will come to order the subcommittee is meeting today to receive testimony on the security of foreign repair stations our witnesses will help us assess the security of these facilities and how stakeholders have been working together to ensure the safety and security of the traveling public i now recognize myself for an opening statement i think it's important to note that this hearing is crucial because all the stakeholders have finally come together but i also think this hearing is crucial in the backdrop of recent news reports on the inspectors comments on foreign repair stations the general representation of that particular report is unacceptable though we are here to factually assess where do we go next we know we have a problem and that problem must be fixed and it must be addressed quickly we're gratified that we have not only representatives from the government but we have representatives from the private sector who we know has worked very hard on these issues and well we are pleased to have those who work in these  present as well just yesterday the t s a issued a notice of rulemaking which i will weave into our ultimate discussion and i would applaud that only to say that i will be interested in why it took so long what is the next step and how we'll be able to proceed so we are here today to discuss the security of foreign repair stations and how the federal government will carry out an inspection program that will protect the flying public long been concerned with the safety and security of aircraft repair stations and after following recent news stories raising oversight problems i decided to call this hearing my view is that if the inspector general in the media or discovering safety oversight issues security vulnerabilities may exist as well accordingly we need to address these comprehensively and immediately congress is already on record asking t s a to develop a security program for farm repair stations and after years of delay under the past administration the agency has finally released its notice of proposed rule making for repair station security which i just mentioned and we applaud that but time is of the essence and i might suggest that safety and security of very much intertwined but our abilities and safety are open doors on the question of security codifying the security oversight of foreign repair stations has never been more essential according to the part of the transportation inspector general foreigner pairs stations has more than doubled from three hundred forty four to seven hundred ninety one might accept that as positive growth and i do recognize that as our industry grows the need for  stations internationally is important but again the question is how effective is a certification and how concerned are those who are sort of flying in issues of safety and security and whether or not there needs to be a collaborative effort between the department of homeland security and the department of transportation in a way that security is as much an issue as safety clearly domestic air carriers are outsourcing more and more repair maintenance work to foreign repair stations and important questions have been raised about the security of these stations and the security threat associate with their workers to be clear i understand that we live in a globalized economy but we have to be sure that this is not at the expense of security today's hearing is not intended to end the use of foreign repair stations but from my perspective it is to enhance the scrutiny provide intense regulation and to determine whether or not these efforts are as trustworthy and secure as they possibly can be but i believe it is also to determine best practices with the passage of two thousand two thousand and three epic reauthorization legislation vision one hundred congress directed released its regulations almost two years later i was so frustrated by the delay in the issuance of the n p r am i included language in the t s a authorization bill h r twenty two hundred that required t s a to release it in consultation with f a a now that the rule making has been released i have several questions and concerns for example the law requires consultation and communication between t s a and f a a in developing and assessment of these repair stations and in suspending their certifications should security discrepancies a vulnerability remain unaddressed it may need a new look at this more than consultation between the two entities it also directs f a a to revoke a sort of occasion should t s a discover an immediate security risk at the reapers base and while this relationship between f a a and t s a forms a crux of an effective security oversight program the n p r and it's unclear in describing how the agencies will work together to implement these processes and the aftermath of such congress also needs clarification on the frequency of security audit and inspections following t s a as an initial review of f a a certified far repair station although the law is silent on this issue we are interested in the agency developing a program that will provide consistent and periodic oversight of security at foreign repair stations in light of the issues i just raised i look forward to hearing more that from t s a and f a a in order to acquire answers to my concerns for the second panel i want to hear about the extent to which stakeholders have been consulted on n p r am and what they feel should be included in any final rule we want to see the establishment of an effective robust security oversight program for foreign repair stations so that we can finally address  workers this subcommittee will continue to oversee the implementation of this important security program and support policies and protocols that will strengthen our homeland security efforts the chair is now pleased to recognize the gentleman from texas happy to be sitting in for ranking member charlie dent today and i'd like to thank all the witnesses again for being here and certainly nice to have t s a with us again and very good to see the department of transportation and the federal aviation mystery before this subcommittee as we all know the responsibility for oversight of safety and security of air transportation is divided between the f a a and the t s a but it is indeed essential that the f a a and the t s a work jointly together on many aviation issues as they are required to do so on the issue of foreign and domestic repair stations are second panel is a comprehensive panel of both the unions and the industry everyone has a voice here today and we should really be able to explore all the issues related to foreigner pair station security i look forward to a very productive discussion in the aftermath of aftermath of terrorist attacks on september eleventh congress to pass t s a with the responsibility of issuing regulations on both domestic and for repair station security by august two thousand and four understand the t s a announced a knows a proposed rule making this week was disappointing that it took t s a over six years to commence rulemaking process on a pair of station security we do appreciate their stance at t s a directed its limited resources to more pressing security matters that the vela as higher priorities over the years there is no question that for repair station security is important and that a potential vulnerability that bad people including terrorists however we should take note that despite the issuance a a formal regulations on repair stations security there are currently security measures at four repair stations in place and while we are aware of the departure of transportation inspector general's two thousand a report that cited some issues  exists and is very good these measures will all be enhanced by the more formalized regulations that t s a has announced this week we should also be mindful that security does not begin and end with the for repair viability shut out the for repair station market