April 10, 2023

On April 10, the FAA informed providers of Inspection Authorization renewal courses that applications for acceptance can now be made on the new Form 8610-6. The document’s release is part of the agency’s multi-year overhaul of its procedures and guidance for managing acceptance of IA training. Although an updated advisory circular for course management and credit remains in development, the FAA has prioritized beginning to accept applications under the new guidance in Order 8900.1.

Unfortunately, the policy updates double down on the most unwieldy elements of the previous FAA process. The new procedures in 8900.1 simply rearrange various responsibilities, tweak communications steps, and extend timelines but do nothing to balance the system’s complexity with the simplicity of § 65.93(a)(4).

In October 2021, ARSA submitted comments (see below) on the still-in-production draft AC to provide overarching encouragement to the FAA for enabling such simplicity. The association’s comments continued years of dialogue regarding the flexibility afforded by the words “acceptable to” in the rule. ARSA provided its own draft guidance that would allow the government to eliminate individual training review, remove unnecessary time restrictions, and refocus attention on mechanics seeking acceptance rather than expending resources on provider oversight.

The new policy fails to offer new industry flexibility and does not significantly decrease bureaucratic burden. Given the value of broad access to professional training, ARSA will continue to focus on ways to streamline credit acceptability while pressing the government to improve how it supports professional and technical growth not only in the industry but also in its own ranks.

Stay tuned to ARSA for continued efforts related to career development and training. The association’s 22 sessions that have been found acceptable for IA renewal credit will remain valid through 2026.

To read the new language in Order 8900.1, click here.

To see ARSA’s IA renewal training sessions, click here.

November 2, 2021

On Oct. 28, ARSA submitted comments to the FAA on Draft Advisory Circular (AC) 65-IART, which would overhaul the agency’s approach to acceptance of training for Inspection Authorization (IA) renewal credit.

For several years, ARSA has been encouraging the FAA to streamline its procedures related to IA renewal course acceptability. Citing the relative simplicity of § 65.93(a)(4), the flexibility afforded the words “acceptable to” under the rules and the value of broad access to professional training, the association has urged the agency to eliminate cumbersome, time-bound reviews of individual training sessions.

“The agency already recognizes this flexibility in both the current procedures outlined in Order 8900.1 and in … the draft AC. Certain entities, including private organizations as well as specified FAA offices, may provide courses that are acceptable to the Administrator without prior review. This practice should be expanded to any provider that demonstrates in writing their ability to offer appropriate training and document completion in a way that is ‘sufficient for the student to claim IA renewal credit,’” ARSA’s comments said, quoting applicable language from the draft AC.

To support the FAA, the association provided a rewritten draft AC that its team has been circulating among trade association allies and referencing in direct engagement with the agency. The rewrite defined basic requirements for acceptable courses while offering three key alterations from current practice:

(1) Eliminating individual acceptance of training courses by setting standards for provider acceptability.

(2) Removing unnecessary time restrictions on course acceptability by eliminating the automatic expiration of acceptance.

(3) Including instruction for eligible mechanics in submitting evidence of course completion.

“By simplifying IA renewal training acceptance, the FAA can limit its own administrative burden while allowing flexibility to both training providers and IA renewal applicants,” ARSA concluded. “The resulting procedures would be consistent with the requirements of § 65.93(a)(4) while advancing agency-wide goals for improving workforce development and training.”

To review the entire comment package, including cover letter and rewritten Draft AC 65-IART, click here.

What you should do…

(1) Contact the FAA and indicate support for the comments (click here to load an email to the responsible agency contractor).

(2) Share IA renewal experiences with the association by emailing Vice President of Operations Brett Levanto (brett.levanto@arsa.org) with the subject line “Overhauling IA Renewal.”

October 8, 2024

On Oct. 4, ARSA joined Aircraft Electronics Association and Airlines for America in confirming for the FAA that new foreign oversight mandates from Congress’ reauthorization law are easily met through existing policy and regulation.

The letter cosigned by the three trade associations addressed the new requirements in 49 U.S.C. § 44733. The letter provided the following analysis of each mandate for the FAA:

(1) Inspect foreign repair stations annually without notification from the FAA consistent with bilateral aviation safety agreements (bilaterals) and the applicable laws of the country in which the repair station is located. (See, § 44733(e).)

The FAA must inform foreign civil aviation authorities to conduct unannounced inspections under its bilateral agreements. It need not notify the repair station subject to inspection. No changes no changes are needed to guidance or procedures to fulfill the statutory requirement when overseeing a foreign repair station in a bilateral country.

(2) Gather and analyze data on heavy maintenance work performed for air carriers. (See, § 44733(g).)

Multiple existing sections in part 121 require the collection, retention, and availability of maintenance data for analysis by the FAA. The agency must require “appropriate actions” by air carriers and repair stations based on any identified safety issue. No change to air carrier procedures is required since the mandate is already met under current regulations through the airlines’ procedures and safety management systems.

(3) Ensure minimum qualifications of supervisors of supervisors and personnel authorized to approve a repair station’s work for return to service. (See, § 44733(i).)

Current guidance can easily be adjusted to ensure §§ 145.153(b)(2) and 145.157(b) requirements are fulfilled by a license or certificate issued by any State signatory to the International Civil Aviation Organization (ICAO) that adheres to Annex 6. The requirements of the annex meet the requirements of the statute for supervisory personnel and those authorized to approve work for return to service under the cited sections. The letter provided suggested language for an update to Order 8900.1.

