ARSA & AEA Release SMS Guidance for U.S. Repair Stations

On Dec. 18, ARSA and the Aircraft Electronics Association (AEA) jointly released and industry advisory for U.S. repair stations holding EASA approval under the U.S./EU bilateral aviation safety agreement needing to implement a Safety Management System. To produce the advisory, ARSA relied heavily on (and is grateful for) AEA’s continued focus on documenting risk analysis.

The advisory document offers clear, concise guidance to the international maintenance industry on establishing and retaining compliance with the special conditions contained in the maintenance annexes in bilateral aviation safety agreements. It is part of the associations’ ongoing collaboration to support global aerospace maintenance safety. The guidance includes regulatory references and basic instruction for integrating SMS into an existing air agency certificate holder’s quality system.

The associations have shared the advisory with the FAA, reminding the agency of its enforcement discretion. Under the agency’s compliance program, the government could recognize the realities facing repair stations holding EASA approval under the bilateral and utilize administrative action for findings related to manual updates. Certificate holders should review and update their own procedures (if necessary) for manual control and revisions to prevent future complications in the timely institution of new required policies or procedures.

The advisory is available as part of ARSA’s free “tools for members.” To request your updated copy, which is delivered as a .zip file containing the “tools,” complete the order form at arsa.org/publications.

Click the logo to go to the publications page.

Tools for ARSA Members| RSQM Compilation| Order Form|FAQ

Interested ARSA members should learn about access to SMS tools available through the association’s partnership with AEA and participate in the associations’ series of free webinars covering SMS integration.

Canadian Compliance Matrix Updated Ahead of New MIP’s Effective Date

On Sept. 9, the FAA and Transport Canada Civil Aviation (TCCA) released revision 2 of the Maintenance Implementation Procedures (MIP) issued under the bilateral aviation safety agreement between the United States and Canada. The new MIP becomes effective on Jan. 7, 2026.

The fully-reciprocal nature of the bilateral allows FAA-certificated repair stations and TCCA approved maintenance organizations to work on aircraft registered under each jurisdiction without  holding an additional certificate or approval. The MIP requires U.S. based repair stations performing such work to comply with the special conditions of the agreement.

ARSA has updated its cross-reference matrix supporting compliance of U.S. repair stations with those special conditions. The matrix includes a “red-lined” version showing edits between revisions 1 and 2. The matrix is available as part of ARSA’s free “tools for members.” To request your updated copy, which is delivered as a .zip file containing the “tools,” complete the order form at arsa.org/publications.

Click the logo to go to the publications page.

Tools for ARSA Members| RSQM Compilation| Order Form|FAQ

SMS Integration Webinar Series Continues Jan. 20

On Dec. 16, ARSA and the Aircraft Electronics Association presented the third of six planned webinars – a monthly series stretching into March 2026 – explaining effective integration of a safety management system within the operations of an FAA-certificated repair station. These hour-long virtual sessions will help U.S.-based repair stations holding European approval to implement a part 5 compliant SMS programs as required by the special conditions of the bilateral agreement between the United States and European Union. This requirement to “design, implement, and maintain” an SMS should be met by effectively and efficiently integrating SMS into the facility’s existing quality system and daily operations.

The session materials and recording from completed webinars are available within the SMS tools managed by AEA and available for discounted access to ARSA members. Interested participants should mark their calendars for the remaining sessions, each beginning at 1:00 p.m. Eastern Time:

• October 29, 2025 – SMS Integration Overview – COMPLETE
• November 18, 2025 – SMS Compliance Elements: Part 5 Subparts A & B – COMPLETE
• December 16, 2025 – SMS Compliance Elements: Part 5 Subparts C & D – COMPLETE
• January 20, 2026 – SMS Compliance Elements: Part 5 Subparts E & F – REGISTER NOW
• February 10, 2026
• March 10, 2026

Session 4

Title: SMS Compliance Elements: Part 5 Subparts E & F
Date: Tuesday, Jan. 20, 2026
Time: 1:00pm – 2:00pm EST
Registration: Click here.