would be catastrophic we should also be mindful that international flights by foreign air carriers in the u s has increased over the last decade and that means penny for an aircraft are being repaired and maintained by u s repair stations that means more jobs here in the u s in fact i'm told that in the fifty billion dollar repair station market nearly twenty billion of those dollars are generated in the u s and canada and homeland security we strive to strike a balance between security and the free flow of information commerce and trade and i believe that adequate security measures at bor paris stations are in place and that they will only be enhanced and more formalized by t s a as repair stations security regulations and i look forward to working with both t s a and f a a on this issue to acknowledge that other members of the subcommittee are reminded that on the committee rules opening statements may be submitted for the record i welcome our first panel witnesses our first panel our first witness is mr calvin scoville the inspector general of the department  office set standards for the certification oversight of foreign repair station i do want to note that the invitation went to the f a a administrator and i hope that our committee will have an opportunity for  is responsible for security and foreign repair stations i should note my welcoming of t s a issuance of it's long overdue n p r am for securing these stations and we hope this testimony today will be helpful and how t s a proceeds and we hop your testimony or in the questioning you will advise us of that i think today's hearing is going to be an important discussion and we welcome you without objection the witness statements will be inserted in the record i now ask each witness to summarize his or her statement for five minutes beginning with mrs couple of you recognize five minutes madam chairwoman congressman olson members of the subcommittee we appreciate this opportunity to testify on f a a has oversight of domestic and foreign repair stations air carriers use of repair stations has increased significantly both in the volume and type of river road repairs outsourced in two thousand and seven nine major carriers sent over seventy percent of their heavy airframe checks to repair stations double what was sent just four years earlier and more than a quarter of these repair stations were foreign while most repair stations are domestic the number of foreign repair stations certificated by f a a has more than doubled during the last fifteen years to over seven hundred despite these increases f a a has oversight lacks the rigor needed to ensure repair stations meet f a a safety standards over the past decade we have consistently reported weaknesses and f a a has oversight and have made numerous recommendations and removing these weaknesses and closing identified safety gaps in addition in two thousand and three we reported security vulnerabilities at repair stations including suicide susceptibility to sabotage while f a a oversees repair station safety and operations d h s oversee their security madam chairwoman we have previously provided copies of our two thousand and three security report as redacted by t s a because it originally included sensitive security information i request that this report be entered into the record at this time without objection sell or today i will discuss our longstanding concerns with f a a as oversight and the actions still needed to improve safety and security at repair stations first f a a continues to lack the data needed to effectively oversee its outsourced repair work in response to our past recommendations f a a has developed a process to identify both the type and volume of outsourced repairs to pinpoint those that are safety critical however we found this process fundamentally ineffective because carriers voluntarily report this information and f a a inspectors do not validate the data f a a agreed to improve the system but the completion date has repeatedly slipped improving its data collection would also help f a a locate nonce or to pick a good facilities performing critical repair these facilities operate without an f a a certificate and therefore do not have the associated regulatory and quality control requirements including training and maintenance supervision despite these vulnerabilities neither f a a nor carriers regularly inspect non certified catered facilities in fact we found in two thousand and five that f a a had inspected only four of the ten facilities we reviewed and was unaware that nonce or to pick a good facilities perform the same type of work as certificated repair stations including engine replacement f a a rel heavily on carriers to oversee repair stations and uses their audit to approve repair stations for air carrier use even if those carriers themselves have flawed audit and quality assurance programs in addition f a a does not specify how inspectors should gather information needed to prove air repair stations and it may be months even years after stations are approved before inspectors conduct on site reviews as a result  maintenance issues that repair stations have gone undetected in one case f a a inspectors found that more than one hundred mechanics at an approved repair station lacked the specialized training required to work on that carrier's aircraft given the safety gaps it is imperative that a take long overdue actions of importance is the need for f a a to obtain information on where critical maintenance is performed without this information f a a will fail in its attempt to implement a risk based oversight approach and of key interest this committee f a a will also have difficulty supporting t s a as that agency prioritizing its scarce resources in order to identify and address security gaps at risk at repair stations following our recommendations in two thousand and three congress mandated that f a a and t s a jointly review for and repair stations to assess risk and develop security programs according to risk levels today that mandate remains  we recognize that this process will be a challenge given that foreign repair stations are not subject to u s security requirements such as background checks but it must be done just this week t s a issued its proposed security rule which is an important step in closing security gaps and repair stations in addition pending house and senate reauthorization for f a a would put foreign repair stations in parity with domestic stations on matters such as drug and alcohol testing and education and licensing of maintenance personnel until f a a has fully addressed our ongoing safety and security concerns we will continue to monitor carefully its progress in working with t s a and improving its oversight of aircraft repair facilities this concludes my statement madam chairwoman i'd be happy to answer congressman olson and members of the subcommittee thank you for inviting me here today to discuss the security of foreign repair stations as you know t s a has responsibility for oversight of repair station security expertise is an aviation safety and we have been and continue to be willing to coordinate with t s a with regard to our respective missions and provide any aviation safety expert oversight of foreign repair stations the responsibility for safety oversight that we determine that the work accomplished at the repair stations is being performed in accordance with the federal aviation regulations and the air carriers approved maintenance program our oversight is based on risk analysis this is our process where we examined detailed safety data to recognize important trends and spot potential safety problems in order to prevent them where we see the greatest safety risk is where we focus our oversight prior to issuing the appropriate housing facilities equipment and trained personnel to perform according to the f a a safety standards currently the f a a has certificated over seven hundred foreign repair