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TSA Aircraft Repair Station Security Proposed Rulemaking
March 1, 2010
NBAA earlier this month weighed in on a proposal from the Transportation Security Administration (TSA) requiring FAA-certificated Part 145 domestic and foreign aircraft repair stations to implement a standard security program, and comply with a new mandates from the Agency. The proposed rule comes in response to a directive in the Vision 100 - Century of Aviation Reauthorization Act. NBAA's comments emphasize that repair stations located off airports should not be included in the regulation, and that repair stations not working on airline aircraft should be exempted.
Detailed Analysis of the Aircraft Repair Station Security NPRM
Repair Station Standard Security Program
TSA is proposing that each FAA certificated repair station implement and carry out a standard security program issued by TSA to mitigate the risk of their facility being targeted for terrorist activity. However, the TSA recognizes that a "one size fits all" approach is not appropriate for all repair stations and based on their risk analyses, has proposed to not include all of the same security measures for those repair stations with a lower risk profile, such as those repair stations not situated on or adjacent to an airport or those repair stations located on airports that only serve aircraft with a maximum certificated takeoff weight of 12,500 pounds or less.
The TSA also noted in the proposed rule that if a repair station is already incorporated within an airport's security program and uses the airport's access control measures, TSA will consider the repair station to be in compliance with the security measures proposed in these regulations. As well, repair stations located at facilities for which the Federal Government has assumed responsibility for security measures, such as a U.S. military base, would not be required to comply with this rule as TSA believes that the security at such a facility would likely meet and exceed the security requirements propsed in this rule.
The regulations propose that the following items must be included in a repair station standard security program:
- a description of the measures used to identify individuals who are authorized to enter the repair station to prevent unauthorized individuals from entering the repair station;
- a description of the measures used to control access to the repair station and to detect and prevent the entry, presence, and movement of unauthorized individuals and vehicles into or within the repair station;
- a description of the measures used to control access to the aircraft and/or aircraft components to allow only authorized individuals to have such access;
- a description of the measures used to challenge any individual entering the repair station to ascertain the authority of the individual to enter or be present in the repair station and measures to escort an individual who does not have unescorted authority while within the repair station;
- a description of the measures to train all individuals with authorized access to aircraft and components on the provisions of this part and the security program;
- a description of the measures used to verify employee background information through confirmation of prior employment and any other means as appropriate to validate employee information;
- the name, 24-hour contact information, duties, and training requirements of the designated security coordinator who will serve as the primary and immediate contact for security-related activities and communications with TSA;
- a contingency plan;
- a diagram with dimensions detailing boundaries and pertinent physical features of the repair station;
- a list and description of all entry points; and
- an emergency response contact list.
The regulations also would require that the security program be in writing, and signed by the repair station operator, owner, or other authorized person. Each repair station would not have to submit the security program to TSA, but would have to make it available to TSA upon request or during an inspection.
Repair Station Profile
To assess the security risks of a repair station and to establish the priority by whcih repair stations must be inspected, the TSA would require each repair station to provide a brief profile, to include general information such as location, whether the repair station is located on or adjacent to an airport, the total number of employees, and the number of employees with access to large aircraft. The TSA notes that some of this information is available through existing FAA records, but not all of it.
The proposed regulations would codify TSA's inspection authority and would require repair stations to permit TSA and DHS officials to enter, inspect and test property, facilities and records relevant to repair operations. The purpose of the inspection would be to assess threats to aviation security, enforce TSA security regulations, directives and requirements, evaluate all aspects of the repair station security program, verify whether the security program is being implemented and whether it is effective, as well as to identify and correct security deficiencies.
In the event that a security inspection identified deficiencies, the TSA would notify both the repair station and the FAA and the repair station would have 90 days to correct the deficiencies. If the deficiencies are not corrected within 90 days, the TSA would notify the FAA that it must suspend the repair station's certificate until such time as the TSA determines that the deficiencies are resolved. The proposed regulations also contain a process whereby a repair station may further request review of TSA's determination regarding security deficiencies.
Immediate Risk to Security
The proposed regulation contains a specific process whereby a repair station that poses an immediate risk to security is identified and the FAA is notified of such a determination. The FAA must revoke the certificate of a station that TSA determines poses an immediate risk to security. Whether the threat is immediate would be evaluated on a case by case basis considering existing and potential circumstances as information is received and analyzed. The proposal provides a repair station with the opportunity to obtain the releasable materials upon which the determination was made and to seek review of such a determination.
NBAA Resources for Understanding, and Commenting on, the TSA's Aircraft Repair Station Security NPRM
- Download the Aircraft Repair Station Security NPRM
- View the Public Docket
- Direct Member Support
NBAA Members needing more information about the TSA's aircraft repair station security NPRM should contact NBAA's Doug Carr, at firstname.lastname@example.org or (202) 783-9259.
Repair Station News
Associations Urge TSA to Complete Repair Station Security Rules by Year-End
August 27, 2012
NBAA, along with 10 other aviation associations, is asking Department of Homeland Security Secretary Janet Napolitano for confirmation that the Transportation Security Administration (TSA) will finalize requirements for Federal Aviation Administration (FAA)-certified foreign repair stations by the end of the year. The aviation groups assert that a congressional mandate blocking the FAA from certificating additional foreign repair stations until the TSA issues security requirements for FAA-certified repair stations has inhibited the ability of the industry to support the growing number of business aircraft overseas. Learn more about foreign repair stations. .