2024 – Edition 10 – November 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.
President’s Desk
Conference Corner
Regulatory Updates
ARSA Works
Legal Briefs
ARSA on the Hill
Training & Career Development
Membership
Resources
Industry Meetings & Events
The President’s Desk
Climbing the Ladder
It is hard to believe that in 2008 I was an intern at the Aeronautical Repair Station Association and today I am its president.
The ladder continues to expand; each rung is built on an abiding interest in the business of aviation safety.
The first rungs were all about safety and technical knowledge, those rungs depend upon the hands-on skills, ability, and continual learning curve that comes from working aircraft and components every day, day in, day out, rain, shine, sleet, snow, heat, hurt, and sometimes blood. Knowledge of the materials, construction, stresses, misdiagnosis, misapplication, and just plain mistakes that can be and are made, all become part and parcel of experience. Knowledge without experience, and experience without knowledge are killer combinations in aviation safety.
After understanding how aircraft should be maintained or altered came learning how to read and apply aviation safety regulations. The stint with ARSA (under the tutelage of its executive director) while learning the art of dealing with government inspectors that can ruin a business allowed me to step up yet another rung. Apparently, it is a good thing to have a mild but stubborn personality when reading and applying international regulations, while negotiating with regulators and customers.
The next rungs of the ladder came with responsibilities for supervising, managing, and motivating individuals that perform essential functions under less than optimum conditions. The gap between those that do and those that manage is deep and wide unless each “side” understands the necessity and contribution of the other. Managing aviation work and technicians takes additional knowledge and a different set of skills. Recognizing and addressing inefficiencies due to human conditions and nature can be daunting. It takes much more time, energy, and resources to understand and motivate humans than it does to fix the most complex aircraft or component.
So far, each rung of the ladder has increased the need for more human interaction and intervention. As president of ARSA, my focus will be to obtain and provide opportunities to interact with other professions and professionals that ensure the aerospace workforce understand the careers available and the rungs on the ladders of growth.
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Bob Mabe 2025 ARSA president | HAECO Americas director of regulatory compliance |
Conference Corner
Get Ready
Experience the maintenance community’s premier event. Join ARSA members and invited guests from around the world to engage governments, network with peers, and improve the state of the aviation world.
Arlington, Virginia and Washington, D.C. with Livestream Options for Online Participants
Registration Opens: December 2024
Event Dates: March 18-21, 2025
Event Information
The details from the 2024 event are maintained as a reference for attendees and to assist in preparation for 2025.
Executive to Executive Briefings: Tuesday, March 18, 2025
Participation by industry executives with senior executive branch officials is limited to annual conference sponsors at the Administratium, Platinum, Gold, or Silver levels. In past years, meeting participants included representatives from the U.S. Departments of Commerce, Defense, Labor, State, and Transportation as well as the fellow trade associations and industry interest groups.Legislative Day: Wednesday, March 19, 2025
The day dedicated to educating both the aviation maintenance industry and elected officials. Learn (or brush up) on what ARSA does and what you can do so you're ready for afternoon visits with targeted Capitol Hill legislators and staff.Annual Repair Symposium: Thursday, March 20, 2025
The centerpiece of Conference week, ARSA convenes a full day of substantive panel discussions covering key regulatory compliance and business issues. After the keynote address, regulators from across the world join the full-morning "Opening Salvo" conversation, followed by lunch and an afternoon of practical regulatory and business discussion.Member Day: Friday, March 21, 2025
ARSA's leadership briefs members on the state of the association as well as goals and priorities for the coming year. Participants then close out the event by participating in breakout and/or training sessions focused on key aerospace topics. The Conference ends by 12:00 p.m. EDT.In-Person
All substantive and social activities were hosted at the Ritz-Carlton, Pentagon City in Arlington, Virginia. Legislative Day participants will head to Capitol Hill for meetings with congressional offices as appropriate.
Livestream
The majority of Conference events will be available to livestream viewers via a Vimeo web-player embedded into a page on ARSA.org. All in-person registrants will be able to name a "Conference Ambassador" as a contact to access the livestream and bring the event back to their home facilities. Paying registrants for livestream access may share with multiple company contacts. Livestream participation will include a mechanism for submitting questions to onsite personnel.
Pricing
| Executive to Executive Briefings | ||||
| Open to Administratium, Platinum, Gold, and Silver-level sponsors. | ||||
| Legislative Day – Wednesday, March 19 | ||||
| Members | Non-Members | |||
| First | Additional | First | Additional | |
| In-person | $400 | $360 | $600 | $540 |
| Livestream Free with in-person registration. | $400 | $600 | ||
| Symposium – Thursday, March 20 | ||||
| In-person | $900 | $810 | $1,250 | $1,125 |
| Livestream Free with in-person registration. | $900 | $1,250 | ||
| Legislative Day & Symposium Bundle | ||||
| In-person | $1,100 | $990 | $1,500 | $1,350 |
| Livestream Free with in-person registration. | $1,100 | $1,500 | ||
| The Super Bundle (Silver Sponsorship, E2E, Legislative Day, & Symposium) | ||||
| In-person | $4,200 | $4,500 | ||
| Livestream Free with in-person registration. | ||||
| Member Meeting & Training/Breakouts – Friday, March 21 | ||||
| In-person | Free with Symposium registration. | |||
| Livestream | ||||
Administratium – $20,000
What is Administratium? An element aerospace professionals see every day (click here to learn more). Notation in all publicity, marketing and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, conference attendee contact list, specific email alerts to association contacts), recognition in event materials and from the podium, specific thank you in ARSA periodicals, additional advertising placement via ARSA’s communications, complimentary registrations for three (3) participants in the Executive to Executive Briefings as well as three (3) in Legislative Day, and free livestream access for personnel unable to attend in person. At the Administratium Level, sponsors may select one of the following* to specifically support (please note the list in this document does not reflect current availability):- Annual Repair Symposium – Ice Breaker Reception
- Annual Repair Symposium – Thursday Happy Hour
- General Sponsorship
Platinum – $10,000
Notation in all publicity, marketing and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, conference attendee contact list, specific email alerts to association contacts), recognition in event materials and from the podium, specific thank you in ARSA periodicals, complimentary registrations for three (3) participants in the Executive to Executive Briefings as well as three (3) in Legislative Day, and free livestream access for personnel unable to attend in person. At the Platinum Level, sponsors may select one of the following to specifically support (may not reflect current availability for 2025):- Online Conference Experience
