To ensure regulatory compliance, we invariably re-trace steps and face the same challenges many times. It is too easy to think that we never get anywhere. The truth is that managing the intersection of business and government isn’t all that different from maintaining airworthiness.
Your business depends on performing an overhaul on the same component for the same customer over and over. The best work requires repetition; aviation safety depends on it. The same is true of perfecting regulatory language, interpretations and application – every time we get a little better.
The repair station rule — Title 14 Code of Federal Regulations part 145 (14 CFR part 145) — is a perfect example. Time and again, the Aeronautical Repair Station Association (ARSA) has worked with the government to refine the rule that governs its regular members. In August 2014 that work began anew. Our regulatory team combed the updates for snags. The association then set about untangling threads.
First, there was the “serious” victory: replacing the word’s mistaken removal from the service difficulty reporting requirement. A coalition of aviation trade associations petitioned the agency to replace the seven letters. Over 40 industry members submitted supportive comments. The FAA promptly recognized its error and reinserted the word “serious” before the rule became effective Nov. 10.
Next, ARSA led another coalition in petitioning the agency to reinstate a repair station’s ability to voluntarily surrender its certificate without affirmative acceptance by the FAA. Requiring an “acceptance for cancellation” of a repair station certificate bears no rational connection to the aim of enhancing aviation safety through investigation and banishment of bad actors. The fact that no other certificate holder is required to wait for FAA action to surrender a certificate highlights the irrationality and disparity…and should concern anyone who holds any kind of FAA certification.
There is more to come. When rules fall short in support of aviation maintenance providers and the flying public, ARSA will work to fix the problem or issue. ARSA always seeks the right answer, no matter the repetitions.
Brett Levanto is director of operations for the Aeronautical Repair Station Association (ARSA). He graduated from the George Washington University in 2004 and earned a Master of Public Policy from the College of William and Mary in 2009. For more information visit www.arsa.org.