Table of Contents
ARSA on the Hill
AVMRO News Portal
Sarah Says – Anything Worth Doing is Worth Doing Again
By Sarah MacLeod, Executive Director
Looking back, you can see ahead. The association will continue to stand tall, work to get the right answers (no matter how long it takes) and ensure regulators and lawmakers do their jobs so you can do yours.
Of course, we learn from experience. The recipe by which we do your work changes: a pinch of coalition building here, a tablespoon of issue development there, a cup or two of persistence and different baking times all to produce the right flavors for engagements with the government. It may not always taste good–but it makes us better.
In aviation, we invariably retrace steps and face challenges many times over. It can be easy to think that we never get anywhere, but doing things right requires repetition and adjustment. The truth is that managing the intersection of business and government isn’t all that different from maintaining airworthiness.
You can replace a part or overhaul a component, and you’ll (hopefully) see it again. Even the best work requires redoing; aviation safety depends on it. The same is true of perfecting the regulatory environment – every time around we get a little better so we can do it more effectively for your benefit.
So, yes, sometimes it’s difficult to tell if you’re looking forward or backwards. That’s why ARSA’s here, that’s how we work. Just like an aircraft returns to service, this association will adjust and readjust its approach to creating better regulations and guidance.
You are a key ingredient in our recipe. Members make this association possible and add force to its calls for change. As you contemplate the New Year, make a resolution to join us in March for the 2015 Legislative Day and Annual Repair Symposium for a taste of the work we do for you.
Registration Open for 2015 Legislative Day and Annual Repair Symposium
By ARSA Communications Staff
Registration is open for ARSA’s 2015 Legislative Day and Annual Repair Symposium. Join aviation professionals from around the world and tackle issues that matter to the maintenance industry.
Legislative Day: Wednesday, March 18, 2015
Annual Repair Symposium: Thursday & Friday, March 19-20, 2015
Location and Accommodations:
The 2015 Legislative Day and Symposium will be hosted at the Ritz Carlton, Pentagon City in Arlington, Virgina. Individual guest rooms may be reserved online using the group code RLYRLYA (book by Feb. 27).
To Register and For More Information:
Please visit the registration page at http://arsa.org/news-media/events/arsa-symposium/. If you have any questions, contact us via email or at 703 739 9543.
Promote your company while showing support for ARSA – sponsor the maintenance industry’s premier event.
Click here to see what sponsorship opportunities are still available.
Need a refresher on past events? Click here.
ARSA Works and So Can You – Association Internship Program
By Brett Levanto, Director of Operations
Obadal, Filler, MacLeod and Klein, PLC, the firm that manages the Aeronautical Repair Station Association, continually accepts law and graduate student applications for its internship program. Interns will gain firsthand knowledge of the legislative and regulatory process and get a behind-the-scenes look at public policy and the impact it has on critical sectors of the economy. Interns will monitor developments in the nation’s capital, draft content for various publications, conduct research on a variety of policy issues, attend industry and congressional events and play a hands-on role in support of the aviation maintenance industry.
Applicants must work well in a team setting and demonstrate independence and initiative in achieving specific tasks and overall objectives, in addition to possessing excellent written and verbal communication skills. Compensation and/or school credit is available, and hours are flexible to accommodate student schedules.
To submit an application, click here.
Saint Louis University Aviation Maintenance/Manufacturing Survey
By Kelsi Oliver, Communications Coordinator
As with any industry, it is important for aviation maintenance stakeholders to evaluate future knowledge, skills and abilities to support the future needs of the flying public. The Center for Aviation Safety Research (CASR) at Saint Louis University is surveying aviation maintenance professionals as part of a research study titled “Next Generation Aviation Maintenance/Manufacturing Competencies” to gather important information of this kind.
The survey will be open until Jan. 9. Approximately six weeks after the survey is closed, results will be posted online at the Center for Aviation Safety Research website. The information gathered for this study may be published in scientific research journals or presented at professional conferences.
Survey results will remain anonymous and researchers will delete identifying information.
