Sarah Says: A Glance Back
As we enter 2014, the association takes the opportunity to review the most visible contributions to its members’ continued viability during the past year. To read MacLeod’s blog, as well as other commentary issued during the month of December, please visit http://blog.arsa.org/?p=288.
Register for 2014 Annual Repair Symposium
On March 19-21, ARSA will hold its Legislative Day on Capitol Hill and Annual Repair Symposium in Arlington, Va. Join aviation professionals from around the world to connect with officials from the FAA and other aviation authorities, as well as key members of Congress and your colleagues in the industry. Read more at http://arsa.org/register-for-2014-annual-repair-symposium/
Different Year, More of the Same
As 2013 came to an end, the aviation maintenance industry is once again left in limbo as repair station security rules aren’t finalized and the prohibition on FAA certification of new foreign repair stations endures. Read more at http://arsa.org/different-year-more-of-the-same/.
New Guidance Available
In response to concerns that the Federal Aviation Administration (FAA) aviation safety inspectors were not uniformly auditing repair stations, standardized checklists have been developed. These documents are not being used by the FAA workforce yet, but will be officially introduced in the near future. Read more at http://arsa.org/new-guidance-available/.
The Custom Agent’s Always Right?
While tariffs and taxes won’t go away, ARSA members are increasingly complaining about interactions with customs and freight forwarders, resulting in increased expenses and time wasted. Read more at http://arsa.org/customs-agents-always-right/.
ARSA Joins CRI ARC Letter
After a memorandum dictating the cancellation of all unofficial guidance issued by policy offices in the FAA was revealed, ARSA joined other industry representatives on Dec. 18 in a letter asking for a withdrawal or delay of the directive until a comprehensive manner of gathering, reviewing, and coordinating policy vis-à-vis the regulations is developed. Read more at http://arsa.org/arsa-joins-cri-arc-letter/.
Senate ASAC Bill Includes Repair Stations
On Dec. 11, Sen. Jon Tester (D-Mont.) introduced the Aviation Security Stakeholder Participation Act (S. 1804), companion legislation to H.R. 1204 which overwhelmingly passed the U.S. House of Representatives on Dec. 3. Read more at http://arsa.org/senate-asac-bill-includes-repair-stations/.
ARSA: Johnson Must Make Repair Station Security Rules Immediate Priority
Christian Klein, ARSA executive vice president, issued a statement in response to the Senate confirmation of Jeh Johnson as secretary of the U.S. Department of Homeland Security. Read more at http://arsa.org/arsa-johnson-must-make-repair-station-security-rules-immediate-priority/.
Budget Deal Increases Security Fee
On Dec. 12, the U.S. House of Representatives approved the Bipartisan Budget Act of 2013 in strong bipartisan fashion, 332-94. The bill now heads to the Senate as lawmakers try to prevent a new round of automatic spending cuts known as sequestration and preempt a last-minute fight over funding priorities for the new year. Read more at http://arsa.org/budget-deal-increases-security-fee/.
ARSA Condemns FAA Overreach
The association recently warned the FAA its disregard of basic requirements for promulgating a safety regulation required an immediate withdrawal of a notice of proposed rulemaking. Read more at http://arsa.org/arsa-condemns-faa-overreach/.
ARSA, TeamSAI Join Forces to Measure Industry Impact
ARSA announced a new strategic partnership with TeamSAI, an aviation consulting firm specializing in strategic, tactical and operational management solutions. The new relationship will combine ARSA’s industry knowledge and policy expertise with TeamSAI’s data-driven forecasting to create regular, high quality economic analyses of the global aviation maintenance sector. Read more at http://arsa.org/arsa-teamsai-join-forces/.
Foreign Repair Station Drug Testing Rule at OMB
The Office of Management and Budget is reviewing a proposed rule from the FAA that will impact foreign repair stations. Read more at http://arsa.org/foreign-repair-station-drug-testing-rule-at-omb/.
