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2022 – Edition 8 – September 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.

The President’s Desk
ARSA Works
Legal Brief
ARSA on the Hill
Aviation Life Calendar
Training
Membership
Resources
Industry Calendar


The President’s Desk

The Year You Make Contact?

By Terrell Siegfried, NORDAM Assistant General Counsel and Corporate Secretary & 2022 ARSA President

Fall is right around the corner, and a quick glance through my calendar indicates I’ll be heading off to the nation’s capital for our annual ARSA meeting next month. The other directors and I don’t waste a moment when we’re all in town together, so this timeframe tends to be a blur of tightly agenda-driven sessions as well as networking breakfasts, lunches and dinners.

We’ll also convene face-to-face with senior safety officials from the FAA and with executives from the many trade associations that collaborate with ARSA all year long. At some point, I’ll ask about their families, and they’ll ask about mine.

Inevitably, we’ll talk about how Notre Dame (my alma mater) is looking for the playoffs. Although I’m not sure who keeps bringing that up every year.

To the casual observer, it might seem as if we’re just socializing. While it may look like old home week in the photos posted to the association website, the fact is there’s a powerful reason each of us attends this event. Bottom line, it leads to more success for the association and for its member businesses.

Coming together each fall is a key part of our collective leadership for ARSA and the industry. We quickly put the updates and input gathered from colleagues and government personnel to good use as we decide on ARSA’s areas of focus for the year ahead.

Even better? This level of access and its resulting productivity is not exclusively for board members. Each March, the Annual Conference allows you to interact with agency leaders, association allies, and professional colleagues – in person or from behind a computer screen. We offer so many opportunities to expand your network, connect with key industry players, stay in the know, share your knowledge, and get things done.

For example last year’s attendees were the first to learn the long-awaited release of the new part 147 was accomplished, with acting administrator Billy Nolen announcing this news from the ARSA stage. And in 2014, a member question led to clarification of FAA policy in less than a month!

So get out there more. The aviation industry calendar is filled with conferences, conventions, forums and trade shows. Some have migrated online; many have returned to having a physical presence, and some, like ARSA’s, offer participation by either method. Find the ones that best support your knowledge and build your business, make time for them, and share the dividends of your trip with others.

And be sure the ARSA Annual Conference is on your calendar for March 8-11, 2023. There will be an online option, but I hope to see you in person, in and around Washington, D.C.

P.S. Get a feel for the shape of our annual meeting by reading through public reviews of past ones, in their current format since 2018. You can rely on the same coverage this year as we ensure all members are kept in the loop on the association’s direct engagement activities.

Terrell Siegfried
2022 ARSA president | NORDAM assistant general counsel and corporate secretary
 

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ARSA Works

ARSA’s Work is Yours

ARSA has a proven track record of standing up and zealously searching for the right answers from the government or industry. Unfortunately, it’s easy to misinterpret our engagement as opposition instead of what it really is: equal accountability for aviation safety.

In 2014, a long time FAA aviation safety inspector shared the evolution of his opinion in a pointed and instructive way:

“It’s funny that I used to think that you just…took pleasure in slamming the FAA. That opinion changed. 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 [Executive Director Sarah MacLeod] and the staff of ARSA for the great work you do.”

Members recognize that the association will take a position on broad, complicated issues and hold fast for the good of all. ARSA’s press on instructions for continued airworthiness (ICA) is an excellent example where the association is representing the entire industry, not any particular company. Availability of essential continued airworthiness information is a regulatory backbone for aviation safety. Similarly, the association leads broad coalitions and supports countless industry efforts to support recruitment, retention, and career development. Building the workforce of the future doesn’t bolster one member, it sustains all.

Each month’s hotline delivers clear evidence of this work to members. The team also publishes and tracks its actions on ARSA.org (with updates for the general public via the weekly Dispatch newsletter) and chronicles its letters, petitions and outreach to the government via arsa.org/arsa-works.

Staying on top of these initiatives, recognizing your own interest in their success, and taking action to support ARSA are key benefits of membership. By answering monthly “quick questions,” submitting queries via the “Ask ARSA First” system and following along with “Act Now” on the association’s website are basic steps in pushing this work forward.

 


EASA Hosting SMS Webinar

On Sept. 15, the European Union Aviation Safety Agency (EASA) will host a webinar to explain recent guidance on new Safety Management System (SMS) requirements.