Questions about the study can be directed to Damon Lercel at firstname.lastname@example.org or 314-977-8527. Questions about research participant rights can be directed to Saint Louis University’s Institutional Review Board at 314-977-7744.
To begin the survey, click here.
Aviation Workforce – Bridging the NGAP
By ARSA Communications Staff
The major ICAO initiative dedicated to the international aviation workforce crisis finally has a voice for the maintenance community. The Next Generation of Aviation Professionals (NGAP) task force convened in Montreal for its annual meeting on Dec. 1, and ARSA took its seat at the table.
The group’s mission is to ensure that enough qualified and competent aviation professionals are available to operate, manage and maintain the future global air transport system. Director of Operations Brett Levanto joined an international corps of private industry, government and academic representatives to pursue that end.
The task force operates through three standing working groups focusing on research, outreach and programs implementation. These interrelated efforts combine to provide the most comprehensive suite of aviation workforce resources for both employers and aspiring airmen. After participating with both the research and outreach groups, Levanto presented some of ARSA’s tools dedicated to workforce development. He introduced the repair station industry’s web-based information portal AVMRO.arsa.org and offered a sneak peak of the forthcoming AVMRO documentary produced by the association.
Maintenance was also represented by Dr. Raymond Thompson, associated dean of Western Michigan University and representative of the Aviation Technician Education Council (ATEC). In close partnership, ARSA and ATEC are committed to providing maintenance providers the right people to support the future of international aviation.
Too Cool for Flight School? (AviationPros, Dec. 4, 2014)
NGAP Symposium Website
To see all the ways that ARSA is working as the voice of the aviation maintenance industry, visit our ARSA Works page.
ARSA Scores Major Victory with Passage of Aviation Security Legislation
By ARSA Legislative Staff
On Dec. 12, Congress approved the Aviation Security Stakeholder Participation Act (H.R. 1204), which establishes a committee within the Transportation Security Administration (TSA) to offer feedback on the agency’s development and implementation of policies, programs, rulemakings and security directives. The legislation now heads to the president’s desk, where he is expected to sign the bill into law in the near future. The president signed the bill into law on Dec. 18.
As originally introduced in the House by Rep. Bennie Thompson (R-Miss.), H.R. 1204 failed to include repair stations as part of the Aviation Security Advisory Committee (ASAC). However, ARSA’s legislative team worked with Rep. Richard Hudson (R-N.C.) on an amendment mandating repair stations as advisory panel participants. The bill passed the House and was introduced by Sen. Jon Tester (R-Mont.) in the Senate listing “aeronautical repair stations” as ASAC members along with representatives from labor unions, manufacturers, air carriers and passenger advocacy groups.
When the Aviation Security Stakeholder Participation Act is signed into law, the expanded ASAC will provide recommendations to the TSA on ways to remove redundancies and apply a more targeted approach to improving the security of our nation’s aviation network.
“ARSA commends Rep. Hudson, Rep. Thompson, and Sen. Tester for ensuring that repair stations have a voice at the Transportation Security Administration,” said ARSA’s Vice President of Legislative Affairs, Daniel Fisher. “Despite the congressional mandate that TSA regulate repair station security, the aviation maintenance industry was originally left off the Aviation Security Advisory Committee. In the end, common sense prevailed and repair stations look forward to having a seat at the table as aviation security matters are contemplated.”
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ARSA, ATEC Rewrite FAA’s Aviation Maintenance Overview
By Brett Levanto, Director of Operations
On Dec. 10, the Aeronautical Repair Station Association (ARSA) and the Aviation Technician Education Council (ATEC) jointly submitted a rewrite of Federal Aviation Administration (FAA) Advisory Circular (AC) 65-30B: “Overview of the Aviation Maintenance Profession.”
The agency solicited input on the draft AC, which had been revised to include updated maintenance career information and details about military to civilian occupational transfers. As the world’s leading voices for aviation maintenance training and employment, ARSA and ATEC completely overhauled the circular.
