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IAM Address NPRM Calling For Tighter Regulations Of Aircraft Repair Stations
By Steve Hall

November 28, 2012 – International Association of Machinists and Aerospace Workers “(IAM) represented aircraft mechanics have set the gold standard in aircraft maintenance. They ensure the airworthiness of aircraft and enable people to travel the world safely. This standard is at risk as the outsourcing of critical safety sensitive aircraft repairs has become the operating norm in an environment where air carriers “forum shop” for cheap labor costs and lax regulations” said IAM’s General Vice President, Sito Pantoja. 

For more than 25 years the IAM has been a vocal critic of federal repair station regulations. Current regulations create risky incentives for US carriers to outsource aircraft maintenance to poorly regulated facilities abroad that do not meet the same rigid FAA safety requirements as do facilities in the United States. The poorly crafted regulations have resulted in the loss of thousands of highly skilled US mechanic jobs at most U.S. airlines (see American Airlines To Outsource Aircraft Maintenance To China). 


“It’s up to the FAA to close loopholes in air safety regulations that incentivize US airlines to outsource aircraft maintenance overseas,” said Pantoja. “We strongly urge the FAA to adopt the changes offered by the IAM.” In a letter Pantoja submitted to Michael Huerta, FAA Acting Administrator in response to the Federal Aviation Administration's (FAA) Notice of Proposed Rulemaking (NPRM) which seeks to reform the rules governing aircraft repair stations certified under Part 145. Patoja stated that for more than 25 years the IAM has been a vocal critic of federal repair station regulations for two main reasons; they create dangerous incentives for U.S. air carriers to outsource maintenance to poorly regulated facilities abroad that fail to meet the same rigid FAA safety requirements imposed on work performed on U.S. soil; and they have resulted in the loss of thousands of high-skill, middle class U.S. mechanic jobs at most U.S. airlines.

Pantoya further stated that IAM agrees with the FAA that it is time to upgrade current regulations to reflect the reality of today's marketplace where more than 70 percent of aircraft heavy maintenance is outsourced and more than one-fourth farmed-out overseas. A byproduct of this stunning growth in outsourcing has been the increased use of non-certified repair facilities that often evade the FAA's inspection and oversight regime. 

IAM is concerned that the current NPRM fails to require mechanics at foreign repair stations to undergo drug and alcohol testing as mandated in section 308(d) of the FAA reauthorization signed into law earlier this year. However, in the NPRM it mandates that the FAA issue a proposed rule to implement the new drug and alcohol requirement within one year of enactment. IAM sees this as a double standard in federal regulations that has forced mechanics in America to operate under completely different rules than those who work overseas. This is not only a critical safety loophole that must be closed, but it has also forced U.S. airline mechanics to compete on an un-level playing field.



IAM agrees that the NPRM fails to close an important regulatory loophole, which today means that repair station supervisors based abroad are not meeting the same part 65 certification requirements as supervisors based in America. This double standard compromises safety and makes no sense in an era where more and more work is being outsourced. IAM has long expressed concern over the role of foreign aviation authorities in the certification process and oversight of repair stations. As a general principle IAM has always questioned the wisdom of "outsourcing" U.S. government aviation safety oversight to a foreign government authority. Under current rules, the FAA can issue a certification to foreign repair facilities based upon findings by a foreign civil aviation authority that the facility complies with FAA requirements. 

IAM is concerned that the FAA is still failing to restrict the subcontracting of maintenance work to non-certificated facilities despite the fact that Congress attempted to address this concern in section 319 of the latest FAA reauthorization. While this proposed rule requires the certificated station to provide oversight, IAM feels it must also ensure that any work sent to non-certified facilities also receives direct supervision and consistent with section 319.

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