Date: Thursday, Sept. 15

Time: 1:30 p.m. Brussels Time; 7:30 a.m. EDT

Description from EASA: The letter “Implementation of Safety Management System in Part-145 Maintenance Organisations in accordance with Regulation (EU) 2021/1963” was issued on June 23 and it affects all valid, pending and suspended organisations. The aim of this webex is to explain the content of this letter and to clarify any doubts. You may send your questions in advance to MOC_145@easa.europa.eu, please indicate in the subject “SMS Webinar” and your EASA approval number.

Prior Registration Required: Click here.

 



Final Documents/Your Two Cents

This list includes Federal Register publications, such as final rules, Advisory Circulars and policy statements, as well as proposed rules and policies of interest to ARSA members.

To view the list, click here.

 


ARSA-onlinetraining


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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.

Layman Lawyer – Government Agency

By Brett Levanto, Vice President of Operations

Since January, this “Layman Lawyer” has been exploring the FAA’s Compliance Program: An overview in January was followed by a guidance review in June and a primer on a certificate holder’s “entitlement” when showing compliance last month. To wrap up this series – for now…exploring compliance is never-ending – demands considering the agency’s freedom to enforce its rules.

The FAA is a mixed-function agency with a broad range of powers. It issues regulations and licenses (e.g., certificates, approvals), conducts investigations (e.g., reviewing applicant qualifications, surveilling, and inspecting certificate holders), and enforces aviation regulations by formally or informally adjudicating violations (e.g., certificate actions, civil penalties, corrective or remedial actions).

As part of the U.S. government’s executive branch, the FAA holds broad discretion in executing these functions. Wherever Congress has not explicitly directed the agency to act, the courts provide broad deference under the Chevron Doctrine. When government officials act “reasonably” and within their jurisdiction, they are provided wide latitude to interpret and enforce – or decline to enforce – their own rules. A government agency indeed holds considerable agency in executing its mandate.

The downside for industry is limited judicial recourse in demanding executive branch action. In 2017, a court reinforced the FAA’s discretion in a case related to enforcement of 14 CFR § 21.50’s Instructions for Continuous Airworthiness requirements. Though the ARSA member at the center of the case had clearly demonstrated the maintenance instructions constituted ICA and the manufacturers unwillingness to allow access, the judicial branch of the federal government would not force the executive branch agency to enforce its own requirement (to review the member’s petition, click here).

The good news is the FAA can utilize this discretion to positive effect – the “just culture” of the Compliance Program depends on agency personnel using critical thinking in the same “reasonable” manner called out by Chevron deference. Making best use of this flexibility demands constant engagement. Building an ongoing professional relationship with government officials in good times will help keep the bad times at bay.

To get started (or improve on) building that relationship—

(1) Review the complete “Layman Lawyer” series on the Compliance Program, with the linked resources and FAA documentation (since the Program has gotten the “webpage-and-brochure treatment” you might as well take advantage of it).

(2) Visit ARSA’s issue page on Dealing with the Government, with its best practices in communicating with agency personnel, and a link to the association’s training resources.

(3) When you have a question on or issue with the executive branch of the federal government, Ask ARSA First!

Help continue this discussion. Submit your “layman lawyer” experiences or questions via arsa.org/contact.

 


Using Discretion

By Christian A. Klein, Executive Vice President

This month’s “Legal Brief” is part of a long series on FAA enforcement. Last month’s column discussed the process leading up to and following issuance of a Letter of Investigation (LOI); this month we explore the last step before the legal process begins – the decision whether the local office refers the matter to the FAA’s Office of Chief Counsel (AGC) for enforcement.

When considering legal issues, always remember the hierarchy of authority. First comes the statute (i.e., a law passed by Congress and signed by the president) as the ultimate authority, then come regulations, then guidance.

The FAA’s regulatory and investigative authority is derived from provisions in Title 49 of the U.S. Code (U.S.C.). For example, 49 U.S.C. Sec. 40113 gives the agency power to conduct investigations, prescribe regulations, standards and procedures, and issue orders and Sec. 46104 authorizes subpoenas and other discovery in conjunction with an investigation.