For more information about webinar logistics, contact Ric Peri, AEA vice president of government and industry affairs, at ricp@aea.net.

Interested ARSA members should learn about access to SMS tools available through the association’s partnership with AEA:

New ARSA Advisory Supports Mobile Workforce

In December, ARSA produced a new association advisory to support labor mobility in the international aerospace maintenance industry. The document substantiates the value of technically skilled individuals to aviation employers and the importance of their service to the world.

“The industry faces a crisis: Finding, recruiting, and retaining professionals with the requisite trainability, skill, character, and focus is the most pressing strategic challenge facing the businesses charged with maintaining civil aircraft and safeguarding the flying public,” the advisory explains.

Providing industry references and regulatory citations, the advisory describes the personnel requirements, demand, economics, and general statement of industry need for technicians and other skilled professionals. It can be used to support any workforce related initiative, including:

(1) Lobbying local, state, or national governments for supportive resources or policy.

(2) Grant applications.

(3) Recruitment, including outreach to schools and community groups.

(4) Immigration efforts associated with aerospace employment.

The advisory is now available inside the complete bundle of free “tools for members” available from the association’s publications department. Learn more about all of ARSA’s publications (including the “tools for members”) by following the links below or going to arsa.org/publications.

Click the logo to go to the publications page.

Tools for ARSA Members| RSQM Compilation| Order Form|FAQ

Welcome & Welcome Back – New & Renewing Members [Full Year]

ARC145, LLC, R01
Aviation Repair Group, LLC, R01
Axcess Aviation Maintenance Services, Inc., R02
FACC Solutions, Inc., R03
FLG Technics, Inc., R02
MHI RJ Aviation Group, R05
QT Aerospace, LLC, R01
Tulsa Aerospace Component Overhaul and Repair Inc., R02

February

Aero Accessories, LLC, R01
Aerotech of Louisville LLC, R02
Alcor Inc., Assoc
California Radomes, Inc, R02
Consolidated Fuel Systems LLC, R01
Integrity Testing & Safety Administrators, Inc., Assoc
Precision Airmotive, LLC, R02

March

Aerocopter Component Services Ltd., R01
Cirrus Design Corporation, Assoc
HIGH CLASS MRO INC, R01
Redline Aviation Inc, R01
RexAir Maintenance, LLC, R01
Santa Monica Propeller Service, Inc., R01
Up North Aerospace Solutions LLC, R01

April

AOG Aviation Spares LLC, R03
Alliance Aeronautical Composites, LLC, R01
Audacity Aviation, R01
Corporate Air Parts, Inc., R03
DRJ Technologies, R02
Global Engine Maintenance, LLC, R04
LF Avionics, Corp, R01
Servotronics, Inc., R01
Turbo Technologies, L.L.C., R02
Tym’s LLC, Affil

May

Jet Air MRO, LLC, R02
Tassili Airlines, R05

June

July

Astrodyne International, Inc., R01
Charles Samsel, Affil

August

Aero Propulsion Support, Inc., R01
Aero-Craft Hydraulics, Inc., R01
Aviation Brake Services, Inc., R02
California Precision Hydraulics, Inc., R01
TIC Aerospace, Inc., R01
Triumph Actuation Systems – Yakima, LLC, R03
Triumph Actuation Systems – Valencia Inc., R01
United MRO Group, LLC, R01

September

Airframe Maintenance Group LLC, R01
Airline Accessory Service Company, LLC, R02
Bernoulli Aerospace, LLC, R01
Carrlson, Daniel, Mil
ITT Aerospace Controls LLC, R02
Mid-Jet Repair, LLC, R02
MRO Technologies, LLC, R01
MT-Propeller Gerd Muehlbauer GmbH, R04
Rice Lake Weighing System dba Measurement Systems International, R01

November

Heritage Turbines, Inc., R01
MeasureTech, Inc., R01
Rapid Imaging Solutions, LLC, R01
Rover Aerospace, Inc. dba Altima Technologies, R01

December

Acron Aviation, Inc.  , R04
Aircraft Interiors Unlimited Inc., R01

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Our 2025

Each story will take you to the hotline in which it appeared (which means readers should beware the timeliness of references and follow up on key issues).