“To ensure the government can do its job, we did ours,” said Sarah MacLeod, ARSA’s executive director. “A coalition worked to ensure the AC created an informational resource for the entire aviation maintenance industry; a blueprint for American workers to build a rewarding, valuable career. We invested the hours so the aviation technical community can benefit for decades.”
The trade associations had jointly requested an extension of the original Sep. 10 comment submission deadline. ARSA and ATEC used the time to construct a comprehensive document with references to appropriate regulations, career resources including trade organizations, labor and private industry group resources.
“Our submission tells a compelling story,” said Ryan Goertzen, ATEC’s president as well as president of Spartan College of Aeronautics and Technology. “Aviation maintenance is an innovative, dynamic, prestigious industry that provides employment and careers with potential for limitless growth. Mechanics, technicians, specialists and repairmen enjoy more than competitive pay and interesting work; they guarantee the safety of the flying public worldwide.”
FAA Announces Plans to Release D&A Testing NPRM in 2015
By Daniel Fisher, Vice President of Legislative Affairs
On Dec. 22, the U.S. Department of Transportation released its semiannual regulatory agenda, which includes the FAA’s planned rulemaking activity for 2015.
Of particular importance to the aviation maintenance industry, the FAA anticipates releasing its congressionally-mandated foreign repair station drug and alcohol testing notice of proposed rulemaking (NPRM) in the next calendar year. According to the unified agenda, the agency will analyze comments to the advanced notice of proposed rulemaking through February with anticipated NPRM release later in 2015. ARSA organized aviation industry views and submitted its own detailed comments before the July 17, 2014 deadline.
To learn more about ARSA’s activities on the proposed foreign repair station drug and alcohol rulemaking visit: http://arsa.org/?s=D%26A
8130-3 Forms: “Not for Export” Still Not Required
By Zach F. Bruckenstein, Advocacy Manager
If you are paying attention to ARSA Works, you will not be surprised by the Dec. 8 FAA memorandum reminding inspectors and designees about the appropriate use of Block 12 on FAA Form 8130-3, Authorized Release Certificate, Airworthiness Approval Tag.
When the agency released its original clarification in April, it established that the statements “domestic shipment only” or “not for export approval” are not required anywhere on FAA Form 8130-3. However, the new memorandum indicates that the some designees continue to require those statements on the form.
The new policy reaffirms that the statements are not required in Block 12 and instead cause confusion. The FAA mandates that those authorized to issue FAA Form 8130-3 not add “domestic shipment only” or “not an export approval” to Block 12 of FAA Form 8130-3. The agency also noted that future revisions of FAA Order 8130.21 would incorporate this clarification.
The FAA Enforcement Process … A Practical Primer
By Laura Vlieg, Regulatory Affairs Manager
NOTE: As a tool for its members, ARSA provides a series of web pages dedicated to key regulatory issues. This month, take a moment to explore the newest page and study the FAA enforcement process:
Step 1: Auditing for compliance
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.
Typically the agency notifies the alleged violator of the investigation by issuing a letter of investigation (LOI); however, this is not required. During the investigation, all “evidence” of the potential violation is placed in the EIR. At a minimum, the report will contain the name of the alleged violator, a description of the incident, witnesses, a summary of the incident including specific regulatory noncompliance, all items of proof and the inspector’s analysis and recommendations. The EIR is reviewed first by the local office at which time several results may occur. If the local office believes no violation took place or that remedial action is the best way to handle the matter, the alleged violator will get letters of:
- No action, or
- Administrative action
If the local office does not clear the matter, it will be reviewed by the regional office and any of the following may result:
- Legal enforcement action
- Request for re-examination
- Referral to other authorities for criminal action
What’s next? Visit ARSA’s enforcement process issue page to find out.
ARSA on the Hill
All About That Base
Before moving on completely from the 113th Congress, it’s time to reflect on ARSA’s legislative accomplishments from 2014.
With a “do-nothing” Congress in an election year, it’s easy to expect getting little done as lawmakers focused on campaigning and politics. Specifically to aviation, without an FAA reauthorization under consideration, many of the industry’s top legislative issues were pushed to the backburner. However, that doesn’t mean ARSA’s legislative team was inactive. In fact, the association chalked up some significant victories while, most importantly, laying a solid base for what will be a busy 2015 on the aviation policy front.