14 CFR part 13 contains the regulations that describe the agency’s investigative and enforcement procedures.

FAA Order 2150.3C (Change 7) provides guidance to FAA personnel about how the enforcement process works and Order 8000.373C describes the agency’s Compliance Program.

Compliance Program Action

When FAA personnel believe that a regulatory violation has occurred, the agency has a lot of discretion in resolving it (see this month’s “Layman Lawyer”). The Compliance Program is the agency’s most recent rendition of when and how it applies its discretion to enforce its own rules. The value of seeking compliance from otherwise willing and able certificate holders has been recognized. It is more effective and efficient than applying legal enforcement actions for alleged violations that do not directly impact aviation safety. The long-standing examples of the agency applying its discretion are the voluntary reporting programs.

The agency recognizes that many alleged deviations are the result of simple mistakes, flawed procedures, lack of understanding, etc. So, unless a statute requires legal enforcement action, agency personnel can determine that compliance action is appropriate instead of pursuing legal enforcement.

In determining whether to allow compliance action, the local office considers if the person has taken responsibility for the event, shared information openly to determine the root cause, and has or is willing to implement corrective action. The agency will also determine whether the person has the resources and ability to take the corrective action, comply in the future, and manage risk to gain the knowledge and competence to hold their certificate. If compliance action is deemed appropriate, the root cause of the noncompliance is addressed through training, counseling, education and/or improvements to procedures, processes, or other programs.

Compliance action is a way to avoid monetary penalties and a finding of violation. However, the agency does consider past compliance and administrative actions in deciding whether to use legal enforcement in future cases.

Administrative Action

Another alternative available to local office personnel is administrative action, which is authorized by 14 CFR § 13.11. It can be used when it is determined that enforcement action isn’t necessary, but compliance action will not remediate the noncompliance and ensure future compliance.

There are two types of administrative actions. A warning letter advises of the facts and circumstances believed to constitute noncompliance and requests future compliance.

The other form of administrative action is a letter of correction. Like the warning letter, it identifies a noncompliance and requests compliance; however, it also includes an agreement between the agency and regulated person regarding corrective action that has already been taken or which will be taken by a set deadline.

As with all compliance actions, failure to complete the agreed upon steps to remedy the alleged noncompliance paves the road to enforcement action.

Enforcement Action

There are laws or statutes, such as revocation of airmen certificates due to driving while intoxicated convictions or convictions of federal statues dealing with counterfeiting aircraft parts, that require the agency to take legal enforcement action.

Otherwise, Order 2150.3C, Change 7 explains that referral to AGC-300 is mandatory in cases:

  • Of intentional conduct – deliberate action (or failure to act) when knowing that the conduct is contrary to law or regulation.
  • Of reckless conduct – an action (or failure to act) that demonstrates a gross or deliberate indifference to safety or a safety standard.
  • Of failure to complete corrective action – As discussed above, this scenario arises when a certificate holder has agreed to take corrective action to come into full compliance and avoid recurrence but has not done so.
  • Where conduct creates or threatens to create an unacceptable risk to safety.

Once the agency has determined that enforcement action is warranted, it can take the form of either a civil penalty or a certificate action. We will discuss both in upcoming “Legal Briefs.”

 


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ARSA on the Hill

Who’s on Deck?

By Christian A. Klein, Executive Vice President

The U.S. mid-term congressional elections this November will determine which party controls Congress during the next year’s FAA reauthorization process. Republicans are bullish on retaking both the House of Representatives and Senate, while Democrats are fighting hard to protect their razor-thin majorities. No matter which party comes out on top, there will be new leadership on the aviation committees and subcommittees.

Rep. Peter DeFazio (D-Ore.), who has served as chairman of the House Transportation & Infrastructure (T&I) Committee since 2019, will retire from Congress this year. His departure sets up a leadership battle in the House committee that will write next year’s FAA reauthorization bill. One of three current members of Congress is poised to claim the gavel in the wake of DeFazio’s departure.

If the Republicans capture the House, Rep. Sam Graves (R-Mo.) is a shoo-in to be the next T&I chairman. Graves, holds an Airline Transport Pilot certificate, is currently the senior Republican on T&I, and has been involved in aviation most of his life. “Growing up, my brother and I would pump gas, wash planes, or do whatever work we could find around the airfield, and we were always mooching a ride in one of the airplanes. That’s what started me on my way to becoming a professional pilot with an ATP,” Graves told the Aircraft Owners and Pilots Association in 2020.