stations in order to ensure comparability comparable safety standards despite geography foreign repair stations must submit to recertify every twelve to twenty four months something not required of domestic repair stations we require at least one comprehensive in depth inspection prior to the renewal of the certificate in the years that the oversight of their own national aviation authority on top of that the air carriers constitute a third layer of oversight all timidly air carriers are responsible for overseeing all maintenance done on their aircraft by any maintenance provider air carriers are required to have a quality management system for monitoring and analyzing the performance and effectiveness of their maintenance programs air carriers quality management system unable as a carrier to track any problems with repair stations and check for similar made throughout their fleet we are confident in the effectiveness of our oversight flexibility to accommodate the range of repair station characteristics and for complement as a safety regime is proposing that a search of a kid repair stations carry out a security program that clearly defines access controls for facilities as well as aircraft and components the security program must also establish measures to identify employees and others with access and restrict access unauthorized individuals and it must describe the means used by the repair station to provide security awareness training employee background checks and designation of a security coordinator importantly the proposed the proposed rule t s a would notify repair station and the f a a if there are deficiencies in a security program and provide ninety days for repair stations to correct deficiencies if not corrected within ninety days a would notify the f a a that it must suspend the station certificate until the deficiencies are resolved a process would be provided so that a repair station could request further review of the deficiency determination in addition the rule addresses the process revoking the sort of occasion of a repair station that is determined to pose an immediate risk just curator while developing the proposed rule t s a collected information on repair stations through voluntary site visits and outreach efforts to assess the current state of aircraft repair station security measures around the world upon finalization of the rule t s a will be prepared to quickly follow through with audits of for repair stations within six months as required by the nine eleven act t s a currently has thirteen international inspectors fully trained and deployed overseas to conduct repair station audits and has provided supplemental repair station inspection training to over one hundred twenty domestic transportation security inspectors we had developed a comprehensive database with detailed repair station information that will help serve as an inspection scheduling and tracking tool scheduling of t s a onsite inspections will be coordinated with f a a inspections we have learned through joint visits that this maximizes inspection effort and promotes the efficient use of resources for both the government and repair stations these coordination efforts will apply to repair stations currently certificate id those waiting for certification and those that apply in the future in closing t s a is committed to working with our stakeholders both foreign and domestic in developing a rules flexible viable and takes into consideration the efforts are already put forth at repair stations to secure their environment from the threat of terrorism t s a strongly encourages all interested parties and stakeholders to review the proposed rules and welcomes public comment thank you for the opportunity to discuss our plans for ensuring the security  repair stations and our proposed regulations i would be pleased to respond to your questions let me thank you very much for your testimony and we will proceed with questions i do want to now recognize myself of questions scoble let me begin by framing the understanding or my understanding of this issue so that it is very clear first of all one report was issued in two thousand and three and one report was issued in two thousand and eight congress acted in between but to this new administration this is an issue that has been ongoing and it certainly raises a lot of questions because of the climate in which we live in nine eleven the second premise or given that i would like to suggest is it would be untenable for any of us to think that airlines would not be due to full and attentive to the issue of the repair status of their craft their aircraft it is the basis of their work product it is the source of their income and i would expect that they would be as due to fall as  an industry could be expected i will hear from their representative on the second panel and i would imagine that there is a need for all of us to improve whatever we might do but we have a higher responsibility here in government and that responsibility is to set the framework of security in this post nine eleven era so if you would give me an assessment of the conflict in this as i perceive it between the working relationship between t s a and tell me what the gaping holes are in your report although it has been made into the wreckage articulate what you originally classified s s i because of the sensitive security information contained in it was redacted by t s a itself redacted copies have been provided to the committee we posted it on my website just this week and i've asked that it be inserted the record as part of our reach that security review we inspected twelve domestic repair stations and ten foreign repair stations like t s a we tried to analyze the security picture depending on where a particular repair station was located was it on commercial airport property general aviation airport property or was it off airport property completely if i could summarize for for repair stations that were located aboard commercial airports and this was only eight percent of the stations that we had occasion to examine we found poor perimeter to perimeter access control such as gaps in fencing unmanned entrance points photos of those are contained in the report that's been provided to the committee we found in effect of controls for monitoring individual movement once on airport property for instance repair station vehicles background investigations and also within a low it was well after a year after the september eleventh attacks we found written security procedures that had not yet been updated and this was found on foreign soil repair stations foreign repair stations it was found on both both domestic and foreign repair stations and the report two thousand and eight two thousand march two thousand a report focused primarily on f a a safety oversight of repair stations safety as you pointed out in your opening statement has an integral link to security any safety vulnerability can be exploited and turned into a security threat what we found primarily in our two thousand eight report was that despite its efforts beginning in two thousand and seven to create a report that carrier submit to it to submit detailed data that would allow f a a to fulfill its safety responsibilities those reports were incomplete and  adequate and what i've characterized as leaving f a a fundamentally ineffective in its safety oversight responsibilities since two thousand and three and when their departure moved them to can you just quickly and i just have another question before i conclude to the other witnesses quickly what have you seen as the oversight relationship the t s a is dealing with the security question well again to clarify my responsibility has not been to look at t s a after two thousand and three however i can speak to f a a if you would look at it from that perspective and f b i s coordination and their work product after two thousand and three on this issue yes a has been collaborating