121 north henry street alexandria, va 22314 tel. 703-548-2030 fax 703-299-0254 staying current with...

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121 North Henry Street Alexandria, VA 22314 Tel. 703-548-2030 Fax 703-299-0254 www.arsa.org Staying Current with Regulations 14 October 2015 London, England Daniel B. Fisher ARSA, VP of Legislative Affairs

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Staying Current with Regulations FAA reauthorization proposals dating back to 2008 included provisions that were much worse ARSA, industry allies successfully “tempered” drug & alcohol testing language in FAA Modernization & Reform Act (2012) “Consistent with the applicable laws of the country in which the repair station is located” FAA issued ANPRM in Spring 2014; ARSA organized industry comments NPRM expected in the near future October 14, 2015Copyright © 2015 Obadal, Filler, MacLeod & Klein, PLC Foreign Drug & Alcohol Testing

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Page 1: 121 North Henry Street Alexandria, VA 22314 Tel. 703-548-2030 Fax 703-299-0254  Staying Current with Regulations 14 October 2015 London, England

121 North Henry StreetAlexandria, VA 22314

Tel. 703-548-2030Fax 703-299-0254

www.arsa.org

Staying Current with Regulations14 October 2015London, England

Daniel B. FisherARSA, VP of Legislative Affairs

Page 2: 121 North Henry Street Alexandria, VA 22314 Tel. 703-548-2030 Fax 703-299-0254  Staying Current with Regulations 14 October 2015 London, England

Staying Current with Regulations

• FAA Modernization & Reform Act expired on Sept. 30, but was extended through March 2016.

• Expect amendments that could disrupt international MRO industry in the hopes of driving up costs on maintenance providers, particularly overseas.– Force FAA to Finalize Foreign D&A Testing

Regulations (prohibit FAA certification of foreign RS)– Mandate intrusive background checks for all FAA-

certificated part 145 repair stations– Require surprise inspections

October 14, 2015 Copyright © 2015 Obadal, Filler, MacLeod & Klein, PLC 703 299 0784 • http://potomac-law.com 2

FAA Reauthorization

Page 3: 121 North Henry Street Alexandria, VA 22314 Tel. 703-548-2030 Fax 703-299-0254  Staying Current with Regulations 14 October 2015 London, England

Staying Current with Regulations

• FAA reauthorization proposals dating back to 2008 included provisions that were much worse

• ARSA, industry allies successfully “tempered” drug & alcohol testing language in FAA Modernization & Reform Act (2012)

• “Consistent with the applicable laws of the country in which the repair station is located”

• FAA issued ANPRM in Spring 2014; ARSA organized industry comments

• NPRM expected in the near future

October 14, 2015 Copyright © 2015 Obadal, Filler, MacLeod & Klein, PLC 703 299 0784 • http://potomac-law.com 3

Foreign Drug & Alcohol Testing

Page 4: 121 North Henry Street Alexandria, VA 22314 Tel. 703-548-2030 Fax 703-299-0254  Staying Current with Regulations 14 October 2015 London, England

Staying Current with Regulations

• Effective Feb. 2014: Applies to all Federal Aviation Administration (FAA)-certificated part 145 repair stations (except those located on military bases)

• Implement Security Measures when:– A large (over 12,500 lbs.) aircraft is on repair station

property; and – The large aircraft is capable of flight; and – The large aircraft is “unattended”

• Prevent the unauthorized operation of unattended large aircraft capable of flight by using means outlined in rule.

October 14, 2015 Copyright © 2015 Obadal, Filler, MacLeod & Klein, PLC 703 299 0784 • http://potomac-law.com 4

TSA Repair Station Security Rule

Page 5: 121 North Henry Street Alexandria, VA 22314 Tel. 703-548-2030 Fax 703-299-0254  Staying Current with Regulations 14 October 2015 London, England

Staying Current with Regulations

Page 6: 121 North Henry Street Alexandria, VA 22314 Tel. 703-548-2030 Fax 703-299-0254  Staying Current with Regulations 14 October 2015 London, England

Contact ARSA

121 North Henry StreetAlexandria, VA 22314

Tel. 703-548-2030Fax 703-299-0254

[email protected]

May 28, 2015 Copyright © 2015 Obadal, Filler, MacLeod & Klein, PLC 703 299 0784 • http://potomac-law.com 6