FAA Responds to ARSA Concerns on Order 8130.21H
On Dec. 2, the FAA responded to a letter ARSA sent on Nov. 19 concerning the prohibition on early compliance of FAA Order 8130.21H, specifically the ability to use the revised FAA Form 8130-3 before its Feb. 1, 2014 effective date. Read more at http://arsa.org/faa-responds-to-arsa-concerns-on-order-8130-21h/.
ARSA’s Eric Byer announces he accepted a leadership position with the National Association of Chemical Distributors beginning on Jan.1, 2014. Read blog post at http://blog.arsa.org/?p=282.
To read ARSA’s other blog posts, be sure to visit http://blog.arsa.org/.
By Daniel Fisher, ARSA vice president of legislative affairs
In December, ARSA’s legislative team began turning its focus to the new congressional session.
At the top of the legislative agenda remains the lift the ban campaign. Another year passing without the repair station security rule and the foreign repair station certification ban in place is unacceptable. In consultation with ARSA, the industry’s Capitol Hill allies are preparing a legislative solution for early in 2014.
The new year also brings preparations for the next FAA reauthorization process. Congressional leadership is starting to lay the groundwork for the next FAA bill and ARSA is in the early stages of formulating proposals for the legislation. Is there an issue the association should address in the reauthorization bill? Let us know at email@example.com.
It’s also time for ARSA PAC to lift off for the mid-term elections. The industry’s success on Capitol Hill depends upon ensuring our biggest supporters have the campaign resources to successfully return to Congress. We are implementing a PAC strategy that focuses on the key races and supporting lawmakers who have demonstrated leadership on the industry’s top priorities. Ensuring our friends get through an increasingly difficult primary process is a crucial aspect of our plan. In order to learn more about ARSA PAC, please provide your solicitation consent today!
In December, ARSA delivered PAC support to Rep. Steve Daines (R-Mont.). A member of the House Transportation & Infrastructure Committee (including the Aviation Subcommittee) and the House Homeland Security Committee, Daines is the frontrunner to succeed retiring Sen. Max Baucus (D-Mont.) as Montana’s next senator.
MAG Change 3 – What You Need to Know
By Crystal Maguire, ARSA vice president of operations
The MAG, originally issued on May 3, 2011, provides detailed guidance for FAA-certificated repair stations located in the U.S. to obtain an EASA certificate (and visa-versa) under the U.S./EU Aviation Safety Agreement. The guidance contains three sections addressing regulatory authorities, U.S.-based repair stations, and EU-based approved maintenance organizations. The first revision was signed on Jan. 10, 2012, and the second revision is dated Oct. 31, 2012.
EASA-certificated U.S.-based repair stations must ensure implementation of all required changes by Feb. 25, 2013 (90 days from the MAG Change 3 effective date). The most notable changes, some of which may require an update to the repair station’s EASA supplement, include—
- A statement that a repair station cannot exercise EASA approval privileges after the EASA certificate expires. If the repair station supplement does not have such a statement, a change should be instituted. Failure to submit a renewal package for more than three months after the EASA certificate expiration date will result in an automatic certificate revocation and require the organization to obtain a new certificate through the initial certification process (see MAG page 75). Bottom line, repair stations should submit renewal packages to the FAA six months prior to the EASA certificate expiration to ensure a timely renewal and avoid revocation.
- A statement that MAG changes must be implemented within 90 days of the revision publication date (see MAG page 88). This may be addressed by amending the EASA supplement to include the following sentence in the revision process section: “Applicable MAG changes will be incorporated, and a revision to this Supplement issued, within 90 days of the MAG change publish date.”
- Clarification of work away procedures to coincide with sample EASA supplement language in Appendix A with the notation that the procedures are not applicable to line stations (see MAG page 83).
- Acceptance of EASA Form 1 triple maintenance release for used components to certify compliance with FAA, EASA, and TCCA requirements (see MAG page 96). If the EASA supplement and/or repair station quality manual does not contemplate the additional language, initiate an amendment to either or both. If your repair station is taking advantage of this capability, a change to the supplement explaining how it will be accomplished should be submitted.