The letter concluded that the FAA need not change its guidance or practices – with the exception of the suggested small adjustment to its Order – to adhere to the new stator provisions. To read the complete letter, click here.

May 15, 2024

On May 7, ARSA delivered a letter to House and Senate leadership strongly supporting the FAA reauthorization bill unveiled April 29.

“At a time when the national airspace system (NAS) and the FAA are under intense scrutiny, [House and Senate committee leaders] have collectively crafted a forward-looking piece of legislation that promises to enhance safety by improving the agency’s effectiveness, professionalism, transparency, and efficiency,” the letter said. “The legislation makes significant investments in the aviation workforce that will help Americans from all backgrounds pursue fulfilling careers and ensure the industry and agency have the professional talent they need to be successful. The bill also makes investments to address current infrastructure needs and ensure the NAS has the physical capacity to support future growth.”

On May 9, the Senate voted 88-4 to pass the legislation and send it back to the House of Representatives for final consideration. On May 15, the House voted 387-26 to passed the bill and it was almost immediately signed into law by President Biden. Stay tuned for further analysis from the association. For a thorough review of the maintenance industry’s priorities included in the bill and the ARSA’s efforts to craft effective reauthorization law, review the update below.

To review the letter, click here.

To see the bill’s page on congress.gov, click here.

FAA Bill on Final Approach

April 30, 2024

There’s a lot of love in the FAA reauthorization bill unveiled April 29. House and Senate negotiators have worked for months to craft a compromise based on legislation passed last year by the House of Representatives and Senate Commerce, Science, and Transportation Committee.

The policy and budget blueprint funds the agency through the end of fiscal year 2028 and contains many provisions recommended by ARSA to address FAA oversight problems and industry workforce needs. Unfortunately, the bill also includes one provision ARSA opposes that will impact foreign FAA certificated repair stations and the part 121 operators that use them.

A quick review of ARSA’s initial highlights:

Access to Maintenance Data

For the first time in political memory, Congress has tackled access to instructions for continued airworthiness (ICA).  Sec. 349 of the bill directs the agency to convene an ICA Aviation Rulemaking Committee (ARC) to clarify maintenance manual access rules and policies. The FAA initiated the ARC earlier this year in response to an ARSA-led petition filed in 2021 and because congressional action in this area was inevitable. The inclusion of ICA is a testament to the hard work by the association and its members to find a solution to a problem that has plagued the maintenance industry for decades. The ARC by itself doesn’t solve the problem of manual access but it’s a big step in the right direction.

Workforce

The FAA bill’s workforce title doubles down on initiatives in the 2019 FAA reauthorization and represents another big win for the maintenance industry. ARSA economic research partner Oliver Wyman projects a shortage of nearly 40,000 technicians in the United States by 2028.

Sec. 440 reauthorizes, improves, and increases funding for the aviation workforce grant programs created at ARSA’s suggestion. The existing mechanic and pilot workforce programs will be quadrupled to $20 million per year.  Congress is creating a new grant program (also $20 million per year) to expand the aviation manufacturing workforce.  The maximum grant award will be increased from $500,000 to $1 million in any one calendar year for all three programs and eligibility will be expanded to include 501(c)(3) nonprofit organizations.  The grant programs will henceforth be known collectively as the Cooperative Aviation Recruitment, Enrichment, and Employment Readiness Program or CAREER Program. Finally, the bill improves reporting about grant awards to help measure the program’s success and eventually shifts management of the program from the FAA to DOT.

Sec. 424, another provision sought by ARSA and its allies, addresses career transition for technicians leaving the military and directs FAA to streamline the process by which they can earn part 65 mechanic certificates.  The provision directs a rulemaking to create a military mechanic written competency test and, as necessary, develop a new Airman Certification Standard. It also creates an interagency working group to advise the Department of Transportation (DOT) and the Department of Defense on the requirements to become a civilian technician to further facilitate career transitions.

Sec. 402 addresses gaps in data about the industry workforce by requiring the FAA to publish civil airmen statistics more regularly and to report the gender of certificate holders.

Sec. 403 makes the Women in Aviation Advisory Committee permanent and names it in honor of African American aviation pioneer Bessie Coleman. 

Sec. 405 directs an FAA working group to evaluate allowing high school students to take the general knowledge portion of the mechanic exam. This provision was requested by ARSA and its allies in response to more high schools offering maintenance curriculum. Early testing would make it more likely that a graduate stays in the industry.

Sec. 414, a related provision, directs the Government Accountability Office (GAO) to assess high school maintenance programs and identify barriers to early testing.

Sec. 441 directs the Secretary of Transportation to develop a national strategic plan for the aviation workforce and establishes a CAREER Council of industry experts to advise DOT on workforce issues in general and the CAREER grant program in particular.

Improving Regulations and Oversight

Several provisions address concerns about FAA’s development and enforcement of regulations and guidance:

Section 821 requires the DOT Inspector General (IG) to audit the Flight Standards and Aircraft Certification Services on the consistency of policy and regulatory interpretation and the application of policies, orders, and guidance.  Three specifically directed audits relate to repair station oversight, supplemental type certificates, and technical standard orders.  The DOT must report to Congress on these three audits and the bill requires the FAA to consider the reports suggested best practices.

Sec. 822 requires the FAA to ensure that policies, orders, and guidance are applied equally and consistently and not altered without consultation. It also requires better documentation of findings and decisions throughout a project to avoid disruptions when personnel change.

Sec. 202 creates the position of Assistant Administrator for Rulemaking and Regulatory Improvement. The position will be responsible for, among other things, developing and managing FAA’s regulatory agenda, reviewing regulations on an ongoing basis to enhance safety and reduce burdens, and improving accountability in responding to petitions for rulemaking and exemptions.