ARSA’s evolving legislative program is a sign that the aviation maintenance industry understands what happens on Capitol Hill impacts the ability of repair stations to expand markets, compete and grow. The year started prodigiously when ARSA members stormed the nation’s capital for the most successful Legislative Day in recent memory. Armed with ARSA’s 2014 Global MRO Market Economic Assessment, attendees held over 40 meetings with lawmakers and staff to educate them about the industry and the issues important to repair stations. ARSA PAC continued to raise repair stations’ Capitol Hill visibility by supporting candidates who demonstrated a commitment to free markets, pro-growth tax and labor policies and limited government intervention in private business.
ARSA congressional engagement wasn’t limited to legislative matters. The association’s legislative team was constantly informing Congress about regulatory issues, such as inconsistent regulatory interpretation, the new part 145 rule, the repair station security mandate, and drug and alcohol testing at foreign repair stations. These efforts to engage lawmakers early should pay dividends in 2015 as Congress addresses aviation policy during the FAA reauthorization process.
As ARSA and its membership educated lawmakers through meetings both in Washington and during facility visits, the association scored a triumph when it successfully gained “aeronautical repair stations” inclusion in the Aviation Stakeholders Participation Act (see article in this edition of the hotline). The momentum of this legislative victory combined with ARSA’s active political program and member involvement should serve as the foundation for a successful 2015.
The coming year is shaping up to be a busy one for aviation policy, but the base is laid for success on Capitol Hill. The FAA reauthorization process will undoubtedly pose significant threats to repair stations while also providing opportunities for positive reform. Continued industry engagement is critical to ensure contract maintenance is at the table, not on the menu. ARSA is your voice, but we need continued engagement from the entire industry to succeed.
Can we count on your legislative advocacy in 2015? Much of the groundwork is done; now let’s finish the job!
Updated Repair Station Quality Manual Released
By Laura Vlieg, Regulatory Affairs Manager
Now that the new repair station rule is effective, repair stations must ensure operations manuals are also revised as appropriate. ARSA has updated its model repair station and quality manual in order to reflect the changes to part 145 as follows:
- Added falsification of records policy as provided for in § 12
- Added the requirement that the FAA accept the repair station’s certificate surrender pursuant to § 55
- Renumbered and updated cross-reference table to ensure new provisions are addressed
Specific changes are provided in tracked excerpts of the manual here.
For more information, or to obtain the latest version of the model manual, 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.
Editor’s note: The views and opinions expressed by contributing authors do not necessarily state or reflect those of ARSA and shall not be used for endorsement purposes.
Enhancing MRO efficiency through Technology – Part II
By Mohan S Perumal, Ramco Systems. © 2015 Mohan S Perumal ALL RIGHTS RESERVED
Welcome back to this series of articles on using technology to enhance MRO efficiency.
We refocus on the importance of adding efficiencies to MRO’s most important resource – the mechanic. Any tool that maximizes mechanic ‘wrench time’ will positively impacts the bottom line.
In the first article we used the example of the evolution from ‘tags’ to ‘bar code readers’ and to ‘QR Code & RFID’ technology.
Let’s now look at the case for ‘creation and management of paper work.’ The following is a pictorial of the evolution in this process.
Obviously, each piece of paper represents an important and normally mandated, record. The MROs must also safely and properly store those pieces of paper for a required period of time.
This means massive storage and retrieval systems. Storage cabinets (like the picture on the left) are used in many repair stations. These should be fireproof and well-protected against potential accidents and disasters. While cabinets are simple tools for meeting paper storage requirements, they have disadvantages.
As the businesses grow, storage and retrieval of physical copies becomes increasingly costly and inefficient. Moreover, it is extremely hard to trace a trend or specific issue. The data cannot be systemically searched and answers to many maintenance-related questions lay buried.
