A coalition of aviation trade associations spoke out on behalf of the international maintenance, repair and overhaul market. While the matter at hand was drug and alcohol testing at foreign aviation repair stations, the Aeronautical Repair Station Association says that what is really at stake is international sovereignty, the health of the global aeronautical business community and the safety of the flying public worldwide.
Daniel Fisher, ARSA’s vice president of legislative affairs, told AIN, “The aviation industry is unequivocally united in its belief that this rulemaking has the potential to detrimentally impact the global aviation sector with no real safety benefit. The complexity of the drug and alcohol testing laws of sovereign countries and the need to respect international agreements necessitates ICAO’s involvement, not unilateral FAA action.”
ARSA, which is leading the coalition’s efforts, is joined by the Aerospace Industries Association, Airlines for America, Cargo Airline Association, General Aviation Manufacturers Association, International Air Transport Association, National Air Carrier Association and Regional Airline Association. The coalition submitted comments to the FAA in response to the agency’s advanced notice of proposed rulemaking. The ANPRM is the first stage of a process that could impose testing requirements on aviation maintenance providers around the globe. Additionally, the FAA is considering expanding the rulemaking to include maintenance personnel working at certain non-certified repair stations.
Fisher added, “We’re asking the FAA to remember that good safety is good business. This is a solution in search of a problem, not a good-faith effort to protect the public. In the end, this rule would impose costs on businesses, their customers and passengers worldwide while producing no additional safety benefit.”
The coalition asked the FAA to adhere to congressional language requiring any such rule be “consistent with the applicable laws” of the countries involved.Brett Levanto, ARSA’s operations director, pointed out that this is more than a legal issue. The American imposition of testing requirements could damage bilateral aviation safety agreements (BASAs) and weaken the small businesses that are the industry’s backbone.
He said, “In the lead-up to the FAA’s extension of the comment deadline, our team, mostly Daniel [Fisher] and Crystal Maguire, our vice president of operations, had been hearing a lot from the rest of our allies about all of the work they were doing–or were planning to do–to address the ANPRM. After the extension, everyone got together on a conference call with the simple goal of making sure we didn’t duplicate effort and waste time.”
“After a couple of calls, a really powerful strategy emerged,” Levanto continued. “Let each association focus their own submissions on their strongest areas of expertise and best serve their individual constituencies while joining together to send some kind of single message to the FAA. The coalition comments were a tool for us all to speak with one voice, simply and clearly, and tell the agency that a final rule would be all downside, another burden on businesses without any direct benefit to the flying public.”
The coalition’s perspective is not without critics. The Transportation Trades Department of the AFL-CIO (TTD) submitted comments to the FAA urging the swift implementation of a statute requiring foreign-based aircraft repair facilities working on U.S. aircraft to be held to the same alcohol and drug testing standards as those based in the U.S. “The time is now to end a double standard that has permitted FAA-approved foreign aircraft repair stations to evade significant safety requirements for more than 25 years,” said TTD president Edward Wytkind.