Sec. 205 creates a review team (including outside experts) to improve the process by which regulations and guidance are developed.  It also tasks the DOT Inspector General (IG) with reviewing the FAA’s processes and recommending improvements.

Sec. 209 expresses the sense of Congress (i.e., it’s not legally binding) that the agency should improve stakeholder engagement during the rulemaking process.

Sec. 805 seeks to end FAA’s practice of leaving letters of investigation (LOI) unresolved.  It requires a final determination on an investigation to be made within two years of issuance of the LOI and that the investigation be closed baring a determination by the administrator or deputy administrator.

Foreign Repair Stations

Sec. 302 directs the FAA to enhance oversight of foreign repair stations:

• The FAA must inspect each foreign repair station annually without advanced notice to the facility being inspected. Those inspections must be conducted in a manner consistent with U.S. obligations under international agreements and the laws of the country in which the repair station is located.
• Part 121 air carriers will be required to report annually to the FAA where and when heavy maintenance is performed outside the United States, what work was performed, failures, malfunctions, or defects resulting from the work, and certificate number of individuals approving the product for return to service following work at the foreign location.
• The FAA may not certificate a new repair station in a country that the FAA has classified as Category 2 via its International Aviation Safety Assessment Program (the prohibition does not apply to certificate renewals).
• Part 121 air carriers are also prohibited from entering new heavy maintenance contracts with repair stations in CAT 2 countries.
• Foreign repair station supervisory personnel and personnel authorized to approve article for return to service will be required to hold part 65 mechanic or repairman certificates or be certified under a licensing regime deemed equivalent by the FAA.
• Persons responsible for approving an article for return to service or directly in charge of heavy maintenance work for a part 121 air carrier at a foreign repair station must be available for consultation while the work is being performed.
• Finally, the section directs the FAA to complete rulemakings foreign repair station drug and alcohol testing and security background check rulemakings.

ARSA is disappointed Congress chose to include Sec. 302, which is a solution in search of a problem. The provision was promoted by labor organizations representing airline mechanics based on false safety arguments to make it more difficult for part 121 carriers to use foreign repair stations. ARSA and its allies were able to negotiate significant changes to the original text to limit negative impact and disruption.

Anything Else?

Sec. 409 directs a review of whether part 121 air carriers and part 145 repair stations have in place “uniform policies and uniform offerings that ensure pregnant employees can perform required duties safely.” The section requires the FAA to brief Congress on the results of the review within two years.

Cleared for Landing?

We expect the bill to receive a full Senate vote in the coming days.  It will then go to the House for final approval before being sent to the White House for the president’s signature.  The clock is ticking: The bill must be signed by May 10 when the current short-term FAA authorization expires.

As the reauthorization process draws to a successful conclusion, ARSA members are encouraged to contact Congress to support final passage of the bill. ARSA’s grassroots action site – sponsored by Aircraft Electric Motors – makes it easy.  Just click here.

To review the complete bill text, click here.

For a section-by-section summary of the bill prepared by committee staff, click here.

October 2, 2023

On Sept. 30, the U.S. Congress passed a stopgap measure averting a federal government shutdown and extending the authorization of the FAA. The agency may operate under this extended authority until Dec. 31, though overall continuing resolution funding will expire on Nov. 17.

“Passage of this short-term measure was the right thing to do,” Sen. Maria Cantwell, chair of the Senate Commerce Committee, said. “This will ensure continuity at the FAA and avoid pointless disruptions for the traveling public. But aviation workers and the traveling public deserve an FAA reauthorization bill that will give the agency the steady authority and the tools and resources necessary to be the global leader in aviation safety.”

Providing that authority is a key priority for ARSA and its members. In July, ARSA Executive Vice President Christian Klein praised the “Securing Robust Leadership in American Aviation Act” (H.R. 3935). The bill passed the House of Representatives – Sen. Cantwell’s chamber has yet to make substantive progress on its own legislation – and would mandate a series of personnel, training, management, and oversight improvements the association and its allies have long called for to improve the FAA (see below).

In a Sept. 13 letter, ARSA joined 27 joined 27 organizations including ally trade associations, labor unions, and business advocates in urging Congress to provide “permanent leadership and clear direction” for the American aviation safety regulator. Neither the continuing resolution or extension of FAA authority provides for such leadership or direction, but prevents further severe short term disruption for the aviation community; shutdown threats have already caused upheavals as industry and government personnel diverted resources to planning for work stoppages.

July 21, 2023

On July 20, the U.S. House of Representatives overwhelmingly passed the chamber’s bill to reauthorize the FAA: the Securing Growth and Robust Leadership in American Aviation Act (H.R. 3935).

In a letter to House leadership on July 14, ARSA Executive Vice President Christian Klein praised the bill and offered the association’s strong support for its passage. Klein noted H.R. 3935 would continue to build on key priorities for the maintenance community and address challenges facing both the FAA and the industry it regulates. As outlined in the letter, if passed into law the bill would:

• Improve FAA personnel training, professionalism, and management.
• Enhance regulatory oversight transparency and consistency.
• Empower the agency to adjust more rapidly to changing circumstances.
• Strengthen the agency’s hand in its relationships with other global aviation authorities.
• Expand efforts already underway to attract a new generation of the technicians to maintain the airworthiness of America’s fleet.

“ARSA is also particularly grateful that the bill addresses the longest standing challenge facing the U.S. maintenance sector: access to Instructions for Continued Airworthiness (i.e., maintenance data),” the letter said.