- Inclusion of FAA authorized line maintenance locations (stations) under the EASA certificate (excluding those located in EU member states as listed in the Safety Agreement, Appendix 2, Annex 2) (see MAG page 105). If your supplement does not include authorized line maintenance locations, a change should be submitted.
Notable MAG revisions directed at the aviation authorities include—
- Notation recommending that the repair station renewal package be submitted six months before the company’s EASA certificate expires, but no later than 30 days before expiration (see MAG page 32). While this is directed to the agency, a repair station needs to accomplish its requirements for renewal to ensure the FAA conducts the necessary review in a timely manner.
- Requirement that the FAA recommendation package for both initial and renewal applications include a copy of a repair station profile information listing ratings, personnel, FAA information, and outstanding investigations (see MAG page 76).
- Clarification that the FAA will advise EASA of any Level 1 findings (as newly defined on MAG page 23) or regulatory compliance failures that would result in an enforcement action through use of EASA Form 9 (see MAG page 76).
ARSA staff is reviewing the ARSA model EASA supplement, designed for U.S.-based repair stations currently holding or working to obtain EASA Part-145 approval, and will notify past purchasers of suggested revisions to ensure continued compliance with the MAG.
By Zach Ferriola-Bruckenstein, ARSA advocacy manager
Under Title 14 of the Code of Federal Register (14 CFR) part 145, certain repair station employees must either be certificated under part 65 as a mechanic or repairman or be able to understand, read, and write English.
For repair stations located in the United States, supervisors and persons authorized to approve work for return to service must be either mechanics or repairmen under part 65. That means the individual will have to read, write, speak and understand English. Additionally, all inspectors must be able to understand, read and write English. For repair stations located outside the United States, supervisors, inspectors and persons authorized to approve work for return to service must be able understand, read and write English. The relevant regulations are 14 CFR §§ 145.153, 145.155, and 145.157.
The Federal Aviation Administration (FAA) does not include the standards for what constitutes understanding, reading, and writing English in the rule. However, Advisory Circular (AC) 60-28A covers English language requirements for airmen, which includes mechanics and repairmen, and therefore provides guidance for all repair station personnel who must establish comprehension of English.
On Dec. 12, 2013, the FAA issued AC 60-28A, which cancelled and replaced AC 60-28 CHG 1. The AC provides guidance on the English language requirements for airmen under 14 CFR parts 61, 63, and 65. AC 60-28A Appendix 1 contains the standards that the FAA adopted from the proficiency scale established by International Civil Aviation Organization (ICAO) Document 9835 (Manual on the Implementation of ICAO Language Proficiency Requirements). ICAO established six proficiency levels that range from Pre-elementary (Level 1) to Expert (Level 6). The FAA’s standards and AC 60-28A guidance correlate to the Operational level (Level 4).
AC 60-28A Personnel
As stated above, individuals must meet language requirements to receive airman certification. 14 CFR part 61 applies to pilots, flight instructors, and ground instructors. Part 63 applies to flight engineers and navigators. Part 65 varies slightly and contains stricter requirements for some positions. For example, under § 65.33(c), air traffic controllers must show they can read, write, understand and speak English and, further, be able to speak without accent or impediment that would interfere with radio conversations. Under §§ 65.71(a)(2) and 65.101(a)(6), mechanics and repairmen who do not meet the basic requirements will receive a certificate that is valid only outside of the United States.
AC 60-28A Basic Criteria
The FAA evaluates airmen certificate applicants on six English language criteria: (1) pronunciation; (2) structure; (3) vocabulary; (4) fluency; (5) comprehension; and (6) interactions.
The pronunciation standard assumes that the applicant has a dialect or accent that is intelligible to the aeronautical community and that the applicant’s first language influences pronunciation, stress, rhythm, and intonation but only sometimes interferes with ease of understanding.
To meet structure standards, applicants must employ grammatical structures and sentence patterns appropriate to relevant tasks in a creative and well-controlled manner. Errors may occur, particularly in unusual or unexpected circumstances, but rarely interfere with meaning.