- Executive to Executive Briefings
- Legislative Day – All Day
- Congressional Directories/Resources
- General Sponsorship
2024 Platinum Sponsors
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Gold – $7,500
Notation in all publicity, marketing and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, conference attendee contact list, specific email alerts to association contacts), recognition in event materials and from the podium, specific thank you in ARSA periodicals, complimentary registrations for two (2) participants in the Executive to Executive Briefings as well as two (2) in Legislative Day, and free livestream access for personnel unable to attend in person. At the Gold Level, sponsors may select one of the following to specifically support (may not reflect current availability for 2025):- Legislative Priorities Brochures/Resources
- Digital Companion/Electronic Materials
- Legislative Day – Continental Breakfast
- Legislative Day – Congressional Briefing and Luncheon
- Annual Repair Symposium – Continental Breakfast
- Annual Repair Symposium – Luncheon with Special Guest
- Nametag Lanyards
- Hotel Room Keys
- General Sponsorship
2024 Gold Sponsors
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Silver – $3,500
Notation in all publicity, marketing, and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, conference attendee contact list, specific email alerts to association contacts), recognition in event materials and from the podium, complimentary registrations for one (1) participant in the Executive-to-Executive Briefings as well as one (1) in Legislative Day. At the Silver Level, sponsors may select one of the following to specifically support (may not reflect current availability for 2024):- Annual Repair Symposium – Coffee Break (5)
- General Sponsorship
2024 Silver Sponsors
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Supporter – $2,500
Notation in all publicity, marketing, and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, specific email alerts to association contacts), and recognition in event materials and from the podium.Contributor – $500 to $2,499 (or equivalent support)
Notation in some publicity, marketing, and periodicals (e.g., the hotline, Dispatch), and recognition in event materials and from the podium.2024 Contributors
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ARSA has reserved a block of rooms for Conference participants at the Ritz-Carlton, Pentagon City in Arlington, Virginia. The hotel hosts most of the activities related to the ARSA Conference and is convenient to the Metro as well as Washington Reagan National Airport (DCA). The deadline for reservations made in this block is Feb. 21, 2025.
To reserve your room(s), visit https://book.passkey.com/go/ARSAAnnualConf2025.
Attendees may also call the dedicated group desk +1.800.422.2410. Reference the ARSA Annual Conference when making reservations. The Leo Weston Award for Excellence in Government Service
First bestowed on Leo Weston himself in 2005, the Weston award honors an instrumental figure in ARSA's birth by recognizing individuals who embody his commitment to the industry's safety and success. The symposium provides a venue for association members and invited guests from around the world to network and discuss issues that matter to the aviation maintenance industry. It is the perfect time to respect the history of the repair station community and honor the good works of those who support it.
Click here to learn more about Leo, the award bearing his name, and those who have received it.The Legislative Leadership Award
The association regularly recognizes members of Congress who have provided outstanding support to the aviation maintenance community by supporting policies beneficial to the industry. Honorees have each been key in moving forward specific legislation advancing priorities championed by ARSA on behalf of its members.
Click here to see past updates regarding Legislative Leadership Award recipients.The "Golden Shovel" Award
From time to time, ARSA recognizes individuals – usually at the time of their retirement – who have spent their careers in steadfast devotion to good business, good safety, and good oversight. In the colorful illustration of Executive Director Sarah MacLeod, these professionals have spent their lives shoveling against the tide of government bureaucracy; their achievement in never giving up is acknowledged through the "Golden Shovel Award."
Click here to learn more about the "Shovel" and see who has received it.Event Photos
ARSA has created a Google Album including photos taken during the 2024 Annual Conference, which allows participants to share their own photos (Sharing event photos constitutes consenting to their use/distribution in association with Conference-related publicity for this or future events, at ARSA’s discretion). To see the album, click here.Select Recordings
The following selections were highlighted in ARSA's member newsletter, the hotline. Click the headline link to view the recording in the March edition.Legislative Day Briefing – Global Fleet & MRO Market Report
The team from Oliver Wyman CAVOK presented their findings to Legislative Day participants on March 13, illustrating the current and projected states of the North American and global aircraft fleets and related impacts on maintenance demand.
Legislative Day Briefing – Perspectives on Reauthorization
Attendees used these insights (and all the March 13 content) in their meetings on the Hill; all members can benefit from the cross-industry expertise of this lobbyist panel.
Symposium Briefing – What Has ARSA Done Lately
The brief session includes key updates from the association’s year as well as instruction for maximizing membership value.
Symposium Briefing – In the Fire with AVS-1
There were no real flames on stage, but an intense and engaged discussion of the state of the aviation industry. View a clip from the exchange where Sarah MacLeod and David Boulter discuss SMS, training, and more.
Symposium Briefing – Training First
The Symposium portion of the Annual Conference wrapped on March 14 with an hour-long session on how we learn and what we can learn about improving training and personnel development.
Regulatory Updates
Boulter to Vacate AVS-1
It appears that David Boulter, the FAA’s associate administrator for aviation safety, will soon be leaving the agency. His departure comes just over a year after officially assuming the AVS-1 position in August 2023 (after acting in that capacity since June 2022).
AVS-1’s importance cannot be overstated. The position is responsible for setting, overseeing, and enforcing safety standards for all aspects of the aviation industry while managing 7,600 FAA employees located around the world and an annual budget of more than $1.8 billion. Only the administrator and deputy administrator are more senior, and they are political appointees.
The FAA is suffering a leadership crisis. Numerous senior agency officials are serving in an acting capacity, with little accountability. Few in “acting” positions feel empowered to make decisions. Oversight has suffered while efficiency and respect has been undermined. As the agency rebuilds the professionalism, regulatory knowledge, and technical aptitude of its workforce, effective, long-term leadership is critical to keeping progress on track.
ARSA thanks David for his public service in the cause of aviation safety and urges FAA Administrator Michael Whitaker to name his permanent replacement as quickly as possible.
New Rule Requires U.S. Agents for American Certificate Holders Abroad
On Oct. 8, the Federal Register published an FAA Final Rule creating subpart C to 14 CFR part 3, requiring certain international certificate holders or applicants to designate U.S. agents for service.