Leading Off

Board Reports

Each quarter the board of directors receives reports on the association’s activities and fiscal health. The subsequent edition of the hotline invites members to step into a board member’s shoes with an overview of the financial, operations, legislative, and regulatory reports highlighting advocacy on behalf of aerospace safety.

To see each report of “what ARSA has done lately,” click the headlines below.

First Quarter 2025

Second Quarter 2025

Third Quarter 2025

Fourth Quarter 2025 – Check out the January 2026 edition.

ARSA Works

U.S. Bilateral Update Requires SMS Compliance

February: On Feb. 10, the Bilateral Oversight Board for the U.S.-European Union bilateral aviation safety agreement issued Decision No. 13. It amends BASA Annex 2 to require U.S.-based repair stations with EASA approval to establish, implement, and maintain a Safety Management System.

SBA Pushes DOT on ARSA OpSpecs Recommendation

May: On May 5, the U.S. Small Business Administration’s Office of Advocacy submitted comments to the Department of Transportation’s regulatory reform request for information. The comments compiled small business issues from across transportation modes, leading its aviation section with multiple recommendations based on ARSA’s analysis of countless Operations Specifications Requirements without regulatory authority.

Drafting Regulatory Purpose into Order 8130.21

June: On June 17, ARSA and the Aircraft Electronics Association jointly submitted a rewrite of the FAA’s Draft Order 8130.21J, “Completion of FAA Form 8130-3 under 14 CFR part 21.” The submission overhauled the FAA’s draft to make clear the different sections and paragraphs of the production rule under which the form is used to issue an airworthiness approval or an authorized release.

ARSA Tool Supports “Traceability” and “Conformity” for U.S./EU Bilateral Compliance

July: The updated “New Article Inspection Form” template supports compliance by U.S. repair stations holding EASA approval under the U.S./EU bilateral agreement. The new FAA/EASA Technical Implementation Procedures made the update possible by clarifying parts acceptability language for components consumed in maintenance for which a dual release will be issued.

Support Simplifying New D&A Rules

November: On Nov. 26, ARSA submitted a petition for reconsideration of its denied petition to improve compliance, oversight, and enforcement of the FAA’s new rules requiring drug and alcohol testing programs at foreign repair stations. The new submission doubles down on the public’s interest in facilitating compliance for repair stations supporting global operations.

Legal Briefs

Layman Lawyer – Damming the Flood

January: The arrival of the Trump administration quickly brought the administrative disruption promised during the president’s campaign. The White House effort to “Flood the Zone” with executive action has the public, media, and particularly U.S. federal employees off balance. While the administrative dust settles, the association will stay the regulatory course by focusing attention on the Jan. 31 executive order “Unleashing Prosperity Through Deregulation.”

Not So Secret Agent

April: Last October, the FAA issued its U.S. Agents for Service rule. Codified at 14 CFR part 3, subchapter C, it requires certain individuals without a physical U.S. address that hold or apply for FAA certificates, ratings, or authorizations to designate a U.S. agent for service of FAA documents.

D&A Complexity

June: Regulators are waking up to the significant compliance challenges associated with the FAA’s new foreign repair station drug and alcohol rule. The congressionally mandated rule requires FAA-certificated repair stations outside the United States whose employees perform safety sensitive functions on part 121 air carrier aircraft to have a testing program in place by Dec. 20, 2027. Some compliance flexibility is available for proactive organizations.

When Government Closes a Door, Pound on a Window

August: The FAA must resist the temptation to bury its head in the sand. Given that safety regulations are simply best practices with the force and effect of law, ongoing public engagement by agency personnel is essential… and will take place whether the FAA wants it or not.

Say What You Mean

September: Some widely used terms in aviation cause confusion. Among the worst culprits is “original equipment manufacturer” or “OEM.” The term is widely used but has no established regulatory meaning.

