An official for the National Air Transportation Association said that of all the rules enacted in the name of air security, the Transportation Security Administration’s latest NPRM directed at maintenance centers isn’t as bad as some have been. “I have to give TSA credit where credit is due,” said Eric Byer, vice president of government and industry affairs the NATA. “After the first go-around raised a lot of controversy, TSA met with industry, did some surveys and definitely did their homework.”
Representing U.S. maintenance, repair and overhaul facilities, NATA has responded to the NPRM with a point-by-point letter. Originally, TSA sought to impose essentially the same security restrictions on all repair stations even if they were a small upholstery shop not located on an airport. Industry reaction was swift and loud.
In the latest version of the Aircraft Repair Station Security NPRM, TSA takes into consideration the size and type of aircraft repair station to which employees have access. It also recognizes varying levels of security considering the type of work permitted by the repair station’s certificate, the location of the repair station (on airport vs. off airport) and the number of employees.
“They have carefully worded this rule,” Byer said. “If you’re an avionics shop 50 miles from the airport you’re not a real security concern and now TSA accepts that reality. I think they’re seriously trying to identify the risks and act accordingly.” The good news for MROs located on CFR Part 1542 commercial airports is as long as they’re in compliance with the airport’s security procedures, it appears they’re not going to have much more to do to be in compliance, he said.
“The kicker here is the Standard Security Program (SSP) that’s going to be one of the requirements for Part 145 operators. It’s true that TSA appears to be flexible now and willing to scale the individual requirements based on the size and location of the operation but the devil’s in the detail and some of those details have yet to surface. We’ll have to work with TSA down the road and I reserve the right to change my mind as this unfolds,” Byers said.
The NPRM proposes, in its preamble, that the requirements of the SSP would vary depending on the level of risk associated with a specific repair stations. It states the regulatory changes contained within the NPRM have been instituted to “prevent persons from commandeering, tampering or sabotaging aircraft” and to “mitigate the potential threat that an aircraft could be used as a weapon.”
The NPRM in its current form calls for the identification of individuals with authorized access–and requires controlled access–to the repair station, aircraft and aircraft components. It calls for challenging unauthorized individuals, instituting escort procedures for authorized visitors, providing security awareness training to employees, verifying employee background information and designating both a security coordinator and contingency plan.
Additionally, the NPRM would give TSA inspection authority over repair stations, require repair stations to comply with TSA-issued security directives and establish a process whereby the agency would direct the FAA to suspend the certificates of noncompliant repair stations and repair stations it deemed an “immediate risk to security.” It also will require all repair stations to submit a “profile” to the TSA.