Noverant Guidance for Part 145 Repair Stations - Preparing For New TSA Security Requirements

The United States Transportation Security Administration (TSA) has released new security requirements for Part 145 repair stations under a new section titled 49 CFR 1554 - Aircraft Repair Station Security. Noverant has completed a review of the new code and summarized key points for repair stations.

Summary of 49 CFR 1554

The requirement imposes security-related process, documentation and record keeping requirements on all Part 145 repair stations. Particular focus is given to those stations serving large aircraft (12,500 lbs) or operating on/near airports with established airport security programs per 49 CFR part 1542 or equivalent foreign airports. Note that the regulation is not applicable to repair stations that are located on U.S. or foreign military installations.

Part 145 Repair Stations (US Locations)

All Part 145 repair stations must allow TSA and other authorized DHS officials, at any time and in a reasonable manner, without advance notice, to enter, conduct any audits, assessments, or inspections of any property, facilities, equipment, and operations; and to view, inspect, and copy particular records as necessary to carry out TSA's security-related statutory or regulatory authorities.Part 145 repair stations serving large aircraft or on/near airports governed by an airport security program must also provide TSA with the name and means of contact, on a 24-hour basis, of a person or persons designated by the repair station as the primary security point of contact with responsibility for overall security compliance to 49 CFR 1554 and communications with TSA.In addition, these stations must maintain accurate records for those employees with access to large aircraft; develop documented key control, aircraft access and related procedures; and maintain appropriate records for evidence of compliance. In addition, specific background checks for various individuals are required and documented procedures must be implemented to receive, protect and respond to TSA-issued security directives.

Part 145 Repair Stations (Non-US Locations)

Part 145 repair stations based outside the United States must abide by the same requirements, including documented evidence of compliance, as US-based stations. Further, all records must be provided in English upon TSA's request.

Recommendations

Repair stations should carefully develop an efficient program to address the new requirements as soon as possible. In most cases, particularly for stations conducting business in English, compliance will not be a major burden after the security program is initially established and an efficient compliance management system is in place. However, Noverant cautions repair stations that compliance and enforcement of these new security rules should be taken seriously and requires immediate attention. According to the new TSA requirement, a repair station may be subject to suspension of its FAA certificate if security deficiencies are identified and are not corrected in a timely fashion.

Noverant is approved by TSA for the storage of Security Sensitive Information (SSI) and has developed applicable standard operating procedures (SOPs) to address 49 CFR 1554. Repair stations are encouraged to contact Noverant to discuss  customization of these SOPs for their particular need.

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