An applicant’s vocabulary range and accuracy must be sufficient to communicate effectively on common, concrete, and work-related topics. In unusual or unexpected circumstances, the applicant should be able to paraphrase.
A fluent applicant is able to produce stretches of language at an appropriate tempo and while an occasional loss of fluency during transition from rehearsed or formulaic speech to spontaneous interaction is acceptable, this loss may not prevent effective communication. The applicant can make limited use of verbal fillers so long as they are not distracting.
Comprehension by the applicant means s/he is mostly accurate on common, concrete, and work-related topics when the dialect, accent, or variety used is sufficiently intelligible. Comprehension may be slower or require clarification when there is a linguistic or situational complication or an unexpected turn of events.
To meet interaction standards, responses by the applicant are mostly immediate, appropriate, and informative. The applicant initiates and maintains exchanges even when dealing with an unexpected turn of events. The applicant deals adequately with apparent misunderstandings by checking, confirming, or clarifying.
Applying AC 60-28A and ICAO Standards to Repair Stations
Unfortunately, there is no AC comparable to 60-28A that applies the English language requirements directly to repair stations. However, AC 60-28A and the underlying ICAO Document 9835 can provide a starting point for developing training and testing standards to ensure non-part 65 certificate holders in a repair station appropriately “understand, read, and write English.”
An excellent way to ensure these personnel meet this standard is onsite, individual testing, both written and verbal, during the hiring process. Online testing conducted off-site opens the possibility of third-party assistance and inhibits an accurate verbal component.
Stay tuned as ARSA develops materials for repair stations to use in personnel hiring, training, and testing.
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. Read more at http://arsa.org/wp-content/uploads/2014/01/hlDec13-FDYTC-20140109.pdf.
Farewell to the Hotline
By Jonathan w. Yarborough,Constangy, Brooks & Smith, LLC, 80 Peachtree Rd., Ste. 208, Asheville, NC 28803-3160. © 2013 Jonathan W. Yarborough ALL RIGHTS RESERVED.
After many years of columns, this will be my last. I have enjoyed providing content to the hotline and I hope you have taken away some nuggets of information that have assisted you with your employees or helped avoid a lawsuit.
I thought I would use this last column to share a few thoughts about the state of employment law in 2014.
First, EEOC charges are at all time highs. Be forewarned. Be proactive. We love clients who pick up the phone after the charge or lawsuit is filed. Instead, pick up the phone and seek advice as the situation is unfolding.
Second, we are seeing an increase in union activity and election wins. As we say in my business, employers often get the union they deserve. Conduct a periodic review of your employment practices. Ask your employees how they are doing. Actually have an open door practice, not just a policy with a closed door.
Third, take the time to review your job descriptions, personnel policies, employee manuals, and other employment-related documents. I cannot tell you how many times I have been involved in client matters, particularly ADA issues, and have reviewed job descriptions that were last updated ten or more years prior. Technology changes, job duties change. Make sure your policies change too.
Fourth, keep up with social media issues related to your employees. The technology is changing faster than the law. Myspace, anyone? But, under the current makeup of the NLRB, employers are at a disadvantage when dealing with employees griping online about you, your supervisors, and the like. Be aware and informed; don’t have a knee jerk reaction, otherwise you may well have a complaint of unfair labor practices.
Finally, don’t be a stranger. I am happy to continue to assist with any labor and employment issues that may arise. I can be reached at firstname.lastname@example.org, and feel free to follow me on Twitter @JWYarbrough.
By Steven E. Pazar, Attorney at Law, 11 Carriage House Lane, Boxford, Massachusetts 01921. © 2013 Steven E. Pazar ALL RIGHTS RESERVED.
Steven is a counselor to businesses operating in high-risk industries, including aviation. He provides templates, tools, and training to improve contracting efficiency, close deals faster, and control costs.
