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ARSA Warns that FAA Reauthorization Legislation Will Damage U.S.-Canada Trade Relationship
Submitted by Keith on Fri, 2010-03-12 11:14.ALEXANDRIA, VA, March 12, 2010 – The Aeronautical Repair Station Association (ARSA) is warning the Department of Transportation (DOT) and Federal Aviation Administration (FAA) about language pending on Capitol Hill that could dramatically alter the relationship between the United States and Canada in the aviation maintenance services sector.
In a letter sent yesterday to Secretary of Transportation Ray LaHood and FAA Administrator Randy Babbitt, ARSA Executive Director Sarah MacLeod expressed concerns about a provision in both the House and Senate FAA reauthorization bills that would require individuals performing work on air carrier aircraft to be employed by the FAA-certificated carriers, FAA-certificated part 145 repair stations, or employed by, and working under the direct supervision and control of a contract maintenance company possessing these certifications.
ARSA Questions TSA Authority
Submitted by Keith on Thu, 2010-02-18 15:27.In its comments to the Transportation Security Administration’s (TSA) repair station security regulations, ARSA questioned whether the agency had jurisdiction over certificate action. In its proposed rule, the TSA attempted to follow the congressional mandate to establish procedures for appealing a revocation of a certificate when the repair station posed an "immediate security risk". However, that statute does not, in ARSA’s opinion, supersede the National Transportation Safety Board’s (NTSB) authority to review all certificate actions. The association requested the TSA to completely rewrite the compliance and enforcement subpart and to use the existing procedures in the Federal Aviation Administration regulations (14 CFR part 13) and NTSB rules (49 CFR part 831).
FAA Responds to ARSA Request
Submitted by Keith on Wed, 2010-02-24 12:44.On February 23, 2010, the Federal Aviation Administration (FAA) issued its final response to a Customer Service Initiative (CSI) request filed by ARSA on behalf of Erickson Air-Crane nearly six years ago. (The program is now known as the Consistency and Standardization Initiative.) The FAA’s CSI letter addresses the relationship between technical data (i.e., engineering information) on the one hand, and methods, techniques and practices for performing maintenance and alterations on the other.
Concurring with ARSA’s interpretation of the pertinent rules, the FAA concluded that the "how-to" instructions for performing maintenance and alterations contained in manufacturer’s manuals is already supported by approved technical data when such approval is required under sections 65.95(d)(1), 121.379(b), 135.437(b) and 145.201(c) (i.e., when performing major repairs and alterations). Because the technical data was approved under the design change procedures of part 21 there is no need to have the data re-approved via a field approval (block 3 of a Form 337), DER approval (Form 8110-3) or approval by another authorized designee. The FAA’s decision applies to thousands of existing manufacturers’ maintenance and overhaul manuals including Structural Repair Manuals, Aircraft Maintenance Manuals, Engine and Propeller Maintenance Manuals and Component Maintenance Manuals.
Part 21 Changes
Submitted by Keith on Wed, 2009-10-28 09:50.Effective April 14, 2010, the FAA rules regarding the certification procedures and identification requirements for aeronautical products and articles will change. Sections of parts 1; 21; 43; and 45 are amended. In the preamble to the final rule (Published in the Federal Register: 74 FR 53368, October 16, 2009 the FAA’s stated aim is to update and standardize requirements for production approval holders, revise export airworthiness approval requirements to facilitate global manufacturing, move all part marking requirements from part 21 to part 45 and amend the identification requirements for products and articles. The FAA claims the changes will better reflect the current global aircraft and aircraft products and articles manufacturing environment.