with t s a through the years and as you pointed out the current proposed rule is quite late but f a a has been working with t s a to prepare that rule i'd like to like to point out that  important as that proposed rule may be perhaps just as important and it's contained in our two thousand and three report as well as in the vision one hundred legislation is the requirement for t s a and f a a to conduct a comprehensive security review an audit of all repair stations that hasn't been done in the last five or six years it won't be done until after the proposed rule becomes final t s a and f a a will have to work carefully on that and to do it effectively  must have a report that will from carriers that will show what type of maintenance in what volume and where it's being conducted so that both t s a and f a a can target its limited inspector resource very quickly mr doll the image how do you and plan to work together on the audit and for t s a to respond to the audience and for f a a to do the audit how do you expect to do that you have a note of a rule making but what are you doing now  worked with f a a very closely to gain an understanding of the types of repair stations that are involved in this industry so the time has given us a chance i understand the industry to consult with partners listening sessions and written comments and also make inroads with the foreign governments because since we do not have a legislation or regulation to allow us to see these for repair stations we negotiated with our partners and asked as part of our program that we already have in place where we inspect  foreign airports and foreign air carriers so because of the relationships we had with our foreign partners and with as with their relationships we were able to go and pay site visits to several of the locations as well as corporate headquarters and industry conferences where we can gain insights and understanding and work forward what are our program office has been doing is taking the information from the databases to put that into our work plan so that as we are  stations without the appropriate background checks i've heard nothing on the perimeter issues nothing on that so let me just allow you at a number point as i yield to mr olson for his questioning thank you domestic repair stations are identical in regards to they must have the same facilities equipment the same kind of record keeping system  for a certain type of or size of aircraft and must be able to whatever kind of equipment they're working on their personnel must be trained they must have a roster of supervisory inspection personnel  inspection and supervisory people must have the same level of knowledge from a performance standpoint it makes no difference whether you're on foreign soil or domestic as far as the technical issues and the performance regulations as you noted we would be emphasizing the access control identification of employees and ways to develop contingency plans in case they're worried about what would be done in the name of security coordinators that we would have a twenty four seven point of contact because we have not had any regulations to have the authority to go into these stations we have done this on a collaborative bases with the foreign government because if they are f a a certificated stations that also gives us  inroad to be able to talk to them about their their structures for the foreign repair stations there's over seven hundred of them and over three hundred of them are located on an airport which would then be subjected to the airport security program and many of the needs of the perimeter control the access control identification badges would be covered under that airport security program so what we have done in conjunction with f a a is to look at a risk based approach and hear the highest right the highest threat areas those stations that are based on a known threat in the region or the country based on using current intelligence information that tells us that there's bad things happening within an area the type of work that's being done on the at the repair station because what we learned was you may have a three person shop that does one small type of repair if it's just the cushions or to a small component of the aircraft but if you may have a big station where there's thousands of employees that are working on engines that are working on airframe and that's the ones where we feel that there are more more of a threat to the proximity to the airport so it is a it's an evolving process it's a constantly changing based on the intel threat that is assigned to repair stations in singapore and every airline certificate management office the f a a inspectors assigned to that are able to go in there and look at that kind of data to determine their relationship going forward that will be successful thank you very much t s a currently has t s a representatives international industry representatives and transportation security specialists deployed around globe it's about twenty two t s a representatives of about seven international and it's representatives working with the airlines and with industry associations that are internationally based and then they try to curity and specialist those who then inspect airports air carriers and will also be conducting the former para station so many of the relationships with the governments are developed between the government entities and the airport authorities the civil aviation side and then the airline side in some cases it will be a new person that will be dealing with as far as the former para station is concerned because every country is kind of constructed a little different and in some cases it may be part of the airport authority in the civil aviation or another it may require us to build a relationship with another department within that government and will work with state department with the embassy contacts to make those inroads and as we've been doing that already over the as  the will have been being through the system we have prioritized that approach so it is based on that success we have had with our past foreign relationships with our representatives around the globe that we're just building another process in place so we have a ways that we've been able to develop these processes harmonized efforts the way we've worked across with our european partners in particular we have worked kind of standardized things the way we operate so that we don't have to inspect as many times there because we're confident of the measures they put in place because of the information sharing that's done and that allows us to take those resources and place them in areas where it's a higher risk or that we're doing something new like the foreign for comment and we are eager to work with others we learned a lot through the time that this was being developed we didn't just we knew we had work to do we were responding as was mentioned earlier there were so many threats that kept kind of rising up that we had to put our resources to other things but because we have placed those additional layers of security in place and other areas we are now able to focus more fully on the form repair station and we look forward to the comments that we receive and i will learn from industry and stakeholders in making this rule flexible and viable for all  thank you let me raise this point in conclusion if i may and refer to the opening statements that you made and my opening statement of questioning is about or worse identifying the security problems that are of an immediate danger and the rules state that t s a will communicate in writing to f a a which will then to spin or revoke the certification depending on the circumstances i need to know that this interagency process will work quickly and without fail and i don't want to let are sitting on someone's inbox for two weeks before actions taken so this is a question f me how this notification will occur at what levels