Despite its general enthusiasm for the bill, ARSA remains on guard against language targeting foreign repair stations. That language has been greatly improved since it was first introduced as a standalone bill by then-T&I Chairman Pete DeFazio in 2019. That previous effort, common to the Oregon Democrat whose policies were generally antagonistic to repair stations, would have imposed considerable burdens on the industry and threatened to punish maintenance providers for FAA inaction on key rulemakings. The provision included in the House bill is much less disruptive, given the maintenance industry’s safety record and the scrutiny foreign repair stations already receive from the FAA, airline customers, and third-party auditors. ARSA continues to believe that the foreign repair station language is a solution in search of a problem.

The legislation had been unanimously approved by the House Transportation & Infrastructure committee on June 14. It now heads to the Senate, which is considering its own FAA reauthorization bill.

To read the bill, click here.

To read ARSA’s letter in support of the bill, click here.

To read about the Senate’s effort to reauthorize the FAA, click here.

June 12, 2023

On June 9, the U.S. House of Representatives Committee on Transportation & Infrastructure released its draft FAA reauthorization bill. The committee has scheduled a markup session for June 13.

ARSA is still analyzing the 700+ page bill, but on first review it includes many of the association’s regulatory and workforce reauthorization recommendations. Among other things, the bill:

• Requires the FAA administrator to task the Aviation Rulemaking Advisory Committee with identifying ways to improve access to instructions for continued airworthiness (the first time in two decades Congress has addressed the ICA issue).
• Directs the U.S. Department of Transportation’s Inspector General to audit the Flight Standards and Certification Services regarding the consistency and application of guidance and regulations.
• Directs the FAA administrator to ensure consistency in oversight through audits, more frequent updates to guidance and rules, and better documentation of findings and decisions.
• Improves transparency relating to the agency’s handling of petitions for rulemaking and exemptions.
• Requires the agency to issue or update guidance to clarify the conditions under which a major alteration requires a supplemental type certificate.
• Requires FAA investigations to be completed within two years of issuance of a letter of investigation.
• Encourages the agency to more aggressively pursue cooperation with other civil aviation authorities.
• Reauthorizes, triples funding for, and improves the aviation workforce grant programs created at ARSA’s suggestion in 2018 (and creates a similar new grant program for the aviation manufacturing workforce).
• Creates a new National Center for the Advancement of Aerospace to coordinate workforce development activities between industry, academia, and other stakeholders.
• Establishes an interagency working group to improve transition for military to aviation careers.
• Establishes a working group to examine airman knowledge testing.

While ARSA is pleased the T&I Committee adopted so many of the association’s recommendations, the bill also includes language (that passed the House in a standalone bill last fall) targeting foreign repair stations. While the legislation was greatly improved last spring in committee to be much less disruptive, given the maintenance industry’s safety record and the scrutiny foreign repair stations already receive from the FAA, airline customers, and third-party auditors, ARSA continues to believe that the foreign repair station language is a solution in search of a problem.

Look for more analysis of FAA reauthorization legislation from ARSA in the weeks ahead. In the meantime, review the bill for yourself and contact the association with questions or thoughts.

June 22, 2022

Aviation took center stage on Capitol Hill in recent weeks as the House of Representatives passed legislation to improve government coordination on advanced air mobility and the Transportation & Infrastructure (T&I) Committee reported bills impacting the aviation supply chain and repair station oversight.

The House passed the Advanced Air Mobility (AAM) Coordination and Leadership Act (H.R. 1339/S. 516) on June 14. The bill instructs the U.S. Department of Transportation to create an AAM interagency working group to evaluate, plan, and coordinate efforts regarding the safety, infrastructure, and security of the developing AAM ecosystem in the United States.

“If we want to keep leading the world in aviation, we can’t wait for technologies to come to us. Today, members from both sides of the aisle showed they are ready to take advantage of the next wave of transportation innovation by passing the Advanced Air Mobility Coordination and Leadership Act,” Rep. Sharice Davids (D-Kan.), the bill’s lead sponsor said.

The strong bipartisan vote in favor of the bill (380 to 30) puts pressure on the Senate to act on the legislation. To review more information on the bill, click here.

On June 15, the T&I Committee gave its approval to two additional bills. The first was the Safe Aircraft Maintenance Standards Act (HR. 7321), which was completely revised and renamed to address concerns raised by ARSA and other industry groups. The bill was changed as follows:

• New name. The bill is no longer “the Safe Aircraft Maintenance Standards Act”. The new name is the “Global Aviation Maintenance Safety Improvement Act.”
• While the new version of the bill still requires reporting by air carriers about where heavy maintenance (C and D checks) is performed, those reports (annually) will be less frequent and the information submitted will be protected as confidential.
• The original version of HR. 7321 required direct certification under part 65 of certain foreign repair station personnel; while the new version still requires personnel certification, it can occur under either part 65 or an equivalent foreign personnel certification system.
• CAT 2 countries are still in the crosshairs, but the implications of falling into CAT 2 status are now less disruptive. The new bill only prohibits new repair station certificate applications from CAT 2 countries and new contracts for heavy maintenance work.
• The new bill still directs the long-awaited drug and alcohol rulemaking to be finished within the year, but rather than punishing industry with a new foreign repair station certification ban if the rulemaking isn’t complete, the new bill bars the FAA from traveling internationally until the rulemaking is done (with exceptions for safety-related travel, travel in the national interest, etc.).
• The bill still allows unannounced inspections, but they are “unannounced” only to the repair station. The bill allows notification of foreign authorities, governments, etc. and those unannounced visits may be risked based and must take place with U.S. international agreements and diplomatic norms.
• The new version of the bill also directs a joint authorities review to examine the question of foreign repair station oversight on a global basis.

