ARSA Symposium – not lost in translation

Following the conclusion of this year's ARSA Symposium, Brett Levanto, vice-president of operations at Obadal, Filler, MacLeod & Klein, discusses some of the issues raised at the event.

Você não pode voar sem nós.

If you can read that, there may be a job waiting for you at one of 217 international repair stations with Brazilian certification.

Attendees at the Aeronautical Repair Station Association’s (ARSA) 2016 Annual Repair Symposium outside of Washington, D.C. touched on the language requirements of the National Civil Aviation Agency of Brazil (ANAC) while exploring a host of pressing international certification and maintenance issues.

Regulators from EASA and the FAA participated alongside ANAC in multiple panel and breakout discussions – as well as individually during networking events and breaks – to engage aviation stakeholders on the needs and challenges of the global industry.

Since aircraft don’t naturally respect political boundaries – there aren’t any lines on the map visible from 30,000 feet – the market for aviation services is by nature a global one.

Managing the regulatory complexity caused by government interaction is the shared responsibility of national aviation agencies, manufacturers, maintenance providers and operators. International gatherings like ARSA’s symposium allow cross-border cooperation to manage these complexities.

So, when officials from three of the world’s largest and robust national aviation authorities sat together in front of industry stakeholders, what issues are key?

Plenty of time was devoted to the most-recent change to the U.S.-EU Maintenance Annex Guidance (MAG). When the change was signed by the FAA and EASA in September 2015, ARSA led a coalition of industry groups including the International Air Transport Association (IATA) to address complications caused by new parts documentation requirements.

Specifically, FAA Form 8130-3 must accompany all new parts released by FAA production approval holders (PAH) on and after April 1, 2016 if they are subsequently installed in articles issued a dual FAA-EASA maintenance release.

Prior to January 4, 2016, FAA rules allowed only the agency or its designees to issue such a document. In an effort to bring the U.S. closer to the EASA system for parts documentation, the FAA added § 21.137(o) in Title 14 of the U.S. Code of Federal Regulations (CFR). It granted PAHs the privilege of issuing Form 8130-3, but unfortunately required the same training and qualifications for persons signing them as agency designees.

Additionally, non-PAH suppliers must rely on upstream PAHs for guidance regarding issuance of the required documentation. And those working under other states of manufacture face added complications. With less than a month before the new requirement takes effect, ARSA members had a vehicle to help them plan for continued operations.

The requirements certainly pose challenges for industry, but they actually represent efforts by cooperating NAAs to align their regulatory systems (making Form 8130-3s as prevalent as the EASA Form 1, for example). Broad cooperation, including multilateral agreements, will enhance efficiencies and reduce operating costs beyond the benefits enjoyed under many bilateral aviation safety agreements (BASAs).

As the various technical arrangements supporting BASAs have expanded – the FAA recently announced completion of its maintenance implementation procedures (MIP) with Singapore and is currently negotiating a similar agreement with Brazil – the bigger government bodies have begun working out more expansive venues for collaboration.

Through reciprocal acceptance of technical standard order authorizations (TSOAs) as well as basic supplemental type certificates (STCs), regulators are building a blueprint for expanded international reciprocity without the need for redundant technical and/or administrative reviews. Through various avenues, the agencies represented at ARSA’s symposium as well as Canada’s TCCA are laying the foundation for worldwide regulatory cooperation.

Obviously, the great challenges of international cooperation aren’t solved in a single conference. Regardless, there is value in getting personal advice on maintaining EASA part 145 approval (don’t forget to file a renewal application 90 days in advance), insights on ANAC’s handling of component repair stations located outside Brazil or a reminder of the FAA’s commitment to the quadrilateral Certification Management Team.

By leaving the friendly confines of our normal jobs and coming together, we can try to make sense of complex requirements, find answers to difficult questions, build solutions to long-term problems and take care of smaller ones on the spot.

See what you missed at the ARSA symposium (or re-live your experience) at arsa.org/symposium and plan to join next year’s conference to be held from March 15-17, 2017. Help ARSA, its members and industry allies ensure that despite our many languages, aviation safety and business success will never be lost in translation.

And whether you speak Portuguese or not, help teach the world the simple truth that began this piece: You can’t fly without us.

Brett Levanto is vice president of operations of Obadal, Filler, MacLeod & Klein, P.L.C. managing firm and client communications in conjunction with regulatory and legislative policy initiatives. He provides strategic and logistical support for the Aeronautical Repair Station AssociationAssociated Equipment Distributors and the Aviation Technician Education Council.

 

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