Urgent Action Needed By All PASS Members

It is our understanding that the FAA reauthorization bill (H.R. 915) may come to the House floor for a vote next week. As you know, this bill contains several critical provisions of importance to PASS; however, PASS has been made aware that there is a move by some members of the House of Representatives to strike or modify Section 303 of the bill, which mandates that all FAA-certificated foreign repair stations must be inspected at least twice a year by an FAA inspector and that all workers performing maintenance on U.S. aircraft at foreign repair stations be drug and alcohol tested.

We need you to immediately make contact with your House representative to convey the importance of this provision. Please take a moment to send the attached letter to your member of Congress in the House. We also ask that you follow up that letter with a phone call to your member telling your representative to oppose any attempt to weaken or modify Section 303 of the FAA reauthorization bill (H.R. 915).

Sample Letter for Campaign

Subject: Please Support Section 303 of H.R. 915

Dear [ Decision Maker ] ,

As an employee of the Federal Aviation Administration (FAA) and a member of the Professional Aviation Safety Specialists (PASS), I am writing to ask you to support the men and woman who protect this country's aviation system by working to pass the FAA Reauthorization Act of 2009 (H.R. 915). This bill contains many provisions of critical importance to the safety of the aviation system and the employees of the FAA. In particular, I want to bring your attention to Section 303 of the legislation, which mandates that FAA-certificated foreign repair stations be inspected at least twice a year by an FAA inspector and that all workers performing maintenance at FAA-certificated foreign repair stations be drug and alcohol tested. I am asking that you support Section 303 of the legislation and oppose any attempts to weaken or eliminate this language.

With the increasing amount of work being performed by FAA-certificated foreign repair stations, it is important that this country ensure the safety of all U.S. aircraft. A Department of Transportation Inspector General study of nine major air carriers revealed that foreign repair stations performed 27 percent of outsourced heavy maintenance work in 2007. Allowing FAA inspectors to inspect FAA-certificated foreign repair stations at least twice a year will protect the growing amount of work being done overseas. Furthermore, as opposed to domestic airline or repair station employees, workers at foreign repair stations are not required to pass drug and alcohol tests. If an FAA-certificated foreign repair station wants to perform maintenance on U.S.-registered aircraft or any aircraft that operate in this country, those repair stations should be required to meet the same safety standards as repair stations in this country.

The United States has the safest aviation system in the world due to the hard work and commitment of FAA employees. In order to maintain this standard, please oppose removing or weakening the language contained in Section 303 of H.R. 915.

Sincerely,

Campaign Launched:
May 15, 2009

Background Information

Oversight of Foreign Repair Stations

FAA aviation safety inspectors responsible for overseeing the certification and recertification of the work performed at foreign repair stations have concerns regarding the oversight of these facilities. Whereas much of this maintenance work was once done at the air carrier's facility, according to the IG, major air carriers outsourced an average of 64 percent of their maintenance expenses in 2007, compared to 37 percent in 1996.For the most recent report, the IG reviewed nine major air carriers. These carriers sent 71 percent of their heavy airframe maintenance checks -including performing complete teardowns of aircraft - to repair stations in 2007, up from 34 percent in 2003. Foreign repair stations performed 27 percent of outsourced heavy maintenance checks for these nine air carriers in 2007, up from 21 percent in 2003.

FAA inspectors at international field offices are charged with certifying foreign repair stations and then recertifying them approximately every two years. In addition, FAA inspectors at certificate management offices in this country provide oversight of the maintenance work performed on their assigned air carriers at FAA-certificated foreign repair stations. However, with the increasing amount of work being performed at FAA-certificated foreign repair stations, inspectors have expressed concern that safety issues are not being addressed. In order to ensure the safety of the work performed on U.S. aircraft at foreign repair stations, it is critical that FAA inspectors be permitted to physically inspect foreign repair stations at least twice a year.

The FAA should not have to rely entirely on data submitted by a foreign aviation authority but should be permitted the opportunity to validate the accuracy of such data through FAA inspections of the foreign repair stations. This is especially important when it has been revealed that information provided to the FAA by foreign entities is often found to be incomplete. In fact, according to the IG, foreign authorities do not always provide the FAA with sufficient information on what was inspected and the problems discovered. The IG revealed that inspection documents given to the FAA were found to be incomplete or incomprehensible in 14 out of 16 files (88 percent) examined by the IG. The IG even stated that at least one foreign authority representative said that "they did not feel it was necessary to review FAA-specific requirements when conducting repair inspections." The questions surrounding the information provided by foreign aviation authorities make it critical that FAA inspectors be permitted to inspect foreign repair stations at least twice per year.

There is also considerable concern over the regulations governing foreign repair stations. For example, as opposed to domestic airline or repair station employees, workers at foreign repair stations are not required to pass drug and alcohol tests. In addition, criminal background checks are not required at foreign repair stations. There also continues to be major concerns regarding security at these facilities, with many of the foreign repair stations lacking any security standards as opposed to those in this country. Domestic repair stations are also required to have at least one FAA-certificated individual at the facility in order to approve an airplane or part for return to service, while this is not a requirement at foreign repair stations. If a foreign repair station wants to perform maintenance on U.S.-registered aircraft or any aircraft that operate in this country, those repair stations should be required to meet the same safety standards as domestic repair stations.

In order to ensure that the work performed at foreign repair stations meets FAA and air carrier standards, PASS believes that all FAA-certificated foreign repair stations should be inspected at least twice a year by an FAA inspector and all workers working on U.S. aircraft should be drug and alcohol tested. Requiring two inspections of FAA-certificated foreign repair stations working on U.S. aircraft should be the minimum standard for this country to protect the work being performed by foreign repair stations.