To read the full text of the Amendment in the Nature of a Substitute (ANS), click here.

ARSA still thinks repair station legislation is a solution in search of a problem. The industry’s safety record is exceptional and new, unnecessary mandates on the agency or industry will only divert resources. However, with House T&I Chairman Peter DeFazio (D-Ore.) retiring at the end of this Congress, this is his last opportunity to move legislation on an issue he’s considered a priority on throughout his career.

Whether or not the bill moves further this Congress (time is short and there’s no obvious vehicle nor Senate companion), given that there are a handful of pro-labor GOP members who support DeFazio’s bill, the T&I Committee’s Republican leadership cannot dismiss the legislation out of hand. Even if Republicans (who have been less susceptible to the false safety arguments used by the bill’s proponents) are running the T&I Committee and aviation subcommittee next year, there is the risk that the legislation could be added as an amendment on a bipartisan basis during a future FAA bill markup.

By negotiating now, the T&I Committee has reframed the conversation and crafted a much more reasonable bill that limits disruption, recognizes our bilateral commitments and minimizes the risks of retaliation against U.S. industry. ARSA will continue to lead lobbying efforts on maintenance issues.

On June 15, the T&I Committee also reported the American Aerospace Supply Chain Resiliency, Innovation, and Advancement Act (H.R. 8049). The bipartisan bill, which is sponsored by the chairman and ranking members of both the T&I Committee and aviation subcommittee, would create a new industry-government task force to investigate supply chain problems and recommend solutions. 

ARSA members wishing to support the association’s legislative program should contact ARSA Executive Vice President Christian Klein for help coordinating a congressional visit to your facility this summer.

Jan. 8, 2025

The FAA has announced an amendment to Order 8900.1, Vol. 6, Chap. 9, Sec. 27 clarifying procedures for aviation safety inspectors (ASIs) who oversee domestic repair stations holding foreign certificates under bilateral aviation safety agreements (BASAs) between the FAA and the Civil Aviation Authority of Singapore (CAAS), the United Kingdom (UK) CAA, and/or the National Civil Aviation Agency of Brazil (ANAC).

Among other things, the updated Sec. 27:

• Provides background on the purposes of BASAs and related Maintenance Implementation Procedures (MIP) and Maintenance Annex Guidance (MAG).
• Describes the various prerequisites ASIs must meet prior to conducting oversight, including FAA electronic Learning Management System (eLMS) course requirements specific to each of the BASAs.
• Explains the interrelationship between ASIs, the FAA Flight Standards Service (AFS) General Aviation Group (AFS 340), and the partnering civil aviation authority, identifying FAA coordinators as primary points of contact between AFS and the foreign CAA and explaining how policy issues and proposed changes to the MIP and MAG are elevated within AFS.
• Details procedures for auditing a repair station pursuant to a MIP.

The Order directs ASIs to use Sec. 27 in conjunction with the applicable MAG between the United States and foreign country, but reminds them the MAG supersedes the order if the two documents conflict.

Similar guidance related to oversight of U.S. repair stations with European Union Aviation Safety Agency (EASA) approval is found at FAA Order 8100 Vol. 6, Chap. 9, Sec. 24. Transport Canada Civil Aviation (TCCA) guidance is in Sec. 22.

March 10, 2026

On March 10, ARSA and the Aircraft Electronics Association completed the final edition of six planned webinars – a monthly series begun in October – explaining effective integration of a safety management system within the operations of an FAA-certificated repair station. These hour-long virtual sessions help U.S.-based repair stations holding European approval to implement a part 5 compliant SMS programs as required by the special conditions of the bilateral agreement between the United States and European Union. This requirement to “design, implement, and maintain” an SMS should be met by effectively and efficiently integrating SMS into the facility’s existing quality system and daily operations.

The session materials and recording from completed webinars are available within the SMS tools managed by AEA and available for discounted access to ARSA members. Access to the recordings was also provided to attendees at ARSA’s 2026 Annual Conference.

Click the session number to access the recording.

Session 1 – October 29, 2025 (Recorded) – Provides an overview of international aviation requirements and agreements.

Session 2 – November 18, 2025 (Recorded) – Introduces the SMS “gap analysis,” and covers key elements of compliance in 14 CFR part 5, Subparts A, “General” and B “Safety Policy.”

Session 3 – December 16 (Recorded) – Reinforces the SMS “gap analysis,” and key elements of compliance in 14 CFR part 5, Subparts C, “Safety Risk Management” and D “Safety Assurance.”

Session 4 – January 20 (Recorded) – Reinforces the basic principles of the “gap analysis” for establishing safety management systems in aerospace environments and key elements of compliance in 14 CFR part 5 subparts E, “Safety Promotion” and F, “SMS Documentation and Recordkeeping”.

Session 5 – February 10 (Recorded) – Establishing how to capture or add to existing parts 43 and 145 procedures that comply with part 5 through the gap analysis.

Session 6 – March 10 (Recorded) – Quickly recaps key compliance elements with open discussion of gap analysis and quality system application.

February 25, 2025

On Feb. 10, the Bilateral Oversight Board (BOB) for the U.S.-European Union (EU) bilateral aviation safety agreement (BASA) issued Decision No. 13. It amends BASA Annex 2 to require U.S.-based repair stations with European Union Aviation Safety Agency (EASA) approval to establish, implement, and maintain a Safety Management System (SMS).

