ARSA CORNER CBEYOND CRISIS BY BRETT LEVANTO, VICE PRESIDENT OF OPERATIONS, AERONAUTICAL REPAIR STATION ASSOCIATION
RESPONDING TO THE MANY MINI CRISES BROUGHT ON BY THE CURRENT PANDEMIC CAN BE DISORIENTING. TRYING TO SURVIVE EACH DAY, SHORING UP STRUGGLING LINES OF BUSINESS, ADDRESSING IMMEDIATE PERSONNEL ISSUES AND OVERCOMING REGULATORY AND BUSINESS HURDLES CAN DISTRACT FROM THE “BIG PICTURE.”
While dealing with all these challenges can be exhausting, the disruptions caused by the pandemic can also be a catalyst to finding better ways to do things. Being innovative in addressing today’s problems will actually serve your long-term interests and potentially prod your company (and the industry as a whole) to adopt practices we should have been doing all along. From ARSA’s perspective,
using remote connectivity is the best example of a better way to work in the “new normal”. Every maintenance facility should be taking advantage of technologies — from basic smartphone video-chat apps to advanced industry communications tools — for regular business, and particularly to facilitate inspection and oversight. There is a sound regulatory basis to allow you to do just that. In 2018, ARSA led an industry- wide effort to confirm that the FAA’s rules allow for the use of real-time connections using communications tools. That engagement resulted in Aircraft Certification and Flight Standards agreeing the regulations did in fact allow for certificate holders and the government to make use of such tools. Having clarified that right, an ARSA-led coalition of 16 trade
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associations and businesses submitted to the FAA an industry-supported draft advisory circular outlining standards for oversight, inspections and testing performed using systems as simple as personal mobile devices. To facilitate the use of the best
available technology, the draft AC established general requirements for set up and use of tools and equipment. The elements outlined in the document were to assist users in ensuring “the same level of acumen and capability [through remote connection] as if the oversight, inspection, test or training task or activity was conducted on-premises.” In its quick response, the FAA promised to publish supportive guidance before the end of 2019. (We know now it would fail to meet that goal but would be moved to action by an unprecedented crisis.) On March 15 of this year, the White House issued a memorandum directing government agencies to realign operations to slow the spread of the current virus. The memo instructed agency leaders to “utilize the full extent of their legal authority and discretion to execute this realignment” and to “maximize telework … while maintaining mission-critical workforce needs.” The impact of COVID-19 was just beginning to be felt, but a clear
message had been sent to continue work, whenever possible, from a distance. ARSA seized on that direction to remind the industry and agency about the work both had done on remote connectivity. On March 31, the FAA’s Aircraft
Certification Service finally issued its policy on use of remote technology. Although the guidance claims it does not add burdens to industry, its general consideration adds the elements of “complexity, novelty, and safety criticality of the product, article or system.” Therefore, it will be up to “applicants” to ensure requests to use the technology conform to the ultimate requirement to “… enabl[e]…proper performance of duties” in spite of – or despite – the general elements that are supposed to be considered. On April 22, the Flight Standards
Service issued its own guidance – in the form of a memorandum to AFS employees – regarding remote connectivity applications. Under the subject “Use of Video and Communication Technology (VCT),” the memo made clear that use of such tools is allowed under the aviation safety rules: “Current FS Orders and [FAA]
regulations do not prohibit FS or industry use of VCT in fulfilling the requirements, and no specific
OMMUNICATIONS
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