in the two agencies and if there is an interagency memorandum of understanding that will be required madam chairwoman as of right now there is no  memorandum that exist but i can assure you the f a a is very well practiced in issuing letters suspension letters of revocation we were will work closely with t s a to establish a process so there are no questions we look at those types of actions as an emergency type of situation and we need to go beyond the fact that it goes to somebody is in box and i would say a very streamlined set of processes that when something of this nature occurs we give people a crisis team together and do that very quickly we're very willing to work with t s a on having a very fast track process for that so you don't have a protocol for that right now no manager until i understand that the farm repair stations have doubled is that accurate over the last we were at three hundred or at seven hundred is that right in fact of the current numbers a little over seven hundred and is and what percentage of that as you indicated is on the contained in a large airport three hostilities and where the others are located some are located in industrial parks nearby areas that i've had to get more details on so they're off site or off site do your inspectors or have your inspectors in this coordination before the rulemaking have made trips to those offsite facilities we have made trips to summit site disability and what is the difficulty for getting to them it depends on the country and the situation  n the way the government is constructed in the country i could give you some more specifics of particular regions if you'd like i would like that for the committee please the nexus that you used to inspect is where domestic airlines u s based airlines travel or utilize those facilities and are foreign airlines that fly to the united states is that how you make the assessment any airport that is the last point of departure to the united states we have the authority to put on the farm repair stations that are offsite industrial buildings how do you assess inspecting them in till we get the rule in place we really had no authority that was done on it that basis but to use as a criteria that those planes will be flying into the united states or flying anywhere for the united states right  just raised about coordination sitting on the desk because again i go back to the point that as we speak there are probably security breaches in terms of background checks and a number of others and i would raise that as a concern how would you  process that's in place for the notification when an airport does not meet security requirements and our intention is to use that program to model how we would i don't know if i went or repair a station is not meeting the security standards and that is a process that i am committed to making sure that it moves through the system and doesn't language and that we do everything we can to ensure that our organizations are working together and i have already met my administrators commitment to facilitate that process as well resourcing or structuring and i appreciate that but i would like to know whether or not you expect the t s a will seek to increase its budget which i would make the request for these inspections at this point we have worked within our budget and expect work in our budget to address the threats and look at the risk based model to then put the resources that we have available to us to those highest threat areas where would you recognize the fact that there is a sense of urgency and that you may need to increase the budget and increase the numbers of inspectors so to increase the number of inspections because we're talking about seven hundred potential sites and we are already training more inspectors or domestic base so that we can then tr use them in international inspections it's also part of their career development because this way when someone is a domestic inspector they also get trained to do international work it's a step up for them and an increase in their responsibilities and continuing classes will are ongoing so we'll have several years over six hundred inspectors that are domestically based so we can then use that pool so until we lost that resource until we look at the actual model of how many times you can send somebody out we are going to work within our existing private prisons program this committee would like to have a report as you move forward in the room making on your assessment of the utilization of the six hundred specters and the need to increase the numbers as i frankly believe they may be overloaded inspections are required more than once and that means i'll have to be repeat visits in assessments and certification let me quickly just address these points to you  dolly and thank you the report and two thousand and eight said this and i think i will do it in a way that you will be able to just comment on it pacifically the report from the inspector general s the f d a did not have an adequate system for determining how much and where the most critical maintenance occurs did not have a pacific policy governing when c m o inspectors should visit repair stations performing substantial maintenance  required did not require inspectors to validate that repair stations have corrected deficiencies identified in air carrier audit which i think is one of the more indicting indictment for did not have adequate controls to ensure that inspectors document inspection findings in the national database and review related findings by other inspectors as a result f a a could not effectively target its inspection resources to those repair stations providing the highest volume of repairs which caused deficiencies that repair stations to go undetected or reoccur and prevent inspectors from obtaining sufficient data to reform comprehensive risk assessment and that could be in safety but it is certainly life or death in security and i might say safety as well but i'll jurisdiction here security what have you done or do you intend to do or have you done on these issues thank you madam chairwoman first of all the recommendations from the inspector general's office very seriously we do appreciate their level of insight and we go through these very succinctly and in the case of the two thousand and eight report we agreed with every recommendation has to go out and look at a repair station that we've identified as an essential maintenance provider which was another thing in the report that we could not figure out who was doing what type of work classifying give to our inspectors are issuing two circulars advisory circulars are documents that are information to inspectors as well as operators which means they apply to repair stations path we have had some bumps along the road where our first attempts at some of these did not work we listened to the inspectors we listened to the came back and this is our course of action and we really think it's going to close out every where we know the background of all of the employees that may be utilized in this important task that these airlines have responsibility for the government has responsibility for and i'm sure when i'm certain we don't know that in connection with our two thousand and eight safety oversight report we visited for an overseas four and repair stations and we know that background investigations are not being conducted on all employees at those locations do you go yes absolutely i understand t s a is resource restraints the need to prioritize and in terms of threat clearly though is this committee in every american knows we remain a nation at war our enemy is implacable they have demonstrated the intent and capability to target us civil aviation repair stations as we noted in our two thousand and three report based on  singapore in late two thousand and one repair stations are on their target list we have to we have to assume that meant so quickly if you had one task coming