As a pilot, Graves understands the importance of regulatory oversight, but also knows regulations need to serve safety – not political – purposes. He and his staff worked across the aisle with Democrats to significantly improve the contract maintenance bill passed by the T&I Committee this summer. He’s also a champion for aviation workforce development. He earned the 2019 ARSA Legislative Leadership Award by being one of the lead sponsors of the maintenance technician grant program created at the association’s urging during the last FAA reauthorization.

The two members vying to be the senior Democrat on T&I (and chairman if their party holds the House) are Rep. Rick Larsen (D-Wash.) and Del. Eleanor Holmes Norton (D-D.C.).

Larsen’s northwest Washington district abuts the Seattle area. According to his online bio: “The Pacific Northwest is the aerospace capital of the world, and I will work hard to make sure the United States invests in our aviation future. Aviation means jobs in Northwest Washington. Anything I can do to support the growth and safety of air travel will bring good jobs to our communities.”

As chairman of T&I’s aviation subcommittee, Larsen has put those words into action. He’s been a champion for aviation workforce development programs and has led annual efforts to secure full funding for the new maintenance technician grant program. While many congressional Democrats seem to accept negative contract maintenance messaging from labor unions without a second thought, Larsen has served as an honest broker on repair station issues and clearly understands the impact that the maintenance industry has in his home state. Despite being a senior Democrat on the T&I Committee, Larsen did not cosponsor Chairman DeFazio’s anti-repair station bill. During the pandemic, he was also one of the champions of legislation to protect aviation jobs. In recognition of his leadership, Larsen received ARSA’s Legislative Leadership Award in 2022.

Continue reading below…

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The other Democratic contender is Norton, who has served in Congress for 30 years and is the chair of T&I’s highways and transit subcommittee. Norton is an unusual candidate for the chairmanship job. As D.C.’s congressional delegate, she does not have a vote on the House floor and would be the first D.C. delegate to chair a congressional committee. Given that there are no repair stations in Washington, D.C., it has been difficult to break through with Norton on maintenance issues; she was an original sponsor of DeFazio’s bill. She also leads the Congressional Quiet Skies Caucus, which works to address aircraft noise issues.

Several factors will determine whether Larsen or Norton become the next senior T&I Democrat. With FAA reauthorization looming, the fact that Norton has just finished helping to steer a major authorization bill (the $1.2 trillion infrastructure bill approved last year) through the legislative process works in her favor. However, Larsen has the edge when it comes to aviation policy knowledge.

Then there are politics. Larsen, a former dental lobbyist, is regarded a moderate at a time when members from the extreme wings of both parties seem to be calling the shots on the Hill. Norton, a Yale law school graduate, cut her teeth on equal employment issues early in her career is as regarded as more liberal than Larsen.

Ultimately, sometime between the November elections and the convening of the new Congress in January, the decision between Larsen and Norton will be made by the House Democrats’ Steering and Policy Committee, which is charged to “consider all relevant factors, including merit, length of service on the committee, degree of commitment to the Democratic agenda, and the diversity of the Caucus, in making nominations for Chair.”

No matter who comes out on top, ARSA looks forward to promoting aviation safety and common-sense oversight in the next Congress.

Next month: Larsen’s potential impact on the aviation subcommittee.

 


Meet the Candidates

Vying for House Transportation & Infrastructure Committee Chair
 
Rep. Sam Graves
Party: Republican
District: Missouri-6
First Elected to Congress: 2000
Current Position: Ranking Republican Member, House T&I Committee
Notes: 2020 ARSA Legislative Leadership Award Winner. Airline Transport Pilot.Link to congressional bio
   
Rep. Rick Larsen
Party: Democrat
District: Washington-2
First Elected to Congress: 2000
Current Position: Aviation Subcommittee Chairman
Notes: 2022 ARSA Legislative Leadership Award Winner. Strong advocate for aviation workforce development.Link to congressional bio
   
Del. Eleanor Holmes Norton
Party: Democrat
District: District of Columbia
First Elected to Congress: 1990
Current Position: Highways and Transit Subcommittee Chairman
Notes: No repair stations in her district. Original cosponsor of anti-repair station bill.Link to congressional bio

 


Getting to the Voting Booth

Editor’s Note: This is the fourth part in this year’s series on active political engagement. ARSA returns to this topic every U.S. national election year. Navigate the series using the links below: 

District Offices – The One Stop Engagement Shop

Being a Good (Facility Visit) Host

Your Town’s Politics

The U.S. election cycle – which now seems to begin immediately after races are called and burns hot along ideological lines for two Novembers – is ending. On Nov. 8, Americans will go to the polls. Every seat in the House and 35 in the Senate are up for grabs, though not all are competitive.

