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Opinion: A Step Toward Eliminating Regulatory Redundancies

As EASA and the FAA work to minimize redundant technical oversight, it is imperative that industry press the issue, work in partnership with the authorities and clear obstacles.

Printed headline: Road to International Harmony

Regulatory compliance, business success and aviation safety depend on the interaction of systems.

At every point in the “regulatory chain,” as ARSA calls the interplay between rules governing design, production, operations and maintenance, it is vital for both governments and industry to understand how moving parts fit together. In international relations, engaging across borders and between agencies is the only mechanism through which we can reduce redundancy and ensure proper technical oversight.

ARSA has a well-established reputation for leadership in maintenance matters, but its interests and membership reflect the broad connections to be made across the regulatory chain. Recognizing this reality, it serves to smooth every interaction at every point between international bodies and work with wide-ranging coalitions of interests to push for progress and celebrate areas where it’s happening.

In late August, the FAA and EASA released their most-recent update to the Certification Oversight Board’s (COB) Validation Improvement Roadmap. Created in 2014, the road map is the agency’s blueprint for “greater collaboration among the authorities to harmonize regulatory systems in order to effectively respond to common industry issues.”

While it is a living document representing an evolving effort, the road map’s up-front commitment to harmonization provides an inspiring but grounded goal for international compliance. By addressing points of commonality in certification and safety, the agencies conserve resources needed to maintain their own airspaces while focusing on areas of greatest technical need in validating the work of foreign authorities. Even in the absence of harmonization, ARSA has encouraged the authorities to evaluate their respective systems and safety outcomes. There is no reason that international progress cannot be achieved even when the authorities have regulatory differences, provided that the outcomes demonstrate an equivalent safety result.

“Both FAA and EASA recognize that while the ultimate objective, under the risk-based approach, is to achieve full acceptance by the [validating authority], without any technical assessment or issuance of a validation approval, challenges remain,” the road map’s vision section explains. “Therefore, both authorities are committed to functionally applying this approach and taking immediate steps to eliminate technical involvement based on level of risk.”

This is good—it is both the end goal and recognition of how to overcome the remaining challenges through risk-based assessment and focus. When European and American regulators have shown such clear intention to minimize redundant technical oversight, it is incumbent on industry to press the issue, work in partnership with the authorities and clear obstacles.

The best mechanism to uphold this responsibility is engagement. Attendance at international conferences and conventions (such as Aviation Week’s MRO event series) is a great foundation. By listening to regulators from around the world and interacting with colleagues, aviation businesses can shore up their knowledge of the “right-now state” of oversight and help develop practices to function within and across international systems.

This kind of collegial interaction must be balanced against direct engagement. Despite its relatively small size and the constant challenge of resource allocation, ARSA has committed to participating regularly with the key international bodies. Alongside its industry allies, the association participates in EASA’s Engineering and Maintenance Technical Body (EM.TEC) as well as with the Certification and Maintenance Management Teams (CMT/MMT) bringing together voices from the aviation world’s quadrilateral group—Brazil, Canada, Europe and the U.S.—to agree on principles to be pursued through those nations’ bilateral relationships.

Investments in this work are well spent but need broad support from industry. So, how can you follow the road map?

The first step is to know why you should. You should because eliminating regulatory redundancy and duplicative oversight—ask an international business how many audits it has each year—is good for everyone. It takes burdens away from the inspector and reinvests time into the industry.

The second is to find the points of entry available to you. While there are many, a good place to start is with the trade associations and other organizations representing your interests in compliance and policy development. There are many, each with areas of heightened focus, but all overlapping and supporting the larger system.

Come get on the road with us. 

Marshall S. Filler is managing member of Obadal, Filler, MacLeod & Klein, plc and the managing director and general counsel of the Aeronautical Repair Station Association. He has advocated for individuals and companies on international aviation safety law, policy and compliance issues for more than 40 years.

 

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