Any foreign person applying for a certificate under parts 47, 61, 63, 65, 67, or 107 must designate a U.S. agent for service unless there is a physical address on file in the United States. Existing certificate holders will be required to provide an agent for service by July 7, 2025.
According to the preamble, as of July 2022 there were approximately 115,000 individuals who had applied for or held a certificate under one of the affected parts and had a foreign address but no U.S. address on file with the FAA. The agency estimated it sends more than 8,000 documents abroad to these certificate holders annually, costing nearly $600,000.
“The FAA determined that the cost of hiring a registered U.S. agent service company may range from $50 to $200 annually. However, as discussed in the NPRM, many individuals with foreign addresses may have a friend or family member residing in the U.S. whom they may choose to designate as their U.S. agent, resulting in no annual costs to those individuals for hiring a U.S. agent for service,” the preamble said.
To review the final rule, click here.
To see the current version of the regulation, go to part 3, subpart C.
Everything Old is New Again in Supply Chain Integrity
In October, the privately led Supply Chain Integrity Coalition release its report in response to the 2023 scandal involving fraudulent parts documentation created by a UK-based aviation broker. The report was supported by eight aviation businesses and headed by former NTSB Chairman Robert Sumwalt. It recommended a series of short-, medium-, and long-term actions to improve vendor, documentation, and part-related data.
The report includes an incomplete regulatory review, the requirements for FAA approval under part 21 and part 43’s maintenance rules are given short shrift. It does not explore what information pertaining to products or articles, or maintenance, preventive maintenance, or alteration performed on them, is required to be created or maintained by the rules. It focuses on the FAA Form 8130-3 without explaining that it is not required by the regulations for either production or maintenance activities in the United States.
The report does not discuss part 3’s definition of “airworthy,” nor does it note the disclaimer on the bottom of FAA Form 8130-3 that the document “does not automatically constitute authority to install” the article. While it does commend the TAP Air Portugal personnel who eventually caught the bad documentation in the 2023 case, it falls far short of ARSA’s focus on individual technical skill for determining suitability for installation.
Overall, the report echoes points that have long been implemented by aviation stakeholders. It supports an FAA Voluntary Industry Distributor Accreditation Program defined by Advisory Circular 00-65; the agency currently accepts standards from the Aviation Suppliers Association (ASA), the International Organization for Standardization (ISO), and the International Aerospace Quality Group (IAQG). The coalition also pushes for further records digitalization to eventually support voluntary databases of vendors and back-to-birth parts documentation. Another effort that has been long sought by the industry while being hampered by international aviation agencies.
“To ARSA, the situation is a painful symptom of international focus on regulatory harmonization at the expense of ensuring safety outcomes,” Christian Klein and Brett Levanto wrote in a November 2023 editorial in Director of Maintenance Magazine. “Governments may run on paperwork, but the last line of defense in aviation safety is still what it always has been: a trained and conscientious technician, not a piece of paper.”
ARSA’s Model RSQM Compilation includes a basic definition and policy for addressing suspected unapproved parts by reporting them via FAA Form 8120-11. A new edition of the form was released in September 2024 without substantive updates. Member companies are encouraged to review their own practices and confirm the regulatory standards for parts documentation (for help, see the association’s three-part training series on aircraft parts).
To read the full report from the Supply Chain Integrity Coalition, click here.
U.S.-Brazil MIP Goes Live
On Oct. 1, the Maintenance Implementation Procedures (MIP) between the United States and Brazil entered into force. The FAA confirmed the agreement’s status in a Sept. 30 Information for Operators (InFO).
The MIP between the FAA and Brazil’s National Civil Aviation Agency (ANAC) was signed on Nov. 5, 2018; the related Maintenance Annex Guidance (MAG) was signed June 15, 2023. However, it was not until Aug. 2 that the FAA notified ANAC it had completed the procedures, guidance, and training necessary to implement the MIP.
The MIP establishes terms and conditions for mutual acceptance of maintenance facility inspections and evaluations by the FAA and ANAC in the United States, its territories, and Brazil. The InFO explains that effective Oct. 1, 2024, a maintenance facility certificated by the FAA as a 14 CFR part 145 repair station and certificated by ANAC as a Brazilian Regulation of Civil Aviation (RBAC) 145 maintenance organization, must comply within two years with all the requirements of the MIP and MAG.
The InFO recommends impacted repair stations begin planning now to implement an acceptable supplement as specified in the MAG. These maintenance organizations will receive a letter from the FAA or ANAC outlining the conditions for transfer of oversight, which will occur within 24 months after the MIP’s entry into force (i.e., by Oct. 1, 2026).
In the United States the MIP’s entry into force primarily impacts repair stations working on products (aircraft, engines, and propellers). Brazil takes a very enlightened perspective on accepting work by repair stations whose local civil aviation authorities are the FAA, Transport Canada Civil Aviation, the UK Civil Aviation Authority, and the national authorities of European Union Aviation Safety Agency member states. Brazil does not require such repair stations to have separate ANAC certification to perform maintenance, preventive maintenance, rebuilding, and alterations on components and approve them for return to service for installation on Brazilian registered aircraft.
For more information on ANAC’s acceptance of foreign component maintenance, click here.
ARSA Works
How the Administrator Can Improve Stakeholder Committees
On Oct. 22, ARSA joined ten other industry organizations including both allied trade associations and independent businesses in requesting FAA Administrator Michael Whitaker’s assistance improving support for agency-convened stakeholder committees.
Specifically, the group highlighted three areas of concern:
- Support from the Office of Chief Counsel when legal parameters and requirements are discussed.
- The knowledge of agency personnel appointed to ARAC and ARCs in complying with the Administrative Procedure Act (APA).
- Lack of direct personal acknowledgement from agency executive management personnel responsible for review and implementation, if appropriate, when a committee makes a recommendation.
The letter underscored the importance to aviation safety of “open and transparent communications between the government and the public.” As evidence of industry’s doubt in the agency’s openness and transparency, the letter cited a recent exchange with the Office of FAA Chief Counsel regarding ex parte communications and misaligned expectations for the rule of attorneys supporting stakeholder committees. To address this misalignment, the group requested that government representatives be well trained and “fully engaged in the work the agency has tasked the industry to accomplish.” To address the lack of executive personal acknowledgement of recommendations, the signatories requested those individuals be present at committee meetings when proposals are considered.