SMS for U.S. repair stations has been on the radar for years. The FAA issued InFo 24007 in June 2024 and announced at the 2024 FAA-EASA International Safety Conference that SMS would be required for U.S. EASA repair stations by the end of 2025. Approved maintenance organizations (AMO) in the EU are already required to have SMS. The FAA decided not to include repair stations in its expansion of 14 CFR part 5, which created a significant difference between FAA and EASA regulations. Thus, SMS was added to the BASA special conditions for U.S. based repair stations wishing to obtain or maintain an EASA certificate.

The BOB is authorized by the bilateral agreement to amend the annexes. The exact language added to Appendix 1 of Annex 2 is—

(b) The repair station shall establish, implement, and maintain a Safety Management System (SMS) acceptable to the FAA and compliant with ICAO Annex 19 as applicable to maintenance organizations. The FAA SMS Voluntary Program outlines the process and requirements.

To facilitate compliance, ARSA has partnered with the Aircraft Electronics Association (AEA) to provide ARSA members with access to AEA’s SMS tools. The AEA-managed program is constructed around the principles created by the International Civil Aviation Organization (ICAO) for adoption by the civil aviation authorities. It is consistent with the FAA’s Voluntary Program.

The BOB’s Decision isn’t the final step in the process of imposing SMS on U.S. repair stations. The authorities must still issue new Maintenance Annex Guidance (MAG) to provide direction to industry about the requirements. At last report, the MAG was nearly complete; however, the regulatory freeze imposed on federal agencies by the Trump administration likely causing delays. ARSA also expects new related guidance for FAA inspectors, but the timing is unknown.

EASA and FAA executives will update the industry on the status of SMS implementation at ARSA’s Annual Conference next month. In the meantime, to read BOB Decision No. 0013, click here. To read the consolidated text of the bilateral agreement, click here.

June 26, 2024

Though the FAA excluded repair stations from its expansion of SMS requirements in part 5, EASA has been clear a mandate for U.S. part 145 air agencies holding European approval under the bilateral agreement will be added to the two jurisdictions’ Maintenance Annex Guidance. Those awaiting the official change to the MAG can pencil in an expected SMS compliance deadline of December 31, 2025: By that date all affected repair stations must have verified their compliance with the FAA’s voluntary program to continue their European approval.

On June 11, the FAA published an InFO advising certificate holders of the Dec. 31, 2025 deadline. The InFO describes the FAA’s recent amendment to 14 CFR part 5 as introducing a “significant difference” between the American and European aviation safety regulatory systems. To address the difference, the FAA and EASA have established a new special condition under their bilateral agreement:

“This special condition requires FAA certificated repair stations located in the U.S. seeking initial approval or renewal of EASA Part-145 certification to establish, implement, and maintain an SMS,” the InFO said. “Participation with the FAA Voluntary SMS Program is deemed acceptable as a means to comply with the new requirement. The deadline for implementation of this requirement is December 31, 2025.”

Despite the InFO’s declaration, the June 20 release of change 9 to the FAA-EASA Maintenance Annex Guidance does not include a new special condition regarding SMS. There is no regulatory requirement for U.S. repair stations to have an SMS until that special condition is released, which may occur in MAG Change 10 – ARSA has heard chatter it is not far behind. None-the-less, with 18 months until the end of 2025, the association encourages members with EASA approvals to prepare for SMS implementation. As with other announcements of European arrivals (remembering Paul Revere’s April 1775 ride), hearing “the SMS is coming!” should not surprise the industry.

ARSA will support impacted repair stations during this transition period by:

(1) Working with regulators to push for smooth installation of SMS requirements into current quality systems.

(2) Continuing the member benefit facilitating access to SMS tools managed by the Aircraft Electronics Association.

(3) Updating the association’s Model RSQM Compilation to include SMS requirements.

(4) Handling confusion and communicating to provide clear information regarding compliance requirements and implementation dates.

April 26, 2024

On April 26, the FAA published to the Federal Register its new rule expanding Safety Management Systems (SMS) requirements to all operators of commuter and on-demand service and commercial air tours as well as type certificate holders and licensees. The agency has not yet placed SMS requirements directly on part 145 repair stations.

“In 2015, the FAA promulgated 14 CFR part 5 which required part 121 operators to develop and implement SMS and set out the basic requirements for those systems,” the agency said in the rulemaking. “The next step in improving aviation safety is to extend the SMS requirements in part 5 to additional organizations that play a critical role in the design, manufacturing, and operation of aircraft. These aviation organizations are in the best position to prevent future incidents and accidents because they are closest to the hazards, and they know the most about their operations and products.”

In January 2023, the FAA’s notice of proposed rulemaking had asked the public for comment on potential expansion of SMS applicability to include repair stations. ARSA and the Aircraft Electronics Association argued such expansion was unnecessary, since part 145 includes a “robust quality management system” as required by §§ 145.209 and 211. The associations explained the agency could find its oversight of maintenance providers to be SMS compliant based on these existing rules and the current use of the Safety Assurance System for assessment of risk and change management.

“The comments received from the NPRM offer a diverse set of viewpoints across the aviation sector, all of which must be taken into account should the FAA consider a future rulemaking to require part 145 repair stations to develop and maintain an SMS,” the rulemaking said. “The FAA continues to collect and evaluate data to determine whether the benefits would justify the costs and will continue to pursue and promote part 145 repair station involvement in the FAA’s SMS Voluntary Program.”

To review the final rule, click here.