OCR (optical character recognition) technology which allows scanning the hand written and paper documents resolved some disadvantages. Critical documents can be scanned into PDF (portable document format) files. This helps to digitize and capture the mechanics’ hand written data while reducing physical storage spaces and enabling quick storage and retrieval.
The scanning solution still has one major disadvantage: the data cannot be processed for information. Specific words and phrases could be searched, but analytical reporting options and other detailed examination fell into the void.
The emergence of technology designed for aviation maintenance enables direct data entry by mechanics and inspectors into online systems, bridging the vital analytical. Useful reports are a click away. For example: how many times did we find the same issue? How many times does the need for repair on a specific part turn into an overhaul? Quick access to this data help the repair station become more pro-active in both planning and customer consultation. Warranty processing is a great example: a part can be tracked through purchase, installation, use and removal. Issues and wear can be recorded and even photographed to submit for the processing of the warranty.
Some of the key advantages:
- Data is entered once, and at the source.
- Entered data is instantly available for review.
- Data can be processed and analyzed directly from storage.
As we did before, let’s consider banking and credit card systems. Our pay is received electronically (no more “checks”); money is directly transferred to from the employer to your bank account of choice. You can then move money among and between accounts and pay bills—all electronically. Online interfaces allow you to see the money flow almost immediately; you can also pull reports and analyze what is spent against what is saved. Simple apps on your mobile device help you categorize your spending into buckets – travel, dining, groceries, gas, investments, etc.
Returning to the repair station, once the systems and applications are available to the mechanic, analyzing performance at a granular level is possible.
Personal Development – How to detect and protect against workplace bullying
By ARSA Communications Staff
The aviation maintenance workplace is a challenging environment. The stress of customer demands, regulatory constraints, safety requirements and the daily business of keeping the world in flight can be a lot to bear. In order for repair stations to operate at the highest level, workers must be able to thrive together in this demanding environment.
How does your team work together? Learn how to detect and protect against workplace bullying with this feature from our friends at Director of Maintenance Magazine.
“Teaching You How to Fish” – Using Congress to Influence the Regulatory Process
By ARSA Communications Staff
Access to regulatory, business, and legislative knowledge is one of the key benefits of ARSA membership. We are standing by for your calls, questions, or clarifications. The association will go a step further, though, and give you the tools to build your own knowledge before the problem even arrives.
Our recorded webinars and training sessions are one way ARSA will “teach you how to fish.” They’re all waiting for you; you can start a session right now.
“Using Congress to Influence the Regulatory Process,” by Daniel Fisher, ARSA’s vice president of legislative affairs. Remember, Congress has the resources to help, in the long term, with problems that repair stations face every day. How do you get the world’s most famous deliberative body to help you? View the training session and learn Fisher’s favorite methods.
Regulatory Compliance Training
Test your knowledge on § 145.203 – Work performed at another location.
Member Spotlight: Av8 MRO – Houston, Texas
By Kelsi Oliver, Communications Coordinator
Somewhere between the time the Waterford Crystal ball dropped in Times Square on New Year’s Eve to ring in 2014 and the confetti blasters fired up again for the brilliant globe to hit 2015, Av8 MRO joined ARSA.
Before arriving on our member list, Av8 invested heavily in developing skills and and translating them into a successful business. Thirty-five years ago, Yoel Arnoni, Mike Washburn and Russell Eckhart, Av8’s three principals, began individually working on Hawker landing gear. Five years later, the three combined their talents to create a company.
Av8 MRO is FAA and EASA certified and their employees are some of the world’s experts on Hawker landing gear. As ARSA wraps up 2014, we have many things to celebrate as we charge into the calendar ahead. We are especially thankful that repair stations, like Av8 MRO, continue to perceive our value, wear our logo and help us to serve the needs of the entire aviation maintenance industry.
ARSA is gr8ful 4 members like Av8. Your cre8ivity inspires us!
Are you an ARSA member who would like to be in the “Member Spotlight?” If so, please contact Kelsi Oliver at Kelsi.Oliver@arsa.org.
Each month, the hotline spotlights key regulatory, legislative, and business leaders making important contributions to the aviation industry. This month we look at U.S. Congressman Sam Graves (R-Mo.).