from your reports collectively two thousand three two thousand and eight as an i g recognizing the firewalls that you exist in but the committee is asking what would you say the first charge should be that we know we have a rule making going on but what would be the first charge or one of the point list of charges to get started between f a a and t s a man first item on the to do list remains to f a a to structure a report from the carriers so that critical maintenance and the volume of  locations that need the most attention so get a report from our airline friends to f a a the one that f a a secures that establishes where these stations are so that a prioritization could begin or it could on and then we'd be able to use scarce resources and build a database to possibly ask for more resources for doing this important work is that my understanding is correct mr dobbie do you have a sense of urgency  chairwoman i would defer as far as the security question to the t s a but i would like to comment that we have helped them in the past by providing our databases with them and will continue to do so do you have a sense of urgency on this ma yes ma'am is or is that the sense that is that f a a if you think that is a sense of that they have established that this is important absolutely matter so can you secure the document that the inspector general is asking which i think is common sense in your partnership with t s a is to secure from the airlines a report on the existence of the far repair stations as so that a analysis of resources could be made we will actually have most of that i believe when we have the essential maintenance providers that is mandated through their operations specifications on their maintenance and what timeframe isn't i believe probably early next year we will have this committee's going to ask before you to report back on whether or not you accelerate that timeframe in light of the work that we expect e s a to do you please provide us with that report yes ma'am as far as to use have a sense of urgency yes ma'am i do this is one of our highest priorities to work through process and then implement and they said we had been conducting the outreach services and we have this continued to plan through the the months until the will is final i currently have a team in switzerland looking at some stations there and have a team going to mexico in december to look at them for repair stations there so you understand however that we as we speak have stations not withstanding the good work of our airlines that are without inspection you understand that as men and that there are individuals working without background checks yes ma'am what i'd like for you to do as you do this rule making which has a legal timeframe is i'd like to say to provide this committee with a report back on of the potential increase number of inspectors and or inspections and what approach t s a is going to take to assess that need is there and let me thank all of you for your very thoughtful testimony and instructive testimony and this panel will be excused and i look forward to your submissions in writing thank you so very much we will start with the second panel after the votes this committee is now in call the hearing back to order and thank the witnesses for their patience i welcome out second panel witnesses on the first witness is mr robert roach general vice president of transportation at the international association of machinists an aero sp aerospace workers i am represent six thousand machines but several of us carry a second witness is mr robert glass assistant director at the transport workers union of america t w represents six thousand five hundred american airlines mechanics that airline is the only u s carrier that does not outsource aircraft maintenance to foreign repair stations out third witnesses mr chris morris chairman of the teamsters aircraft mechanics coalition the team says represent eighteen thousand five hundred a s operations and safety division now fifth witness is mr christian kline he is the executive vice president the aeronautical repair station association he oversees its communications and industry outreach activities without objection the witnesses full statements will be inserted in the record and i will now add each witness to summarize his statement for five minutes let me also thank each of you for the time you have taken to come your employer is a particularly important interest t j part of how we review the security risks and safety concerns of foreign repair stations so again we thank you and we'll begin with mr roach who is now recognized for five minutes machine issues the largest aviation unit north america representing a hundred thousand and eighty thousand in aerospace workers at almost every classification including mechanics flight attendants ramp service workers passive service employees reduction workers and i would like to say on behalf of the twenty five thousand members that we have in texas thank you for calling us here in especially continental flight attendants which are based in houston texas each year u s sailors increased use of overseas aircraft from repair facilities i don't know of anyone who has ever said that qaeda member was employed in the singapore we pay a station that perform maintenance for us aircraft at the time he was arrested in two thousand and one pre employment ongoing random drug and alcohol testing of another employment requirement for us aircraft technicians it makes no sense the to read english creating a major safety problem i am members regularly report running from heavy maintenance performed overseas with dangerous malfunctions reports including miswired engine indicators critical sensors covered up in can indicate that these planes are in service when many of these things detect a biomechanics after them back in service there is a danger the danger of bogus parts making their way onto u s aircraft without proper oversight there is no uniform facility security requirements there is a potential sabotage of smuggling of weapons on board aircraft without proper security practices f a a inspectors do not inspect far we p s stations on a regular basis when they do they must announce their inspections in advance and the us in the u surprise inspections are allowed non certified f a a station to utilize by many airlines but the f a a has no oversight and does not monitor these stations at all u s airlines have increased outsource maintenance from twenty nine percent in two thousand to forty five percent today much of it going overseas but else but f a a oversight has not kept pace and that's not kept pace jeopardizing our aviation system and it was indication about loss of employment one facility in india in indianapolis was modern facility in the world and has now operating at twenty five percent because united airlines chose to take their work out of that location and from that work out to subcontract work much was going overseas since nine  and we look forward to answer any questions you may have thank you very much mr rudd for your testimony mr glass you now recognize for five  minutes the transport workers union of america members of the a f l cio on behalf of two hundred thousand active and retired members in the transportation industry including aircraft mechanic said america now and then american eagle roughly about fifteen thousand appreciate the opportunity to appear before the committee today like to speak on the issue of after of maintenance and the need to strengthen security to help ensure safety at overseas aircraft repair stations there are three major concerns that we have with regard to repair work performed at foreign aircraft repair stations for us we have long held that our belief is that the same standard should be applied to repair work being performed on u s bound aircraft or gals the work being done in the us or abroad second the loss of thousands of american jobs to outsource foreign repair