To read the complete letter, click here.
In addition to ARSA, signatories from the following organizations – all representatives on various agency committees – supported the letter:
Aircraft Electronics Association
Aircraft Mechanics Fraternal Association
Aviation Technician Education Council
Chromalloy
HEICO Aerospace
National Air Carrier Association
National Air Transportation Association
HAECO Americas
Professional Aviation Maintenance Association
United Airlines
Breaking Invisible Walls at Leadership Roundtables
Industry roundtable participants connect with FAA and EASA representatives (far end of table) during the Oct. 17 meeting.
On Oct. 17, ARSA convened its annual Leadership Roundtables with representatives from the FAA, EASA, and 10 allied organizations joined the association’s board of directors for an afternoon of industry updates and discussion. The meeting series has provided the aviation community an in-person venue for substantive collaboration since 2018.
After a special luncheon for enterprise member representatives and an industry-only session focused primarily on career development needs, the group welcomed American and European regulators. During that final session, FAA Flight Standards Service Executive Director Larry Fields described the agency’s continuing reorganization as a “breaking invisible walls.” The description was an apt metaphor for the meeting’s content, which focused on areas where government oversight limits industry creativity and effectiveness.
Some highlights:
- Both FAA and EASA are working to address misunderstandings about parts documentation requirements associated with work performed under the U.S.-EU bilateral agreement. Upcoming revisions to the agreement’s Annex II and Maintenance Annex Guidance are being finalized.
- The FAA is assessing its procedures for legal interpretation review in light of the recent suspension of its problematic analysis of the “in person” requirement in 43.3(d).
- Both the Flight Standards and Aircraft Certification Services are updating professionalism, safety, and regulatory training for new personnel (see the Workforce Development and Training Report made by the SOCAC for reference).
- The Aircraft Certification Service is reassessing its current guidance regarding remote technology tools and techniques based on experience gathered since the COVID-19 pandemic.
Rob Roedts, ARSA director and Columbia Helicopters vice president of aircraft solutions, speaks during the industry roundtable session on Oct. 17. ARSA Director Jon Silva or AeroKool Aviation, Choose Aerospace Executive Director Crystal Maguire, and ARSA Managing Director & General Counsel Marshall Filler listen on.
The government and industry representatives discussed how agency processes limit inspector flexibility. Rigid approaches to oversight, along with inconsistency across (and within) offices contribute to inefficient compliance and create safety risks. While the agency has cut its still-extended list of applicants awaiting certification, administrative slowdowns and workforce limitations continue to exacerbate issues for those seeking certificates as well as facilities holding them.
The group began the day with a short briefing from Choose Aerospace Executive Director Crystal Maguire. Organized in 2020, Choose Aerospace is a non-profit partnership providing resources to improve the availability of a diverse, qualified technical workforce. Its high school curriculum program has reached almost 1,500 students and provides foundational aerospace competency that can be a model for apprenticeships, career development resources, and recruitment pipelines for the industry.
After wrapping the roundtables, ARSA’s board met privately on Oct. 18 for its annual meeting. The association’s directors elected Bob Mabe of HAECO Americas to serve as the body’s 2025 president, John Riggs of Chromalloy as vice president, and Alison McHugh of FEAM Aero as treasurer. The group approved the 2025 budget as well as an amendment to the association’s bylaws that, among multiple updates, transitioned the association’s top-tier membership category into an “enterprise” election made by the member company.
To read amendment 5 of the association’s bylaws, click here.
In addition to ARSA and its board representatives, roundtable participants attended from the following organizations:
Aerospace Industries Association
Airlines for America
Aviation Suppliers Association
Aviation Technician Education Council
The Boeing Company
Cargo Airline Association
General Aviation Manufacturers Association
International Air Transport Association
Modification and Replacement Parts Association
National Air Transportation Association
NORDAM
Raytheon Technologies Corporation
Regional Air Cargo Carriers Association
For updates from previous roundtables, review the content below.
FAA Suspends Problematic Part 43 Interpretation
On Oct. 15, the FAA responded to a request by ARSA and 15 other industry organizations by suspending a recently released legal interpretation that reversed years of well-established policy and contravened recognized legal precedent to require certificated individuals to be physically present while supervising others.
The problematic interpretation was issued on Sept. 3 in response to a request from Little Rock FSDO Manager Jonathan Moss. In it, the FAA Office of Chief Counsel distinguished physical presence from “mere virtual or remote” oversight as the determining “in person” standard.
“Although the [“Moss” interpretation] was directed at the obligation of mechanic or repairman certificate holders when supervising maintenance activities,” an Oct. 10 industry letter to the FAA said, “its application to the term ‘in person’ has had an immediate detrimental impact on all persons subject to 14 CFR, and the agency that oversees or enforces those regulations.”
The Oct. 10 industry coalition letter requesting the suspension followed a previous request by Savvy Aviation and considerable discussion among and between industry stakeholders. The request included multiple citations to regulatory and rulemaking documents as well as existing case law. It highlighted the agency’s responsiveness during the 2020 pandemic in utilizing permissive performance-based rules to allow the use of remote technology for various supervisory and inspection functions. Overall, the group’s submission urged the chief counsel’s office to focus on the plain language of the rules:
“The only time a mechanic or repairman should be subject to enforcement is if the supervision was insufficient to determine the work was performed correctly. To presume that result before the work is approved for return to service is beyond the plain language of the regulations that allows the certificated person to determine the amount and extent of supervision required.”
The agency responded on Oct. 15 it had issued a stay of the “Moss” interpretation, explaining it will be effective “until such time as the Agency issues new or supplemental guidance.” ARSA and its allies will continue to follow up on their request for industry discussion of the now-suspended interpretation.
To read the industry’s Oct. 10 letter, click here.
To read the FAA’s Oct. 15 response, click here.