How long has it been since you have had a hard look at your standard contract forms? Have you really considered your commercial terms in light of their use in practice? When was the last time you assessed the implications of recent case law or changes in state and federal regulations? Are your current insurance coverages and limits reflected in your documents?
With the new calendar year, review and refresh your contract forms and templates, particularly if it has been several years since a fresh, independent read of your working forms.
An independent review can:
- Accelerate contract negotiations by addressing concerns raised by your customers. If you are seeing the same comments over and over again from customers (or potential customers), consider making some adjustments to your templates to streamline the negotiation process.
- Spot errors, typos, and confusing or ambiguous text. Being too close to a document hinders the identification of obvious issues that can be easily remedied as part of a refreshed template.
- Ensure your insurance coverage and limits are appropriate. These are likely renewed each year; a good review of your contract forms will include a check with your risk manager, broker or underwriters.
- Keep your templates abreast of new or updated laws and regulations, as well as recent case law. Just like the standard of care for professional or manufacturing practice, the law is not static; old forms tend to reflect old practices.
“It sounds like a lot of work. How do I get a good review in a prompt, cost effective manner?” It’s not hard or costly if you use a simple plan:
(1) Gather your standard contractual forms and templates, in an electronic form (if they are not in electronic format, scan them!).
(2) Check aviation regulations for required elements (repair station must have certain language in contracts with maintenance vendors, such as required drug and alcohol testing, quality requirements and information).
(3) Pull together written comments or mark-ups received from customers during negotiations – both the initial comments and the final executed agreement.
(4) Identify errors, typos, inconsistencies and common comments.
(5) Ask your legal counsel and risk manager to review the documents for clarity and substance.
(6) Prepare a draft update for consideration by management.
(7) Ask your insurance broker or underwriter for a final check on insurance issues.
(8) Prepare an updated revision for use.
(9) Update management and staff on the revisions and use of the forms and templates.
Your contracts are a reflection of your company’s philosophy, culture, and sophistication. Old, outdated documents present an old, outdated image. Updated forms and templates reflect current trends and business practices. In the end you will improve your company’s contracting practices and close more deals faster.
By Matt McKinney, ARSA communications manager
Jet Center Medford first opened in 1967, growing into a strong and successful family owned business in the decades that followed. Forty-six years later, the company continues to serve the needs of its customers by providing outstanding aircraft management, aircraft maintenance, and parts, avionics, and aircraft sales and service.
Jet Center Medford is located at the Rogue Valley International-Medford Airport and is an independent fixed base operator and Federal Aviation Administration part 145 certificated repair station. The maintenance provider offers a variety of services including MRO, avionics upgrades, and aircraft sales and storage. Additionally, the repair station has Cessna and Cirrus factory-authorized maintenance personnel and boasts capabilities for all brands of jets, turboprops, and piston aircraft.
An ARSA member since 2006, Jet Center Medford’s General Manager Gary Hudnall currently serves on the association’s Board of Directors as treasurer.
For more information, visit http://jetcentermedford.com/.
Are you an ARSA member who would like to be in the “Member Spotlight?” If so, please contact Matt McKinney at email@example.com.
Have You Seen This Person?
By Matt McKinney, ARSA communications manager
Each month, the hotline spotlights key regulatory, legislative, and business leaders making important contributions to the aviation industry. This month we look at Deborah Hersman, chairwoman of the National Transportation Safety Board.
Deborah Hersman, chairwoman of the National Transportation Safety Board
Deborah Hersman is currently serving her third term as chairwoman of the National Transportation Safety Board (NTSB). She was first appointed to the board in 2004, and in 2009 President Obama appointed her chairwoman, making her the youngest person ever to lead the transportation body. During her tenure, Hersman has made increasing safety across multiple transportation modes a top priority.
Prior to her current role, Hersman was a senior advisor to the U.S. Senate Committee on Commerce, Science & Transportation and acted as a key player in the passage of many transportation and safety related pieces of legislation.
In 1992, Hersman graduated from Virginia Tech with a Bachelor of Arts in Political Science and in International Studies. In 1999, she received her Masters of Science in Conflict Analysis from George Mason University.