mechanics mechanics for the weakens our u s economic security and finally we have a concern regarding security breaches within and around the primaries of which can lead to sabotage us we have four recommendations regarding aircraft maintenance that we see as necessary to ensure a safe and secure air travel for the american public one require that all maintenance on aircraft used in domestic u s service be done in f a a certified repair facilities to require as a condition of the f a a certification that all repair stations meet the same standards that would include not limited to the drug and alcohol testing and the port sixty five mechanics certification three reconfigure the f a a inspection oversight to place the greatest scrutiny on those repairs stations whose orders determine oppose the greatest risk to safety and security and for requires condition f a a certification that all repair stations be subject to unannounced f a a inspections the f a a shall be prohibited from certifying and repairing and any repair station in any countries up or have it unannounced inspections and shall immediate revoke any existence certifications and such countries ironically and housework performed by the carriers has received the greatest scrutiny and f a a oversight but opposed the least risk because of the following factors the carriers have shouldered the responsibility to monitor themselves and i'm mindful of the in house regulations that are required to meet in addition the f a a regulations hold the domestic station aircraft mechanics to a high standard including having all aircraft mechanics being subject to the drug and alcohol testing to pass a criminal background checks and under the unannounced inspections by f a a inspectors at any time and in any place addition to mechanics who work on aircraft usually start a fight on the plot sixty five and those that sign off the work on the aircraft certification is required if all the aircraft flown  domestic u s service was serviced by the aircraft mechanics then a concern of the lack of oversight would be no american airlines a prominent carrier mechanic that the represents does not outsource that work instead americans when a trendsetter and brought  additional income by insourcing work are mechanics employed by american allies a hot held to a standard unlike workers at overseas repair stations that have no background checks are not subject to alcohol and drug testing or to the unannounced inspections by the f two thousand three homeland security mandate that resulted from the attacks on september eleventh set in place that security rules for foreign domestic stations to ensure they'll be equally applied much to our dismay six years later security will still have not been implemented we feel that this is simply unacceptable giving a security risk at hand the suggestion is not the foreign countries must adapt to change must adapt and change the laws to institute widespread drug and called testing and criminal background checks however to achieve the highest level of safety and security we asked the federal government and congress to require those that work on u s aircraft to meet the same standards that the f a a imposes on the u s domestic stations from a repair from a security standpoint it is not hard to imagine how certified foreign aircraft are pa this kind of clear and direct risk of our national security must be enough to prompt action we call on t s a to start with stakeholders regarding implementation of a robust and effective security program that will begin to build a firewall to protect the american flying public against any future aviation related such security program would need to include protocols dealing with background checks of workers drug and alcohol testing and overall perimeter safety and security measures for all repair stations working on u s bound aircraft the alternative of double standards strict scrutiny world where already layers of protection are applied first a lack of oversight where layers of protection are absent is merely a roadmap for disaster and direct impact the integrity of the american worker thank you for this opportunity to testify before you today i'm a bell to answer any questions you may pose regarding my testimony thank you thank you for your testimony mr moore you're recognized for five minutes and welcome at the on but in those times are bad chairman thank you for the opportunity to testify today on this vital issue of security and foreign repair stations my name is chris moore and i'm the chairman of the teamsters aviation mechanics coalition we represent eighteen thousand five hundred mechanics across  major concerns regarding the foreign outsourcing of aircraft maintenance the work is being done in facilities located in developing nations where security safety and quality standards are lax and adequately in june southwest airlines cited  those layers are being removed one by one is a real control over who is actually working on our aircraft and developing economy when aircraft are literally thousands of places where explosives and other contraband can be hidden are we willing to take that chance the average will cost us jobs safety is a constant overriding consideration our members activities understand there was it's abilities in the act accordingly the u s industry's stellar safety record record demonstrates that unflagging commitment in so let's talk about facts maintenance contracting has increased over the last decade but as the chart on page six of my written testimony clearly shows the u s airline industry's maintenance safety record is the best it's ever been in fact no eighty a member airlines has experienced a maintenance related fatal accident in nearly a decade and that's while operating over one hundred million flights if there were a systemic problem with contract maintenance the data would have exposed to contract maintenance is common and commonly accepted in the industry virtually every airline to some degree relies on contract maintenance whether it's in the form of line maintenance heavy maintenance component or engine maintenance aircraft operators with demanding and highly sophisticated maintenance needs including various branches of the us military contract for maintenance services it is not an exotic practice regardless of where it's done that multilayered and continuous oversight of contract maintenance does more than ensure a safe aircraft it enhances what's already a robust security system a complex system of checks and balances originally designed with safety in mind are interwoven with comprehensive security and asset protection systems to mitigate risk regardless of their nature keep in mind that we're talking about assets worth hundreds of millions of a it will establish security regulations for repair stations and we look forward to working closely with t s a to further enhance today's robust security system continued access to high quality cost effective maintenance is one ingredient in airline's efforts to remain competitive both here and abroad maintaining a competitive cost structure is critical to the health and sustainability of u s airlines for this reason we oppose efforts to limit the ability of u s airlines to obtain necessary and necessary services consistent with the highest degree of safety and security as economically as possible and maintenance is good business for the us the search for quality efficiency in value has meant that some airlines have shifted where their maintenance is done some has have consolidated in house facilities other times it's contracting with a third party sometimes overseas to perform some of that airline's maintenance neither type of change is pleasant both can adversely affect employees their families and their communities it has however meant that met new job opportunities in new benefits for some communities far from resulting in the export of the majority of us maintenance jobs overseas it's meant that