Congressman Sam Graves (R-Mo.)
Congressman Graves is a member of the Congressional General Aviation Caucus, a group formed in the U.S. House of Representatives in 2009 to inform members and staff about the importance of general aviation to the nation’s economy and transportation system. Led by leaders like Graves, policymakers, industry groups, airline representatives and aviation business partners have already started talk of the FAA reauthorization coming up in 2015.
During his keynote address at a Sept. 18 gathering at the National Press Club in Washington, D.C., Graves noted the 23 extensions required when FAA policy was last set in 2012 and expressed “the last thing we want is another reauthorization like we had last time.” He is very involved in aviation as a member of Congress and as we work toward a better FAA Reauthorization Bill, Graves is certain to be a key player in the process.
Graves serves on the Transportation & Infrastructure Committee and the Small Business Committee and is a sixth-generation, full-time family famer dedicated to making Missouri a better place to live, work and raise a family.
Click here to read more about Representative Graves.
Take Advantage of ARSA’s Members Getting Members Program, Get 10% Off on Membership Dues
The best form of advertising is word of mouth. Use the Members Getting Members Toolkit to recruit an ARSA member and your company will receive a discounted membership rate for your next membership term. Get more information at http://arsa.org/membership/members-getting-members/
Target Your Message: Advertise Today in ARSA’s Newsletters and Website!
ARSA recently updated its 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 http://arsa.org/advertise/
Exhibit, Sponsor the 2015 Repair Symposium
As the maintenance industry’s top event devoted exclusively to regulatory compliance, the ARSA Symposium attracts a highly qualified professional audience. Use this opportunity to promote your company while showing support for ARSA. Get more information at http://arsa.org/news-media/events/arsa-symposium/arsa-annual-repair-symposium-sponsorship/
Q: Our repair station recently received a notice of proposed civil penalty from the FAA based on a letter of investigation received during our annual audit. This is the first time we have dealt with this situation. Would you provide guidance on how to proceed and tell us the options of how to respond to the FAA?
A: Once a notice of proposed civil penalty (NPCP) is received, the ‘legal enforcement” process starts, as explained in 14 CFR part 13 and Order 2150.3.
Upon receiving the NPCP, ARSA recommends that the company:
- Request releasable portions of the enforcement investigatory report (EIR) developed during the audit/investigation and the basis for the NPCP.
- After receiving and digesting the EIR, request an informal conference with the FAA lawyer (and his/her specialist).
Right before the informal, a “smart letter” should be written explaining the company’s position on each allegation for discussion during the informal. This letter should address the facts of the allegations versus the regulations, explain and attach favorable or correct facts, defenses and the mitigating steps taken by the company to address any potential non-compliance. However, it should not “admit” any wrongdoing. It should also address any applicable small business aspects of the assessment.
For more information on the FAA enforcement process, visit ARSA’s issue page.
AVMRO News Portal
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.
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.
The FAA is very concerned about counterfeit aircraft parts. They call them Suspected Unapproved Parts (SUP). Having any in your inventory could be a legal disaster!!
- There is only one centralized DataBase of Suspected Unapproved Parts – Over 60,000 of them. Find the ones on your shelves before the FAA fines you.
- There is only one integrated PMA/AD System. Find ADs that apply to or reference any of almost 1,000,000 PMA parts. Do multi-level PMA research.
- Due Diligence is the key phrase and The Aviation DataBase® is the only source for an easy and inexpensive way to do it. Head off the legal problem before it occurs.
- There is a User friendly and searchable copy of the Flight Standards Information Management System (FAA Order 8900.1) in The Aviation DataBase®.
- Do you need an Aviation Regulatory Library?: Over 18,000 ADs – Large & Small AC, Over 1,500 Type Certificate Data Sheets, Over 1,200 FAA Advisory Circulars.
- Call Aviation DataSource, Inc. (800) 952-8844.You can be using The Aviation DataBase® within minutes.
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 http://arsa.org/membership/join/.
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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.
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© 2015 Aeronautical Repair Station Association