On Feb. 1, ARSA requested the FAA immediately cease requiring air carrier and repair station applicants and certificate holders to complete the data collection tools (DCTs) associated with the agency’s Safety Assurance System (SAS).
ARSA’s letter highlights the Paperwork Reduction Act’s prohibition against federal agency information collection without approval from the Office of Management and Budget. The law restricts government entities from calling for “answers to questions posed to, or identical reporting or recordkeeping requirements imposed on, ten or more persons, other than agencies, instrumentalities, or employees of the United States.”
According to the Flight Standards Information Management System (FSIMS), DCTs are to be used by aviation safety inspectors to assess the design and system performance of an applicant or certificate holder under parts 121, 135 and 145. DCTs are composed of numerous questions gathering information at the system, subsystem or element level organized according to the six safety attributes identified by the agency.
The letter describes how inspectors gather this information by providing the DCTs to the cmopany and requiring the applicant or certificate holder to answer the questions. Considering the substantial time and expense demanded by this requirement, ARSA reminded the FAA of its statutary obligations.
“We recognize that the agency has instituted the SAS to implement a risk-based approach to its safety oversight responsibilities,” the letter said, noting the demand placed on the FAA by Congress as well as executive branch auditors to implement reasonable safety oversight with limited resources. “However, those pressures do not relieve the agency of its obligations under the laws passed by Congress; particularly those that reduce the burdens on small businesses.”
On behalf of the majority small-business community of FAA-certificated repair stations – in addition to many other resource-constrained aviation stakeholders – the association requested the FAA stop requiring completion of DCTs by the public until proper OMB approval is obtained.
To read the full letter, click here