A Member Asked…
Q: Can a repair shop use its own custom-made label instead of the original equipment manufacturer identification plate listed in the illustrated parts catalog?
A: According to a letter from the FAA Flight Standards Service Aircraft Maintenance Division (AFS-300), and the updated advisory circular (AC) on this subject, a maintenance provider can re-identify the part during Title 14 Code of Federal Regulations (CFR) part 43 operations. Review the information provided on this subject in AC 43-213A.
Obviously, following the AC is an acceptable procedure; whether the local inspector finds it so is a different matter altogether. I would suggest you write a polite letter to the individual pointing out the agency has indeed found repair station re-identification an acceptable practice. While, you acknowledge that the agency recommends contacting the manufacturer (see paragraph 6.c.2 of the AC), the FAA does not require that action.
Indeed, except in limited circumstances, no part marking is even required (see paragraphs 6.a.(1)(a)-(c) of the AC and 14 CFR part 45). If the inspector has a particular regulation s/he think is applicable, ask her/him to let you know so you may address that specific issue.
ARSA is pleased to announce recorded online training classes and webinars are now available for member purchase. Check back often as courses will be continually added. Read more at http://arsa.org/training-2/online-training/.
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 2014 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/
Aviation Maintenance Resource Site Takes Flight
Addressing the need for a single hub of information about the aviation maintenance industry, ARSA recently announced the launch of www.avmro.arsa.org (AVMRO).
AVMRO Industry Roundup
ARSA monitors media coverage on aviation maintenance to spread the word about the valuable role repair stations play in their communities by providing jobs and economic opportunities and in civic engagement. These are some of this month’s top stories highlighting the industry’s contributions.
Clearwater High to Offer Aviation Academy (The Tampa Tribune)
FAA Honors Mountain Aviation Mechanic for Decades of Work (Denver Journal)
New Company Formed at Airport (Record Courier)
LAN Airline Plans Miami Maintenance Hub (Miami Today News)
ST Aerospace Mobile Expanding to Pensacola (All Alabama)
To provide more international coverage, ARSA presents a monthly roundup of world events pertaining to the industry.
Avcom Expands Russian MRO Network with Siberian Base (AIN Online)
Boeing to Expand Aviation Training in Russia (Wall Street Journal)
UTair Selects Swiss AviationSoftware to Provide MRO Software Solutions (Air Transport News)
Malaysia Poised for Growth in Maintenance Demand (AIN Online)
PPG Aerospace Expands Operations in Japan (AviTrader)
Gulfstream Beijing Service Center Marks First Year (AIN Online)
Bell Helicopter Expands Singapore Service Inspection (AIN Online)
Welcome New Members
- CAVOK, Keller, Texas
Regulatory Compliance Training
AMT Society IA Renewal Training Seminar (Sarah MacLeod presenting) – Oklahoma City, Okla. – Jan. 27, 2014
AVM Summit, Europe – London, U.K. – Jan. 21-22, 2014
MRO Middle East – Dubai, U.A.E. – Feb. 5-6, 2014
AMT Society IA Renewal Training Seminar (Sarah MacLeod presenting) – Kansas City, Mo. – Feb. 12, 2014
AMT Society IA Renewal Training Seminar (Sarah MacLeod presenting) – Aurora, Colo. – March 5, 2014
ARSA Annual Repair Symposium and Legislative Fly-In – March 19-21, 2014
AMT Society IA Renewal Training Seminar (Sarah MacLeod presenting) – Las Vegas, Nev. – March 25-26, 2014
AMT Society IA Renewal Training Seminar (Sarah MacLeod presenting) – San Antonio, Texas – April 5, 2014
To view this publication in .pdf format, .
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the hotline is the monthly publication of the Aeronautical Repair Station Association (ARSA), the not-for-profit international trade association for certificated repair stations. It is for the exclusive use of ARSA members and federal employees on the ARSA mailing list. For a membership application, please call 703.739.9543 or visit http://arsa.org/membership/join/
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.
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