The association invests a lot of time in ARSA’s training program – developing content, handling logistics, working with presenters, and facilitating sessions are all essential to providing this service. Producing courses on regulatory compliance and maintenance management is central to the association’s mission; we invest in making ourselves smart and keeping our members out of trouble.
Regardless of the actual content, there are a few basic concepts that run through everything we teach. These ideas help to make sense of the material and they provide a roadmap to navigate the regulated world:
1. Connect the Regulatory Chain
If you have participated in Marshall Filler and Sarah MacLeod’s “Regulation 101” class, this will be very familiar. The regulatory chain is the starting point for determining what rules apply to an aviation-related activity. The links of the chain connect design, production, operations, and maintenance in shared responsibility for airworthiness.
While there are rules that obviously focus on one “link” or another – part 21 on design and production, part 91 on operations and part 43 on maintenance, as obvious examples – when you really examine the system it becomes clear that every paragraph of 14 CFR impacts all areas in some way. Additionally, your aviation business cannot confine itself to a single “link” at the expense of others.
2. Know the Definitions
We invest careful attention in the words used in the regulations and guidance material. Almost every presentation has something quoted from either 14 CFR § 1.1 or a relevant part’s definitions section. In general, the rules are very particular about word choice so it behooves a regulated entity to speak the language, so to speak. You can cause a lot of trouble if you can’t define an “airframe” or “overhaul” to the government’s satisfaction or if you fail to understand the difference between “approved by” and “acceptable to.”
3. Source the Authority
The FAA promulgates rules for a reason. In general, the regulations in 14 CFR should advance aviation safety (this mark gets missed, of course, but let’s applaud the goal). You can’t understand a rule unless you know what specifically brought it about. The agency responds to statutory mandates from Congress, addresses industry issues (real or perceived), “harmonizes” with other authorities, and acts on data collected through its oversight.
Always reading the statute and the preambles to rules in the Federal Register are imperative. Finding the original authority or impetus for regulatory action – understanding what the government was trying to do – is key to establishing compliance or dealing with its impact.
Adhering to these principles makes ARSA training effective and remembering them is key to staying compliant, not to mention dealing with the government as it tries to enforce a rule … or working with an inspector who “thinks” they know a regulation’s requirements.
What’s the general takeaway? Everything works together, and ARSA engages on all fronts in order to best manage the intersection of business and government.
Considering that, it should come as no surprise that we assigned the theme “Engaging for Effect” to ARSA’s 2017 Strategic Leadership Conference. This year’s SLC, which the association is hosting in Washington, D.C. on Oct. 18 and 19, comes at a pivotal time: The White House and Congress are trying to reform the entire regulatory system and reauthorize the FAA; these efforts will be felt – one way or another – by repair stations, from C-level to the shop floor.
We’ve designed this year’s event to leverage our opportunity to engage: After a morning of panel discussions and presentations by senior government officials and industry executives, SLC participants will fan out across the nation’s capital for small delegation meetings coordinated by ARSA with executive and legislative branch policymakers.
Whether we see you personally in October or online during an ARSA training session, take advantage of the association’s expertise and remember the threads that tie its work together.
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 Association.