Inc., R02, 2009
Pacific Aerospace, LLC, R01, 2005
S & T Aircraft Accessories, Inc., R02, 2003
SAI Flight Support Company, R01, 2016
Southwest Airmotive Corp., R01, 2012
T&W Aircraft Electrical, LLC, R01, 2014
Unicorp Systems, Inc., R03, 2003
Warner Propeller and Governor Co., LLC, R01, 2010


A Member Asked…

Q: Are you aware of a vision test, (e.g., Jaeger #2) requirement for maintenance personnel other than those performing NDI/NDT or Welding tasks?

I can find requirements for flight personnel (part of medical certificates), industry standards for welding inspections and have located AC 65-31 for NDI persons, but I am unable to find a regulatory requirement for persons performing visual inspection during maintenance.

We have local policies that require inspectors to have vision tests, but I trying to run down any regulatory requirements.

A: There are no direct requirements—the regulatory hooks that ultimately require maintenance personnel to have good eyesight are:

Section 145.155 that requires inspectors to be:

(1) 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; and

(2) Proficient in using the various types of inspection equipment and visual inspection aids appropriate for the article being inspected.

It is hard to be proficient in using the equipment and “visual” inspection aids without having good eyesight!

Another regulation (that applies to all maintenance personnel) is § 145.163 that requires the training program to ensure persons are capable of performing assigned tasks. While physical capabilities (eyesight) are not “training,” it is hard to argue that a person with bad eyesight is capable performing maintenance tasks, let alone be an inspector…although umpires may be blind (HA).

With respect to “normal” MRO personnel; the general requirement for all repair station personnel is found in section 145.151(b), which states that a repair station must “provide qualified personnel to plan, supervise, perform, and approve for return to service the maintenance, preventive maintenance, or alterations performed under the repair station certificate and operations specifications…” (Emphasis added.)

I don’t know how one would provide “qualified” personnel if they did not have necessary physical attributes – lifting 50 pounds, being flexible enough to maneuver appropriately for the work required, etc. Again, while this may not be a direct requirement for adequate eyesight, it certainly falls within ensuring proper qualifications are set forth by the certificate holder.

On the pragmatic side, it seems checking a person’s driver’s license, could be used to verify that the person can perform general maintenance tasks and verify that task was performed properly, provided s/he uses any “corrective lenses” noted on the license.


Make ARSA’s Voice Your Own: Advertise

ARSA has a menu of advertising opportunities for, 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


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 (



Return to Top of Page


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

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

Resources for Dealing with the Government

As a repair station, dealing with the government, particularly the Federal Aviation Administration (FAA) is inevitable. Building a good relationship with government officials in good times will help keep the bad times at bay.

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

AeroEngines Americas 6/30-7/1/2021 Dallas, TX
FIA Connect 2021 7/13-15/2021 Online
Flight School Association 8/18-20/2021 Orlando, FL
ICAO Global Aviation Security Symposium 2021 (AVSEC2021) 9/8-10/2021 Online
MRO Asia-Pacific 9/20-24/2021 Online
MRO Asia-Pacific 9/21-23/2021 Singapore
RAA 45th Annual Convention 9/25-28/2021 Phoenix, AZ
Business Aviation Convention & Exhibition (NBAA-BACE) 10/12-14/2021 Las Vegas, NV
MRO Europe 10/19-21/2021 Amsterdam, The Netherlands
MARPA Annual Conference 10/TBD/2021 TBD
Fall 2021 Aviation Safety InfoShare 11/2-4/2021 Pittsburgh, PA
LABACE 2021 11/9-11/2021 Sao Paulo, Brazil
DUBAI Airshow 11/14-18/2021 DWC, Dubai Airshow Site
EASA Rotorcraft and VTOL Symposium 12/9/2021 Online
EASA-FAA International Aviation Safety Conference TBD/2022 TBD
MRO AmericasMRO Latin America 1/TBD/2022 TBD
ATEC Annual Conference TBD/2022 Fort Worth, TX
Heli-Expo 3/7-10/2022 Dallas, TX
ARSA Annual Conference 3/8-11/2022 Washington, DC
WAI Annual Women in Aviation Conference 3/17-19/2022 Nashville, TN
AEA International Convention and Trade Show 3/28-31/2022 New Orleans, LA
ABACE 4/12-14/2022 Shanghai
MRO Americas 4/26-28/2022 Dallas, TX
NBAA Maintenance Conference 5/3-5/2022 San Antonio, TX
EASA Rotorcraft and VTOL Symposium 11/16-18/2022 Koelnmesse, Germany

Return to Top of Page

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 For information about previous editions, submit a request through 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.

© 2021 Aeronautical Repair Station Association