Layman Lawyer – A Lonely Regulatory Word

September: In September, the FAA channeled Billy Joel in its final rule consolidating the many falsification-related sections across 14 CFR into the new part 3, subpart D. Just like Joel doesn’t want “some pretty face to tell [him] pretty lies,” the FAA needs “someone to believe” in the basic definitions surrounding falsification and fraud.

ARSA on the Hill

It Only Takes One

April: The association advocates on the legislative and regulatory fronts to ensure legislation is implemented both efficiently and as intended. Even when the president signs a new FAA authorization bill into law (as President Biden did last spring), the ARSA’s work doesn’t end.

Sucking the Air Out of the Room

May: On May 14, the Senate Commerce, Science, and Transportation Committee convened a hearing reviewing implementation of the FAA Reauthorization Act of 2024. One year since the law’s enactment, the hearing demonstrated how aerospace policymaking attention has been captured by the FAA’s struggle to manage resources and technology supporting the nation’s air traffic control system.

Grantham Gets Cycle’s First ARSA PAC Contribution

June: Air Force and aviation industry veteran Travis Grantham, a candidate for Arizona’s fifth congressional district, has received the first ARSA Political Action Committee contribution of the 2026 election cycle. Grantham is running as a Republican to replace Rep. Andy Biggs, who is retiring from Congress to run for Arizona governor.

Senate NDAA Tackles Maintenance Data Access

July: Policymakers are looking closely at the U.S. Department of Defense procurement practices that restrictive maintenance data access.

From Legislation to Regulation – Tenacity is Key

August: ARSA’s congressional lobbying began two decades ago when it was obvious that FAA doesn’t operate in a vacuum. Flawed laws based on flawed assumptions yield flawed regulations. Even good and clear legislation can be misinterpreted by the agency or wind up as a low priority. That’s why ARSA’s holistic advocacy focuses on the entire process.

Regulatory Updates

FAA and EASA Message: SMS is Here December 2025

January: ARSA continues to warn both agencies about the risks for enforcing compliance shortly after the official publication (assuming there is one in 2025) of any new requirement. While the association will push for an extension of the enforcement date, American members holding EASA approval under the bilateral must prepare to comply.

Security and the Supply Chain

May: In May, the U.S. Department of Commerce announced it had opened a national security investigation on the import of commercial aircraft, engines, and component parts. On June 3, ARSA responded to the government’s request for public comments addressing the criteria defined in 15 CFR § 705.4 for determining the effect of imports on national security.

MAG Compliance Matrices Updated

June: Following the publication of change 10 to the FAA/EASA Maintenance Annex Guidance, ARSA updated its cross-reference matrices for tracking bilateral compliance. The matrices provide a method to compare quality system/manual elements against the (1) special conditions and (2) supplement guidance included in the updated MAG.

FAA Confirms SMS Compliance Dates Under U.S./EU Bilateral

July: ARSA and multiple industry allies engaged the FAA after the June 20 publication of the MAG, noting it was unclear regarding compliance between the Oct. 10 effective date of change 10 and the previously-reported deadline requiring SMS compliance before the beginning of 2026.

FAA Stays True to Falsification

September: On Sept. 3, the Federal Register published the FAA’s final rule consolidating the many falsification-related sections across 14 CFR into the new part 3, subpart D.

Training & Career Development

Membership

Renewal and Reinvestment

April: ARSA members show continual support by renewing their membership, and they do so at a consistent 90 percent rate.

Honoring NFF Aviation Services’ Masters

May: On May 12, ARSA regular member NFF Aviation Services announced five of its technicians had been awarded the FAA’s Charles Taylor Master Mechanic Award. The award recognizes the lifetime accomplishments of senior mechanics, honoring professionals with 50 years or more of civil and/or military maintenance experience.

Advertising – Flexibility

July: ARSA’s periodicals and websites provide first and last minute announcements at reasonable prices and lengths. Flexible advertising terms and statistical feedback on ad engagement allows targeting around key activities.