To see the comments ARSA and AEA submitted to the NPRM, click here (and review the content below).

For information about the SMS program resources available to ARSA members, visit arsa.org/sms-program.

April 23, 2023

In joint comments submitted to the FAA on April 11, ARSA and the Aircraft Electronics Association (AEA) opposed the potential expansion of the agency’s Safety Management System (SMS) rules contained in 14 CFR part 5 to include repair stations certificated under part 145.

The comments were submitted in response to the FAA’s Jan. 11 proposal to update and expand the requirements for SMS and require certain certificate holders and commercial air tour operators to develop and implement an SMS program. While certificated repair stations were not included in the proposed SMS rule, the FAA requested comments and information regarding a future rulemaking project to expand the applicability of 14 CFR part 5 to include repair stations.

As part of the rulemaking process, the FAA must assess and substantiate the economic burden by establishing the requirement would increase safety. The agency was unable to do so when attempting to apply quality assurance to U.S.-based repair stations in its 1999 rulemaking. Therefore, it is unlikely the FAA could validate an increase in safety to justify the burden of implementing and maintaining an SMS, particularly on small businesses.

In support of this effort, ARSA conducted a survey of its members the week of April 3. Ninety-four percent of respondents opposed a future rulemaking to expand the applicability of part 5 to repair stations, 97 percent opposed applying part 5 to all repair stations, and 96 percent opposed limiting the applicability to a certain subset of repair stations.

“Part 145 already has a robust quality management system as required by 14 CFR §§ 145.209 and 145.211. This is not to assume that the quality management system is perfect and that it could not be enhanced with continuous improvement however, the FAA is already overseeing repair station certification and operations through its Safety Assurance System with many of the 3 elements contained within SMS such as risk assessment and management, change management, and promotion and outreach,” ARSA and AEA said. “The FAA should declare 14 CFR part 145 combined with the Agency safety assurance oversight of repair station to be SMS complaint.”

To read the ARSA-AEA joint comments, click here.

For more on AEA’s SMS advocacy, click here.

January 11, 2023

On Jan. 11, the FAA issued a long-awaited notice of proposed rulemaking (NPRM) that would update and expand the requirements for safety management systems. The proposal’s applicability does not include 14 CFR part 145.

NPRM: Safety Management Systems
Published 01/11/2023
Docket #: FAA-2021-0419
Comments due: 03/13/2023

FAA Summary: The FAA proposes to update and expand the requirements for safety management systems (SMS) and require certain certificate holders and commercial air tour operators to develop and implement an SMS. This proposed rule would extend the requirement for an SMS to all certificate holders operating under the rules for commuter and on-demand operations, commercial air tour operators, production certificate (PC) holders that are holders or licensees of a type certificate (TC) for the same product, and holders of a TC who license out that TC for production. The FAA also proposes this rule in part to address a Congressional mandate as well as recommendations from the National Transportation Safety Board (NTSB) and two Aviation Rulemaking Committees (ARCs). Additionally, the proposed rule would more closely align the United States with Annex 19 to the Convention on International Civil Aviation. This proposed rule is intended to improve aviation safety by requiring organizations to implement a proactive approach to managing safety.

Stay tuned to ARSA for more updates on the regulatory process for this rule. Register for the 2023 Annual Conference to hear from the FAA and EASA about each regulator’s efforts related to SMS and then participate in a breakout session covering programs for small businesses.

December 19, 2022

In November, the European Union Aviation Safety Agency (EASA) made public a series of resources for EASA Part 145 maintenance organizations implementing new safety management systems (SMS) requirements. The new requirements became effective on Dec. 2 and apply to holders of EASA Part 145 approvals not subject to a bilateral agreement.  Maintenance organizations in the United States, Canada and Brazil will continue to comply with the current bilateral aviation safety agreements and their corresponding maintenance implementation or guidance procedures.

According to a Nov. 11 letter from the agency, approval holders should refer to its documentation index for updated guidance material. The new requirements allow for a two year transition phase, giving approval holders until Dec. 2, 2024 to fully comply with European Commission Implementing Regulation (EU) 2021/1963. During the SMS transition phase, compliance verification will be limited to the “Classic Part-145 requirements” of the new regulation.

In a separate letter, EASA announced the application of a “transition finding” to all approval holders. The letter explained the “finding” allowed each organization “to maintain its approval valid [sic] even if not in compliance with the novelties introduced by the Part-145 regulation, providing the necessary time to concentrate on the implementation of the SMS change without undue pressure.”

To support approval holders during the transition, EASA has published SMS assessment guidance and a matrix for transition phase regulatory compliance. The matrix covers every section of EASA Part 145, identifying “novelties” for compliance by late 2024.

To access EASA’s information page for foreign Part-145 approval holders (those located outside the EU and not subject to a bilateral), click here.

ARSA members seeking full analysis of EASA’s SMS requirements for non-bilateral foreign repair stations should refer to the September 2022 edition of the hotline.

July 14, 2022

The European Union Aviation Safety Agency (EASA) has published new resources to facilitate compliance with its recently adopted safety management systems (SMS) requirements for EASA Part 145 maintenance organizations. The new EU SMS requirements are not applicable to EASA approved repair stations in countries with bilaterals, such as the United States.

The FAA currently requires SMS for operators, airports, air traffic organizations and commercial space. Some U.S. repair stations are voluntarily adopting SMS to meet customer demands and/or in anticipation of future requirements. Runway Girl Network recently reported that the FAA’s upcoming SMS rulemaking for aircraft and engine manufacturers will seek comment on whether non-scheduled part 135 operators, part 91 tour companies and repair stations should also be required to adopt SMS. Since SMS is on the horizon for the entire industry, understanding EASA’s SMS requirements for its approved maintenance organizations will facilitate future compliance.

