ARSA Dispatch
July 29, 2009
ARSA Legislative Conference Call Update
On July 23, the ARSA legislative team hosted a conference call to update membership on the status of the Federal Aviation Administration reauthorization bills currently before Congress. Particular focus was given to the recently introduced Senate FAA reauthorization bill (S. 1451) and its differences from the House bill (H.R. 915) passed in May. While ARSA remains opposed to any attempts by Congress to micro-manage the FAA, the Senate bill was recognized as containing improved language over that found in the House counterpart. The sections of the Senate bill addressing oversight of foreign repair stations (Sec. 521) and use of non-certificated maintenance providers (Sec. 521) were thoroughly discussed. For additional information on the House and Senate bills, please see ARSA’s side-by-side comparison available here.

In addition to discussing the status of legislation on Capitol Hill, the call also served to remind members how effective (and easy) it is to become involved with elected representatives. Such interaction is particularly important as both chambers of Congress prepare to recess for the summer work period in August and early September.

On Thursday, July 23, 2009 the Federal Aviation Administration (FAA) released the long anticipated advanced notice of proposed rulemaking (ANPRM) on Safety Management System (SMS). The purpose of the ANPRM is to solicit public comment on potential rulemaking requiring 14 CFR part 21, 119, 121, 125, 135, 141, 142 and 145 certificate holders (product/service providers) to develop an SMS. The ANPRM does not propose specific rulemaking language; rather it requests information from industry by asking 17 questions, the answers to which may help the FAA in developing a final proposal.

In February of this year, the FAA formed an industry Aviation Rulemaking Committee (ARC) to review and disposition the ANPRM comments. The ARC has met four times and formed three working groups; Operations and Training, Design and Manufacturing, and Maintenance. The working groups will disposition the comments as they address each of their areas of responsibility.

Comments are due Oct. 21, 2009 and may be submitted by clicking here and entering Docket Number FAA-2009-0671.

A copy of the ANPRM may be found here.

How Durable Are Your PMA Parts?
Advisory Circular (AC) 33.87–2, Comparative Endurance Test Method to Show Durability for Parts Manufacturer Approval (PMA) of Turbine Engine and Auxiliary Power Unit Parts, is now available. The AC describes a comparative endurance test method to use for certain turbine engine or auxiliary power unit PMA parts.

For a copy of the AC click here.

FAA Sponsors TSO National Workshop
This Federal Aviation Administration (FAA) sponsored workshop will bring together individuals from FAA Headquarters, Certification Directorates, including the Aircraft Certification Offices, industry and other civil aviation authorities including the European Aviation Safety Agency (EASA), and Transport Canada, Civil Aviation (TCCA) for a collaborative discussion about Technical Standard Orders (TSO) and European (E)TSO programs.
The workshop will include presentations on the TSO and ETSO programs, which will include the following discussions:
Aviation authorities and industry personnel, including avionics manufacturers, installers and Supplemental Type Certificate holders, who work with TSOs or ETSOs are encouraged to attend. The workshop runs from Sept. 1-3, 2009 and is held at the FAA Southern Regional Office, 1701 Columbia Ave., College Park, GA 30337.

More information on the workshop is available here.

"Not So Fast"
Jack Brodbeck, ARSA's guest author on export compliance issues points to a recent AP release as a more realistic news article on the Obama administration's posture on the Department of State policy on exporting to Syria than articles run in The Wall Street Journal and The New York Times on July 28. Jack’s highlighted AP release can be found here.

Part Marking AC Open for Comment
Draft Advisory Circular (AC) 43-PM, Parts Marking Identification is currently open for comment. The AC provides information and guidance on developing procedures for part marking and part re-marking when performing maintenance, alteration and fabrication, including the fabrication of owner-produced parts.

Comments are due Aug. 9, 2009, and may be sent by clicking here.

A copy of the draft AC may be found here.

Where Did I See Those Life-limited Items Again?
The Federal Aviation Administration issued a draft policy statement concerning life-limits and Instructions for Continued Airworthiness (ICA). The purpose of the policy statement is to clarify that certain life-limited items, in addition to those specifically required by 14 CFR §§ 27.571 or 29.571, should be included in the Airworthiness Limitations Section (ALS) of the ICA for rotorcraft.

Appendix A of both part 27 and 29 states that the ALS must set forth each mandatory replacement time, structural inspection interval and related structural inspection procedure approved under §§ 27.571 or 29.571. However, other mandatory replacement times, mandatory inspection intervals and related procedures associated with structural integrity are also appropriate for inclusion in the ALS. The policy, along with an upcoming rulemaking, helps clarify that other life limits can be included in the ALS.

Comments are due Aug. 10, 2009, and may be sent here.

A copy of the draft policy may be found here.

FAA to Reconsider Air Tour Operator Maintenance
from CharterX
The FAA has issued a Notice of New Task Assignment for the Aviation Rulemaking Advisory Committee (ARAC) to develop maintenance requirements for aircraft used in commercial air-tour operations as covered in 14 CFR Part 136–Commercial Air Tours and National Parks Air Tour Management. More

S.C. Groups Team Up to Improve Skills of Greenville County Workers
from The Greenville News
A dozen Greenville, S.C. groups encompassing public, private and nonprofit interests have banded together to battle what they see as Greenville County's most critical shortcoming — a work force lacking skills for jobs that would lift the community's collective income. More

NTSB: Planes At Increasing Risk from Large Birds
from The Associated Press
Aircraft design standards aren't tough enough for planes to withstand collisions with growing numbers of large birds, safety investigators examining an Oklahoma crash that killed five men recently said. More

Congress to Toughen Airline Standards
Safety standards for airlines and pilots would be dramatically toughened in legislation scheduled to be introduced Wednesday in Congress. Prompted by the crash last February near Buffalo that has raised questions about pilot qualifications, training and fatigue, the "Airline Safety and Pilot Training Improvement Act of 2009" aims to find the most successful safety programs and mandate them for all airlines, said Rep. Jerry Costello, D-Ill., chairman of the House Aviation Subcommittee. More

Final Documents/Your Two Cents
from ARSA
ARSA now keeps a list of Final Documents and Your Two Cents on its Web site By accessing the links (provided in blue) you will find a complete list of items the Association has noted as important to aviation design, production and maintenance activities. Final Documents: This list includes Federal Register (FR) publications such as proposed and final rules, Advisory Circulars (ACs), Orders, Notices, policy statements and related material of interest to ARSA members. The date shown is the date of FR publication or other official release. Your Two Cents: Provides you with the opportunity to provide input on rules and guidance that will affect you. Agencies must provide the public with notice and an opportunity for comment before their rules change. Your input matters. Comments should be received before the indicated due date; however, agencies often consider comments they receive before drafting of the final document begins. More