General political analysis is found in countless media outlets of varying pedigree. Expectations shift, but the storylines are remain familiar: Republicans seek to retake both chambers of Congress by fending off recent Democratic resurgence as the sides spar over student loans, reproductive rights, the economy, and a host of other issues.

Predictions abound; ARSA will wait and see. Regardless of what the nation’s political map looks like on Nov. 9, it’s important to vote. Beyond the federal elections, citizens will elect governors, state house officials, and others in addition to deciding the fate of countless ballot measures and referenda.

Adding your voice to those decisions is an essentially American activity. It’s also a practical one. The winners of this year’s election will weigh heavily on the next two years of national and local policymaking. As members of a regulated industry, its vital to your professional interests.

Prepare by:

(1) Visiting www.usa.gov/how-to-vote to see where and when you can vote – including absentee and early voting options.

(2) Use ARSA’s Legislative Action Center – provided by 2022 Annual Conference Platinum Sponsor Aircraft Electric Motors – to see the candidates running for national office in your jurisdiction. You will find state-specific voter resources by entering your address and zip code into the “Find Officials” field and select “Candidates.”

No matter what happens this election, ARSA will be ready to show a new Congress that the world can’t fly without you.

Click here to learn more about ARSA’s efforts on – and off of – the Hill.

 



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Aviation Life Calendar

Something exciting happens every day in an aviation career.

If you want to keep aviation in the forefront of career choices, celebrate success every day with these resources. Every one provides a positive view of the industry’s ability to make the impossible an everyday event by individuals from every walk of life, socio-economic level, race, creed, color, religion, orientation, and physical capability.

Check back regularly for updates.

Month Day Event or Celebration
All All This Day in Aviation
September   This Day in Aviation History – September
September 1st Wednesday Global Talent Acquisition Day
September 15 Hispanic Heritage Month
October   This Day in Aviation History – October
October 4 World Space Week
October 20 International Air Traffic Controller Day
November   This Day in Aviation History – November
November   National Native American Heritage Month
November   National Aviation History Month
November 8 National STEM/STEAM Day
December   This Day in Aviation History – December
December 1st Saturday International Civil Aviation Day
December 17 Wright Brothers Day

 


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Training

Make ARSA Training Work

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.

To review sample syllabi of training session options from the firm – many of which have similar sessions available generically through ARSA training – click here to download a combined PDF. The syllabi include “Regulatory Comprehension for Maintenance,” “Public Aircraft,” “AD Compliance” and more. 

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 (brett.levanto@arsa.org).

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 PotomacLaw.InreachCE.com, 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

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.

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 (brett.levanto@arsa.org).

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.

 



Self-Disclosure – The Elements

This session reviews the elements of self-disclosure established by the FAA. It will cover the who, what, why, when, where and how of filing a voluntary self-disclosure report with the agency. Additionally, it will cover how the agency is to handle the report and its expectations for follow up actions.

Instructor: Sarah MacLeod

Click here to register and get access for 90 days.

Purchase both self-disclosure sessions together and save on the bundle.

Registration for an ARSA-provided training session includes:

  • 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.
  • 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.

 


Self-Disclosure – Avoiding Self Exposure

This session reviews the best methods for investigating a potential non-compliance, including how to distinguish between business and regulatory requirements and how to use language that relates facts to the regulations without creating unnecessary consternation or scrutiny. To obtain the most from this session, participants must have a basic knowledge of the FAA’s program elements.

Instructor: Sarah MacLeod

Click here to register and get access for 90 days.

Purchase both self-disclosure sessions together and save on the bundle.

Registration for an ARSA-provided training session includes:

  • 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.
  • 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 § 11.71, content of rulemaking petitions.

Click here to download the training sheet.

 


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Membership

Share Your News!