In addition to ARSA, the following organizations supported the Oct. 10 industry letter:
Aerospace Industries Association
Aircraft Electronics Association
Aircraft Owners & Pilots Association
Aviation Suppliers Association
Aviation Technician Education Council
Cargo Airline Association
Commemorative Air Force
Experimental Aircraft Association
General Aviation Manufacturers Association
International Air Transport Association
Modification and Replacement Parts Association
National Air Carrier Association
National Air Transportation Association
National Business Aviation Association
Regional Airline Association
Helping FAA Quickly Meet New Foreign Oversight Requirements
On Oct. 4, ARSA joined Aircraft Electronics Association and Airlines for America in confirming for the FAA that new foreign oversight mandates from Congress’ reauthorization law are easily met through existing policy and regulation.
The letter cosigned by the three trade associations addressed the new requirements in 49 U.S.C. § 44733. The letter provided the following analysis of each mandate for the FAA:
(1) Inspect foreign repair stations annually without notification from the FAA consistent with bilateral aviation safety agreements (bilaterals) and the applicable laws of the country in which the repair station is located. (See, § 44733(e).)
The FAA must inform foreign civil aviation authorities to conduct unannounced inspections under its bilateral agreements. It need not notify the repair station subject to inspection. No changes no changes are needed to guidance or procedures to fulfill the statutory requirement when overseeing a foreign repair station in a bilateral country.
(2) Gather and analyze data on heavy maintenance work performed for air carriers. (See, § 44733(g).)
Multiple existing sections in part 121 require the collection, retention, and availability of maintenance data for analysis by the FAA. The agency must require “appropriate actions” by air carriers and repair stations based on any identified safety issue. No change to air carrier procedures is required since the mandate is already met under current regulations through the airlines’ procedures and safety management systems.
(3) Ensure minimum qualifications of supervisors of supervisors and personnel authorized to approve a repair station’s work for return to service. (See, § 44733(i).)
Current guidance can easily be adjusted to ensure §§ 145.153(b)(2) and 145.157(b) requirements are fulfilled by a license or certificate issued by any State signatory to the International Civil Aviation Organization (ICAO) that adheres to Annex 6. The requirements of the annex meet the requirements of the statute for supervisory personnel and those authorized to approve work for return to service under the cited sections. The letter provided suggested language for an update to Order 8900.1.
The letter concluded that the FAA need not change its guidance or practices – with the exception of the suggested small adjustment to its Order – to adhere to the new stator provisions. To read the complete letter, 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.
Legal Briefs
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.
Moss Spotlights FAA Challenges
By Christian Klein, Executive Vice President
The FAA’s Sept. 3 “Moss Interpretation” set off a firestorm that ARSA quickly helped extinguish. The episode points to bigger challenges.
The memorandum from the FAA Office of Chief Counsel was in response to an inquiry from Little Rock FSDO manager Jonathon Moss. The opinion reversed years of well-established policy and contravened recognized legal precedent by requiring certificated individuals to be physically present while supervising others. The interpretation focused on the obligation of a certificated mechanic or repairman supervising maintenance activities, but it had broad implications for the use of remote technologies across the industry.
ARSA and 15 allied organizations quickly responded with a request to suspend the interpretation pending further consideration. On Oct. 15, the FAA responded favorably to that request, staying the interpretation “until such time as the Agency issues new or supplemental guidance.”
It’s easy to speculate about what went wrong within the agency. Though issued by Assistant Chief Counsel for Regulations Laura Megan-Posch (AGC-210), the interpretation was prepared by an “attorney advisor.” The agency, like the industry, is suffering significant turnover; as a result a large percentage of the workforce is new. That’s not necessarily a bad thing, but it becomes a problem for the government and the industry when much of the agency is still working remotely with few opportunities for close supervision, personal interaction, mentoring, and on-premises training.
That the interpretation exceeded the plain language of the regulations is unfortunately no surprise. It is a problem that Congress, at ARSA’s urging, has directed the Department of Transportation Inspector General’s Office to audit. The interpretation also reflected a stunning lack of coordination within the FAA, contradicting myriad FAA policies on the use of remote technologies that have been broadly adopted by industry.
Few missed the irony that just a month after Moss was issued (and before it was stayed), the FAA granted an airline permission to use drones for maintenance inspections. Senior FAA officials have advised ARSA that new internal procedures will ensure future legal interpretations are better coordinated with AVS, the agency’s aviation safety organization.
The episode is another demonstration of FAA’s misunderstanding industry trends and how emerging technologies are being used. The agency was caught off guard by the surge in drone use a decade ago and, more recently, by the roll out of 5G wireless signals over new C-band networks and possible interference with radio altimeters.
To address those challenges, ARSA has been working for years to improve the regulatory knowledge, professionalism, and technological capabilities of the FAA workforce. We’ve advocated for more regulatory training and opportunities for regulators and industry to cross train to enhance mutual understanding. Whether the agency will fully embrace ARSA’s recommendations to avoid future snafus like the Moss interpretation remains to be seen.
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 – The R in Pear
By Brett Levanto, Vice President of Operations
The layman lawyer is completing an exploration of the human factors practice in Safety Management Systems by diving into each element of the PEAR Model.
The primer in the June 2024 hotline introduced the “people, environment, actions, and resources” safety assurance structure. July’s article looked at the “human” performance elements of the model, which exists within the working environment provided by a company and created by its people (August) through their actions (September).
The model concludes with the “resources” available to support the actions of those people and in that environment. ARSA’s Human Factors training provides examples of the resources that must be considered in a repair station environment:
- Computers/Software
- Fixtures
- Hand/Power Tools
- Heavy Equipment
- Ladders/Platforms
- Lighting
- Materials
- Paperwork/Signoffs
- Personnel/Team
- Procedures/Work Cards
- Technical Publications/14 CFR
- Test Equipment
- Time
- Training
The FAA Safety Team’s “Human Factor’s Guide for Aviation Maintenance and Inspection,” explains human factors demands attention to how technician skill balances against the resources available to complete their work.
“In the aviation maintenance world, it would be quite unusual for an AMT to be able to perform a job task without using computers, procedures, tools, test equipment, fixtures, or talking with other AMTs, factory technical support people, etc.,” the Guide says. “All of these ‘other things’ that AMTs use to do their jobs are the focus of the ‘resources’ element of the PEAR human factors model. It is important to identify and understand the resources required for a particular procedure or task. Often, human factors problems arise either because of a poor match between AMTs (and inspectors) and the resources required to perform their job or because required resources are not available in a timely fashion.”