Pursuant to European Commission implementing Regulation (EU) 2021/196311, effective Dec. 2, 2022, EASA Part 145 organizations must implement SMS within a two-year transition period (through Dec. 2, 2024). The system must include, among other things, hazard identification, risk management and safety assurance processes, and the designation of a safety manager. To support SMS processes, the regulation also made changes to existing requirements related to an organization’s safety policy, internal occurrence reporting, competence of staff, and compliance monitoring.

EASA’s states in its new “Guide for Compliance with Part-145 As Amended by EU Regulation 2021/1963” that it recognizes “SMS is a concept that may need to mature over multiple years.” As such, the agency does not anticipate maintenance organizations will have “a fully operational and effective SMS in the first oversight cycle or at the end of the transition period.” It is the agency’s position that to retain its Part-145 certificate, an organization must show its system and procedures are ‘present’ and ‘suitable.’

The guide illustrates a typical process that a maintenance organization and its competent authority may follow to transition to the new requirements, describes a step-by-step approach for the transition, and provides guidance for competent authorities to use during the process. Appendix I explains the technical requirements EASA Part-145 organizations must meet; Appendix II applies to competent authorities.

EASA also issued a separate FAQ explaining references to “use of the organisation’s safety risk management process” in the requirement to assess non-mandatory modifications/inspections pursuant to CAMO.A.315(b)(4).

September 9, 2019

ARSA filed comments on Sept. 6 in response to European Aviation Safety Agency (EASA) Notice of Proposed Amendment (NPA) 2019-05, Embodiment of safety management system (SMS) requirements into Parts 145 and 21 of EASA’s rules.

The proposed changes would initially apply only to approved maintenance organizations within the European Union and to those outside the EU regulated directly by EASA (i.e., not to facilities that hold certificates pursuant to a bilateral aviation safety agreement). However, it’s likely SMS will become a “special condition” required by EASA for AMOs holding certificates through a bilateral. It’s therefore important for repair stations serving European customers to be aware of the potential rule changes, regardless of where located.

ARSA told EASA that the association shares the agency’s objective of improving aviation safety and generally supports encouraging AMOs to adopt SMS policies. The association also commended EASA for recognizing the complexity associated with managing compliance within companies with multiple certificates and that a one-size-fits all solution is inappropriate for a diverse industry made up of companies with various sizes and specialties.

However, ARSA is concerned that certain provisions of the NPA run contrary to the philosophy underlying SMS, suggest a lack of confidence in the systems required by the new rules, would create new and unnecessary burdens for certificate holders and regulators and would potentially undermine safety. For example, the proposed regulation would require certificate holders to obtain prior approval by the competent authority for many types of organization changes, including personnel involved in safety management.

ARSA believes a fundamental concept underlying SMS is that safety depends on the organization and its processes, not individuals. “Requiring the regulator to approve personnel changes made in accordance with the company’s SMS defeats the purpose of the system and the proposed regulatory changes,” ARSA said.

“It is the company’s responsibility, not that of regulators, to manage operations and make decisions about who is best suited to ensure compliance, safety and the company’s success. If the company has properly designed and implemented its SMS, the new employees appointed to key positions should be presumed qualified and trained.”

ARSA said the new approval requirements “would give regulators unprecedented authority over internal personnel changes, diverting competent authority resources and undermining the ability of certificate holders to manage their businesses on a daily basis. Finally, by requiring the regulator’s approval of personnel changes, the new rule will undermine safety by thwarting a company’s ability to remove a team member whose acts or omissions run contrary to the company’s SMS.”

ARSA’s comments also expressed other concerns, including that expanded occurrence reporting requirements are too broad leading to over-reporting and clogging the regulators’ reporting system and that the rules would not afford sufficient due process to AMOs facing certificate actions.

If your company submitted comments to EASA on SMS, please send a copy to christian.klein@arsa.org.

To read ARSA’s full comments, click here.

To view a PDF file of the comments as submitted through EASA’s Comment Response Tool, click here.

To see the results of a “quick question” ARSA asked about SMS, click here.

January 7, 2015

On Jan. 7, the FAA issued a final rule that requires most U.S. commercial airlines to have Safety Management Systems (SMS) in place by 2018. The rule builds on programs many airlines already use to identify and reduce aviation risk.

The rule requires each certificate holder operating under 14 CFR part 121 to develop and implement SMS within three years and to submit an implementation plan within six months. While the 121 requirement is not expanded to contractors or subcontractors, or entities not directly regulated by the FAA, repair stations are well aware of the “trickle-down effect” when air carriers implement and interface their SMS with contract maintenance vendors. Indeed, in the preamble to the rule, the FAA acknowledges that some air carriers may opt to extend their SMS to part 145 repair station activities. That said, the rule does not require the air carrier to require SMSs on the part of contractors, code-share partners, or other business affiliates

As stated in the NPRM, the FAA developed the framework of the rule as a means of harmonizing with ICAO standards, while establishing a uniform standard that could be extended to apply to 14 CFR part 135 (part 135) certificate holders, part 145 repair stations, and design and manufacturing entities. The uniform standard is necessary because some of these regulated entities may hold more than one FAA certificate and may need or want to create one SMS to encompass all of their aviation-related activities.

The final rule will be effective within 60 days once it’s published in the Federal Register. More information is available on FAA.gov and the FAA’s SMS Office website.