In addition to informing members of its work on the aviation maintenance industry’s behalf, ARSA uses its communications to celebrate the great work by repair stations, operators, manufacturers, service providers and everyone else with an interest in aviation safety. The association’s team fills its weekly Dispatch with news and updates from all over the world.

Ensure that your message gets out so your colleagues can celebrate with you by sending news items, press releases, and other updates to arsa@arsa.org. The team reviews all incoming content for potential inclusion in ARSA newsletters. Get the association on your distribution list today.

Note: The Dispatch is a news roundup that always links to primary sources. For best chance at inclusion, provide a link to your content. Acceptable sources include industry news or general media sites as well as your own hosted webpages/blog posts.

ARSA Newsletters and Outreach

Member contacts should regularly receive the following general communications from the association:

Weekly: Every Wednesday the Dispatch is distributed.

Monthly: The hotline is distributed the first week of each month (members only).

Various: Member alerts regarding specific events, activities or updates demanding specific attention are distributed as needed.

Membership Term Dependent: Renewal reminders begin flowing out 90 days before the expiration of membership term.

In addition to these large-scale distributions, ARSA team members will use their @arsa.org email addresses to coordinate directly with member contacts related to association business and industry matters.

Special Advertiser Distributions

From time to time, ARSA provides a mechanism for sponsors of its Dispatch and hotline periodicals to reach readers directly through “blast” emails. This advertising option gives companies a chance to show support of the association and to provide useful information and resources to readers. While receiving this message, ARSA subscribers and members should be assured that:

  • The frequency of special “blast” messages is kept to a minimum. This maintains the special focus provided to advertisers sending the messages and prevents “overload” in readers’ inboxes.
  • Advertisers are not provided direct access to newsletter subscription lists.
  • ARSA team members review and approve all messages prior to distribution.

For questions about ways to stand up for the association through ARSA’s advertising options, contact Brett Levanto.

Advertising Solicitations

The association has recently decided to return advertising sales in house. Beginning Nov. 3 – active advertisers will hear from the team prior to that – only personnel with @arsa.org email addresses will solicit advertising sales. Interested in supporting ARSA and sharing your good work? Contact ARSA.

Spam Filters and Firewalls

It can sometimes be difficult for organizations like ARSA to get messages into your inbox. To ensure you have access to every periodical, alert, and update, place the following domains are on your “safe list”:

@arsa.org
@potomac-law.com

To learn more about ARSA’s communications efforts – including how to advertise – visit arsa.org/news-media. For assistance with technical issues, consult your organization’s IT department/assistant as necessary.

 


Quick Question – Lawyering Up

Smart aviation professionals know when to ask for help and to be the best aviation business it is important to use appropriate support to bolster or protect their enterprise. ARSA members have long directly and indirectly benefitted from the legal expertise of the association’s management firm.

There are many reasons aviation companies seek legal advice. Help the association understand your triggers by answering 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-lawyerselection.

 

Click here to see what questions have been asked and answered…and keep a lookout for more.

 


Welcome Back – 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 renewed in August:

AAR Corp., Corp., 1985
Aircraft Systems Division of Com-Jet Corp, R03, 2011
Airframe Components by Williams, Inc., R02, 2003
Aerospace Welding Minneapolis, Inc. , R01, 2020
AllFlight Corporation, R03, 2011
Aviation Repair Solutions, Inc., R02, 2006
CorpAir Supply Company, Inc. dba AVMATS Component Support, R02, 2001
Cross-Check Aviation, R02, 2003
E.U.A. Air Support, Inc., R01, 2003
Eagle Creek Aviation Services, Inc., R04, 2016
Gyro Specialist, Inc., R01, 2011
HEICO Aerospace Corporation, Corp., 1992
Hot Section Technologies, Inc. , R02, 2017
International Turbine Industries, LLC, R02, 2010
Intrepid Aerospace, Inc., R02, 2016
Jordan Propeller Service, Inc., R02, 2002
Millennium International, L.L.C., R02, 2013
MTI Aviation, Inc., R02, 2011
NFF Avionics Services, Inc., R01, 2010
National Flight Services, Inc., R04, 1991
Pacific Aerospace, LLC, R01, 2005
Pacific Turbine Brisbane, R03, 2018
Palm Beach Aircraft Propellers, Inc., R02, 2001
Paz Aviation, Inc., R02, 2016
Precision Aero Technology, Inc., R03, 1993
R.W. Raddatz, Inc., R02, 2004
Rotron, Inc. dba Ametek Rotron, R02, 2016
S & K Aerospace dba AE & C Services, LLC, R01, 2017
Signature Engines, Inc., R02, 2017
Team Aerospace, Inc., R01, 2005
Tennessee Aircraft Company, Inc., R01, 2012
Unical 145, Inc., R04, 2012
Unicorp Systems, Inc., R03, 2003
Zee Company, Inc., R02, 2019