The rules demand appropriate resources. In many instances these demands are explicit, like the requirement for “suitable racks, hoists, trays, stands, and other segregation means for the storage and protection of articles” in § 145.103(a)(2)(iii). Others are more general, as in the requirement that maintenance providers use “materials of such a quality” in the performance rules of § 43.13. Ensuring adequate resources in the form of sufficient personnel, functional facilities, required data, calibrated tools, and an effective quality system are both regulatory and practical requirements.
For tools that can help ARSA members with the translation to SMS, go to arsa.org/sms-program for resources available through a partnership with the Aircraft Electronics Association.
ARSA on the Hill
Control is up for Grabs
By Christian Klein, Executive Vice President
Control of Congress and the White House are at stake on election day and neither party is a clear favorite.
Republicans currently control the 435 member House of Representatives with the narrowest of margins: 220 Republicans, 212 Democrats, and three vacancies. The number of competitive races varies depending on the pundit, but UVA politics professor Larry Sabato’s “Crystal Ball” currently shows 212 House seats leaning Republican, 209 leaning Democrat, and 14 toss ups. Which party will get to the magic 218 majority number is anybody’s guess.
The situation is reversed in the 100-seat Senate, where Democrats hold an equally slim majority. There are only 47 Democratic senators compared with the GOP’s 49, but four independent senators caucus with the Democrats, giving them 51 votes. The Democrats’ Senate majority may be coming to an end. They’re defending 20 seats this cycle (23 factoring in three seats held by the independents) versus just 11 seats being defended by Republicans. Sabato’s Crystal Ball shows 48 races as leaning, likely, or safe for Democrats, compared to 51 for Republicans. The best GOP opportunities are West Virginia and Montana; Ohio is also in play, but there’s no clear favorite.
It’s possible that the Senate will be divided 50-50 in the next Congress, which means whatever party controls the White House would control the Senate because the vice president casts the tie-breaking vote.
There’s little to say about the presidential race. It takes 270 electoral votes to win. The Crystal Ball currently has 226 electoral votes as safe, likely, or leans Democrat compared to 219 for Republicans with 93 electoral votes in the toss up category.
Competitive states are Pennsylvania (19 electoral votes), North Carolina (16), Georgia (16), Michigan (15) Arizona (11), Wisconsin (10), and Nevada (6). If you’re looking for early clues on election night about which way the presidential race is going, watch the three East Coast toss up states, as well as Maine, Virginia, and Florida. The former two are expected to go Democrat, while Republicans are favored in the latter. If a presidential candidate loses in a state in which he or she is favored or loses more than one of the East Coast toss up states, the wind isn’t blowing in their favor.
Election Day is the most sacred day in democracy. It’s a unique opportunity to help determine who is making decisions on your behalf in Washington, D.C. Cast your vote thoughtfully, deliberately, and with both your best personal interests and those of our Republic in mind.
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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. |
Finding Your Member of Congress
In the summer of an election year, senators and congressmen want to meet constituents. ARSA members should take advantage of this interest to schedule facility visits, town halls, meet and greets, or any other excuse to spend time with the person representing your business in Congress.
As ARSA Legislative Day participants hear every year, building an ongoing relationship with your elected officials is really a matter of simple effort. The most successful constituents are patient and persistent…and they know how to use a few simple tools for finding their members of Congress.
Who represents you?
Using ARSA’s Legislative Advocacy Tools – provided all year by Conference sponsor Aircraft Electric Motors – find your elected officials by entering your zip code in the “Election Center.” (Remember to enter your personal zip code and also the one for all facilities associated with your company; there may be multiple officials/offices with an interest in your needs.) Get started at arsa.org/congress.
When will they be home?
Members of the U.S. Congress try to spend as much time in their states/districts as possible. Both the House and Senate leadership have published session calendars for 2024. By reviewing these calendars, you can determine when your senators and congressman are likely to be “back home” by looking for dates not in session. Review the schedule documents below and find updated information at www.congress.gov/calendars-and-schedules.
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What do you do now?
Contact use the contact resources available at arsa.org/congress to get in touch with the offices that represent you and invite them to visit your facility on one of the dates for “district work.” For talking points and other guidance, visit arsa.org/legislative or contact ARSA.
Aviation Life Calendar
September Through March
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 |
| October | All | This Day in Aviation History – October |
| October | 4 | World Space Week |
| October | 20 | International Air Traffic Controller Day |
| November | All | This Day in Aviation History – November |
| November | All | National Aviation History Month |
| November | 8 | National STEM/STEAM Day |
| December | All | This Day in Aviation History – December |
| December | 7 | International Civil Aviation Day |
| December | 17 | Wright Brothers Day |
| January | All | This Day in Aviation History – January |
| January | 9 | National Balloon Ascension Day |
| February | All | This Day in Aviation History – February |
| February | 11 | International Day of Women and Girls in Science |
| February | 18 | National Battery Day |
| February | 16-22 | National Engineers Week |
| March | All | This Day in Aviation History – March |
| March | All | International Women’s History Month |
| March | 1-7 | National Invest in Veterans Week |
| March | 3-9 | Women of Aviation Worldwide Week |
| March | 8 | International Women’s Day |
| March | 18-21 | ARSA Annual Conference |
Training & Career Development
Support ARSA through Advertising and Training Partnerships
ARSA advertisers receive more than business opportunities. Advertising supports the stability of an organization that exists for the international aerospace maintenance industry. ARSA doesn’t diminish the value of advertising, it enhances it.
ARSA ads reach thousands of decision makers, as well as the people who fill positions so desperately needed by most in the industry.
For over forty years, the association’s never-ending pursuit of better regulations and clarity between government and industry has been achieved on a shoestring budget and the team is proud of its success. Through advertising members and others can share in ARSA’s accomplishments.
With the addition of a new Training Sponsorship program, ARSA is moving forward with a broad array of training courses that will add to the 90 sessions already available on-demand. Sponsoring new or available sessions creates visibility for years, while investing in industry knowledge, and bringing the information to company personnel. Sponsoring a course displays your brand prominently for all future training participants while you provide that training to your own employees. There’s no time limit; the course is yours until the regulations that govern it change. Given the typical pace of that process, you’re generally looking at years of exposure.