 


A Member Asked…

Q: According the § 145.153(a) a certificated repair station must “ensure it has sufficient number of supervisors to direct…work performed.” What’s considered sufficient/insufficient, how is that measured?

A: Excellent question. The path is simple: Section 145.163 requires the repair station to assess the capability of technicians and either put them into training or supervise them until they have the capability (through experience) to perform assigned tasks without oversight. The more experienced the crew the less supervision/supervisors needed.

The knowledge and experience of a supervisor must be documented on the “employment summary” required by section 145.161(a)(4). The summary must “contain enough information on each individual listed on the roster to show compliance with the experience requirements of this part [145].”

Qualifications for supervisors are in section 145.153. If the person is overseeing individuals that are unfamiliar with their tasks, the supervisor must know (from experience or training) how to do the task. If the supervisor is directing work on the floor, s/he must know the workflow, skills, and capabilities need to accomplish the task.

Finally, it is important that all technicians performing tasks on civil aviation articles are reminded that “each person” must perform their work so it meets the quality requirements of section 43.13. That section requires tasks be performed in accordance with “methods, techniques, and practices acceptable to” a federal agency and it must return the article worked on to “at least” its original or properly altered condition. Safety is not just a responsibility to an aviation technician, it’s the law.

 



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.

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.  But ARSA is prohibited from sending PAC information to members who haven’t opted in to receive it.

Careers in Aviation Maintenance

How do you share the industry’s story with the people who could be its future? Teach them about the great work done every day to keep the world in flight. (Even if we can’t recruit somebody, we sure can make them thankful for our work.) 

U.S./EU Maintenance Annex Guidance

See all of the association’s public updates since 2012 on the Maintenance Annex Guidance between the United States and European Union. The page focuses in particular on matters related to parts documentation issues arising since MAG Change 5 was issued in 2015.

The FAA Enforcement Process

There are several reasons the agency may open an enforcement investigative report (EIR). Complaints from former or current employees, routine surveillance of your operations or a problem from a customer are all examples of how an “investigation” starts.

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

Conference Dates Location
Helitech Expo 2022 9/7-8/2022 ExCel London, UK
Dulles Plane Pull Event 9/17/2022 Dulles, VA
MRO Asia-Pacific 9/20-22/2022 Singapore
NBAA Business Aviation Convention & Exhibition (NBAA-BACE) 10/18-20/2022 Orlando, FL
MRO Europe 10/18-20/2022 ExCel London, UK
MARPA Annual Conference 11/2-3/2022 San Diego, CA
Purdue University National Aviation Symposium 11/8-10/2022 West Lafayette, IN
European Rotors: VTOL Show & Safety Conference 11/8-10/2022 Cologne, Germany
HAI Aerial Work Safety Conference 11/16-17/2022 Boise, ID
Aero-Engines Americas 2/7-9/2023 Dallas, TX
MRO Latin America 2/22-23/2023 Buenos Aires, Argentina
WAI Annual Conference 2/23-25/2023 Long Beach, CA
MRO Middle East 3/1-2/2023 Dubai, UAE
Heli-Expo 3/6-9/2023 Atlanta, GA
ARSA Annual Conference 3/14-17/2023 Washington, DC
ATEC Annual Conference 3/26-29/2023 Chicago, IL
MRO Americas 4/18-20/2023 Atlanta, GA
WATS 2023: 25th World Aviation Training Summit 4/18-20/2023 Orlando, FL
AEA International Convention & Trade Show 4/24-27/2023 Orlando, FL
NBAA Maintenance Conference 5/2-4/2023 Hartford, CT
EBACE 2023 5/23-25/2023 Geneva, Switzerland

 


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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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