This unique industry opportunity is another example of ARSA’s commitment to better education for the industry and the government. Sponsoring a training session or having new content tailored to your needs provides an instant return on marketing dollars that will pay dividends for years..
Want to see what’s already in the training catalogue? Click here.
Ready to start the discussion about your training sponsorship? Contact ARSA.
Three-part Series on Aircraft Parts
Get immediate access to Executive Director Sarah MacLeod’s three-session series on the regulations and other requirements affecting the purchase, stocking and sale of aircraft parts.
Regulations Impacting the Purchase of Aircraft Parts
The course reviews the civil aviation regulations in 14 CFR that impact the purchase of civil aviation parts, as well as other requirements that should be considered when making such purchases.
Click here to register and get 90-days of access to the recording.
Regulations Impacting the Receiving, Inspection and Stocking of Aircraft Parts
The course reviews the civil aviation regulations in 14 CFR that impact the receiving, inspecting and stocking of civil aviation articles for maintenance purposes, as well as other requirements that should be considered.
Click here to register and get 90-days of access to the recording.
Regulations Impacting the Sale of Aircraft Parts
The course reviews the civil aviation regulations in 14 CFR that impact the sale of civil aviation articles, as well as other requirements that should be considered when selling parts.
Click here to register and get 90-days of access to the recording.
Interested in all three? Click here to purchase them together and save.
Registration for an ARSA training session includes:
- Access to the on-demand recording of each session for 90 days.
- Digital copies of the presentation and all reference material with links to relevant resources and citations.
- A certificate upon completion of each class.
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 § 21.21, issuance of a TC.
Click here to download the training sheet.
Membership
A Career Enterprise for New ARSA President
ARSA 2025 President Bob Mabe was crew chief of this F-16 during his service in the U.S. Air Force. He chose it to represent his communications in lieu of a headshot. Photo courtesy Bob Mabe.
Bob Mabe, director of regulatory compliance for HAECO Americas, was elected to serve as ARSA’s 2025 President during the Board of Directors’ Annual Meeting on Oct. 18. Entering his first presidency, Mabe joined the ARSA Board in 2020. He was elected to replace retiring director David Latimer and continued HAECO’s active leadership on behalf of both the association and the global industry it represents.
Mabe entered civil aviation in 2007 after serving as an F-16 crew chief in the U.S. Air Force. Following an important career pathway championed by ARSA, he earned his mechanic’s certificate with airframe and powerplant ratings and immediately found work with HAECO in Greensboro, North Carolina. During his first year of civilian service, Mabe received the world’s finest education in regulatory compliance by “interning” with ARSA; his company’s foresight allowed for a stay in Northern Virginia to support the association’s team and learn from its direct engagement with the FAA.
“It was a real indoctrination,” Mabe said of his experience from inside ARSA. “I may not exactly have swept the floors, but I really saw with my own eyes the daily grind put in by ARSA’s team for the industry. It’s been two decades and still it’s the same: Our brand of out-front leadership is based on the getting it right in terms of the rules and making it right for maintainers.”
Having risen to the association’s top volunteer position, Mabe will continue working directly with Executive Director Sarah MacLeod and the ARSA team to push both regulators and businesses to “get it right.”
“The internship experience Bob got has since been called the ‘Naval Academy of Regulatory Compliance’,” MacLeod said after Mabe’s election. “I hope an Air Force guy – an actual working one at that – can forgive the reference to another service, but either way he’s turned into a first-class leader for us all.”
The Board embodies a broad range of international maintenance interests, with directors elected to represent specific industry segments. After several years of transition, the body’s composition remained the same going into the new year: Mabe was also re-elected as a director along with John Riggs of Chromalloy (who will serve as Vice President), and Rainer Lindau of Lufthansa Technik, returning all nine elected members from 2024. Alison McHugh of FEAM Aero, who first joined in 2022, was elected with Mabe and Riggs to the executive committee and will serve as ARSA’s 2025 treasurer.
During its annual meeting, the Board also approved an amendment to the association’s bylaws, including several membership-related revisions. Notably, ARSA’s top membership category was renamed so companies electing to register all constituent parts, divisions, or wholly owned subsidiaries shall collectively be known as “Enterprise Members.”
“Just like the Board, ARSA’s membership structure reflects the industry,” ARSA Executive Vice President Christian Klein said. “The newly approved bylaws include simple updates that better express the overall value and commitment made by those larger entities sharing the association’s value with every part of their business.”
To review the new bylaws, click here.
To see ARSA’s Board of Directors, click here. To meet them and spend time with industry colleagues and regulators, plan to attend ARSA’s 2025 Annual Conference in March.
Budgeting for 2025
Despite inflation, ARSA membership dues haven’t increased in a decade and will remain unchanged in 2025.
Dues are low so members can allocate resources to ARSA programs and services that provide an immediate return on investment to the company and ARSA.
To create your own win-win during the budget season, read and click on the headings.
Aviation regulatory compliance is complicated. ARSA’s online, on-demand training library covering design, production, operations, and maintenance regulatory issues makes it easier. Members can purchase ARSA training for regulatory obligations (for example, the full human factors series), orienting new hires, remedial training, or as a refresher for seasoned employees. Individual classes and package deals are available. Company specific training can be developed which, when conducted under the auspices of the law firm that manages ARSA, affords attorney-client protection to discuss issues specific to your company.
ARSA’s periodicals and websites receive thousands of views per month because of the quality information provded. Whether rolling out new capabilities, looking for talent, or building brand visibility, advertising with ARSA reaches lots of industry professionals looking for quality qualified suppliers while supporting the association.
Each March ARSA’s Annual Conference attracts industry professionals and regulators from around the world. Each member should budget for at least two conference attendees (e.g., bring your potential successor(s) to introduce them to ARSA).
Sponsoring the conference supports ARSA and provides an opportunity to be recognized by international regulators and other industry leaders. Higher level sponsorship includes dinner with ARSA’s board of directors and the exclusive Executive-to-Executive (E2E) meetings with senior officials from multiple executive branch agencies.
Modern Repair Station Manual Compilation
If your company is new to the maintenance industry, ARSA’s model repair station manual compilation is an essential tool for gaining and maintaining an internationally recognized part 145 certificate. Updating an old manual to create and maintain efficiencies and compliance is also made easier through the compilation system. The compilation may be purchased stand-alone or with full customization for your company.
Thanks for including ARSA in your company’s 2025 budget. Remember that your investment in ARSA is an investment in success: your company, ARSA, and the industry are all winners.
New Member Benefit – Purdue Global Tuition Reductions
At its annual meeting in October, the ARSA Board of Directors was briefed on ARSA’s newest member benefit: tuition discounts to association member contacts and their families (spouses, domestic partners, parents, siblings, and children).
The program offers more than 100 programs, including aviation, business, public safety, technology, legal studies, and health sciences. Individuals connected to an ARSA membership can receive tuition reductions in the amount of:
20% on undergraduate programs.*
14% on graduate programs.
Veterans can receive
38% on undergraduate programs.*.
14% on graduate programs.
Active-duty service members receive:
55% on undergraduate programs.*.
17% – 30% tuition reduction on graduate programs.
*Textbooks are included for undergraduate programs.
To learn more and start the enrollment process, visit arsa.org/purdue.
Quick Question – 2025 Conference Planning
March 18-21, 2025
Arlington, Virginia and Washington, D.C.
Event Information | Registration Coming December 2024
The repair station community’s premier substantive event returns; help ARSA’s team plan for the 2025 Annual Conference.
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/ARSAConferencePlan.
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 October:
New Members
Aereos Defense, LLC, R01
DC Roberts Aircraft Co Pty Ltd, R01
David Murphy, EDU
NDT Solutions, LLC, R03
Spectrum Aerospace, Inc., R02
The GlenMark Group LLC dba LW Aerospace, R01
Renewed Members
A Plus Avionics Corp. dba AvionTEq, R01, 2020
Air Technology Engines, Inc., R03, 2006
Aircraft Inspection Services, Inc., R01, 2013
Aircraft Systems Division of Com-Jet Corp, R03, 2011
AirMetrics, Inc., R01, 2019
Air Cargo Equipment, LLC, R02, 2010
Axxeum, Inc., R01, 2023
Aviation & Marketing International, Inc., R01, 2021
Aviation Services of TN Inc., R01, 2023
Columbia Helicopters, Inc., R06, 1998
EuroTec Vertical Flight Solutions, LLC, R02, 2004
HAECO Americas, Corp, 2000
JETTECH, L.L.C., R01, 2021
Midwest Turbine Service, LLC, R01, 2015
MRO Holdings, Corp, 2017
Offshore Helicopter Support Services, Inc. dba DART Aerospace, R02, 2019
Quality Aircraft Accessories, Inc. (Tulsa), R03, 2023
Safran Nacelles Services Americas, LLC, R02, 2017
Schaeffler Aerospace USA Corporation, R02, 2012
Palm Beach Aircraft Propellers, Inc., R02, 2001
Raytheon Technologies Corporation, Corp, 1997
Soniq Aerospace, LP, R01, 2016
Southwind Aviation Supply, LLC, R02, 2008
A Member Asked…Getting into a Scrap?
Q: I need clarification on the government requirements related to the scrapping of aircraft parts. Specifically, are there any regulatory guidelines or legal obligations for how scrapping should be documented, and whether a scrap certification must be provided by the entity performing the scrapping?
Additionally, I have a specific scenario I’d like your insight on:
A company is engaged in purchasing aircraft, disassembling them, and reselling the components in the aftermarket. When parts are sent to repair facilities and determined to be beyond economical repair, the company directs the repair shops to scrap the parts. However, rather than obtaining scrap certifications from the repair facilities, the company issues its own scrap certificates, asserting that they have personally handled the mutilation of the parts.
Would this practice be considered a violation of FAA regulations or any other legal requirements? Could the company potentially face penalties or legal action from the FAA for not obtaining scrap certifications directly from the repair shops?”
A: Good day, and great question! ARSA cannot speak to all “government” regulations, but it can opine on FAA requirements regarding “scrap.” There are no 14 CFR sections that require any method of disposing of “scrap.” Since that term has different meaning to different people, the drafters of the aviation safety regulations took the approach that maintenance includes the “replacement of parts” – thus, one cannot install an unairworthy part. Part 145 quality requirements dictate describing the system and procedures for stocking airworthy parts and material while ensuring unairworthy items are not used or installed (§ 145.211(c)).
The aviation industry has “standards” for disposing of “scrap” – see, for example, the ASA Best Practice Disposition of Unsalvageable Aircraft Parts – Draft Quality Guideline and the AFRA “Disassembly Practice Guide and Minimum Standards – Disassembly-Practice-Guide-and-Minimum-Standards (Rev 4).
With respect to your scenario, without more facts, it is hard to determine the nature of the matter. My question is why would the repair station change its practice of confirming it fulfilled the customer’s requirement to destroy the items determined to be beyond economic repair (BER)?
I imagine the work order is closed out with the same determination and may even be provided to the customer. The repair station can put a process in place that explains how it handles BER articles – return to customer, destroy, or mark for training or testing purposes. The manner of destruction can be documented and explained on the work order and any commercial documents provided to the customer. One of the sample work order forms in the Tools for Members includes the BER close out choices which can be customized with other possibilities and additional information.
Have questions about aviation regulatory compliance, legislative policy, or ARSA resources? Ask ARSA first!
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.
Industry Meetings & Events
| Conference | Dates | Location |
| MRO Australasia | 11/13-14/2024 | Brisbane, Australia |
| NATA Aviation Business Conference | 11/13/2024 | Nashville, Tennessee |
| 2024 UAFA Annual Conference | 11/13-14/2024 | Boise, Idaho |
| AOPA High School Aviation Symposium | 11/17-19/2024 | Atlanta, Georgia |
| VAI Aerial Work Safety Conference | 11/19-21/2024 | Boise, Idaho |
| MRO Latin America | 2/4-5/2025 | Panama City, Panama |
| MRO Middle East | 2/10-11/2025 | Dubai, UAE |
| Aviation Week Supply Chain Conference | 3/12-13/2025 | Southlake, Texas |
| ARSA Annual Conference | 3/18-21/2025 | Arlington, Virginia |
| NBAA Maintenance Conference | 4/29-5/1/2025 | Columbus, Ohio |
| IAQG Meeting Week & 57th General Assembly | 4/7-10/2025 | Brussels |
| MRO Americas | 4/8-10/2025 | Atlanta, Georgia |
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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