we've been able to retain them in the united states u s is a major exporter of maintenance services and enjoys a two point four billion dollars positive balance of trade in this area the over four thousand f a a certificate repair stations employ about two hundred thousand people and keep in mind that eighty five percent of those repair stations qualify a small business is efforts to limit u s airline access to foreign repair stations will certainly trigger retaliatory actions by other countries in closing let me reiterate that maintenance contracting is done safely and securely around the world it is important to the health and viability of u s airlines and finally it creates  thank you very much as client you'll recognize for five minutes thank you very much chairwoman jack it's a pleasure to be with you today i appreciate the opportunity to this important discussion on behalf of arse's members around the country and around the world the three major points i'd like to make this first i want to start by answering the basic question posed by this hearing is the flying public safe and the answer is yes the use of contract maintenance facilities whether they are in the united states or overseas do not add any additional security or safety  for airline passengers in fact the increased use of the increased use of contract maintenance has coincided both with the period of greatest risk of terrorism the nation's history and also with the safest period in the history of u s civil aviation and we believe this correlation suggests at a minimum that the increased use of increased use of stations has not negatively affected there's a simple reason and to be quite frank it has nothing to do with government for repair stations good safety and good security practices are good business airlines simply will not the lives of passengers nor will they risk losing aircraft which are multi million dollar business assets by using maintenance providers that don't evidence a strong commitment to safety and security so even in the absence of a long awaited t s a repair station rules maintenance companies already have security policies and procedures in place for example as part of our model repair station manual recommends a number of best security practices and a highly reliable or a member survey conducted just last week found that the majority of our members only have the perimeter fencing a large percentage of our member companies also use video surveillance and require employees to wear badges and other words a lot of the things that are contemplated by the t s a will be came out already being done by industry on its own of course all those practices are in addition to the existing t s a regulations regarding access to aircraft at airports in addition to the standards and in addition to laws requiring pre employment verification all the foregoing a  pretty safe and secure system even in the absence of the t s a repair station rules the second point out that i've asked the members of this committee to keep in mind is that although the public focus of the new t s a rules has been on foreign repair stations thousands of small businesses throughout the united states are also going to have to comply with the t s a rules and they could therefore have enormous consequences for the u s economy when most people think of aviation maintenance they probably think of a big airplane and a massive hangar with scores of mechanics forming around it and while heavy airframe work is certainly a big part of the maintenance equation most aviation maintenance work is done off the aircraft away from airports smaller specialized engine components in fact of the four thousand one hundred twenty two repair stations nationwide eighty five percent are small or medium size entities and that just as an aside if you're curious about the industry footprint in your state we have attached a breakdown of the number of repair stations and total employment in the state as appendix a of our written testimony there are four hundred nineteen a certificate of repair stations in texas that collectively employ more than twenty five thousand people although our industry in the united states is dominated by small companies we have a massive economic the annual maintenance repair and overhaul market in north america is estimated at nineteen point four billion dollars and when in and related economic effects are considered the m r o industry impact on the u s economy is thirty nine billion dollars per year all companies the united states also has a strong and favorable and favorable annual balance of trade in the market for aviation maintenance services to the tune of two point four committee to be careful what you wish for when it comes the new security rules because you've got constituents are going to have to divert time and resources away from serving customers to comply with yet another regulation you had asked in your opening statement for our recommendations about what should be in the t s a rule details we're really looking forward to t s a and crafting a good rule that's going to work for the industry because if t s a doesn't get it right it's a good bet you're going to hear about it when you're back home monitor i see the my time is about to expire and what if i could have just one more minute to make a final point  my third point is that in mandating the new security rules congress a set of very dangerous precedent of punishing industry for the failings of government because t s a hasn't completed the rule making on time congress has barred the f a a from issuing new form or para station certificates while congress likely intended foreign companies to bear the brunt of the sanction the reality is that it's putting u s companies at a competitive disadvantage because they can open new facilities to service international customers in emerging markets that means american companies risk losing market share to foreign competitors as one responded to our recent survey commented quote we have been unable to support a market that was very heavily into our business plan and a situation could likely cause the closure of the facility of the ban is lifted impacting employment both in our united states station and in europe and are so therefore urges that since the t s a has demonstrated significant progress in crafting new security rules and because of the security practices already in place in the industry congress should lift the ban on newborn repair station certificates and remove this impediment that the status of f a a certification was a pie by partisan decision made in two thousand and seven two in the bush administration so i hope that we can establish that this is a bipartisan desire to ensure the security of this nation and with that let me begin my questioning with mr roach and mr glass and mr moore i would like your perspective on the overall differences between security protocols and foreign repair stations compared to security systems we have here in the united states some of what you've heard from your fellow colleagues are some of you may have firsthand knowledge mr roach was the difference in the security protocols you think there are here versus in foreign repair stations and you not in the united states people who work with very strict background checks there are tre there's a distinct difference between what happens here in the united states what happens every place else without the inspections that we are subject to surprise inspections one really does not know what happens  when you have an inspection that you have to tell somebody sixty days ahead of time that you're coming a lot of things can happen for a short period of time and when one still wants to inspectors leave when they can get the money go back to business as but on our our largest maintenance base being the one in tulsa oklahoma we could turn around and have a fleet of f a a inspectors show up come in and dig through everything from a simple piece of paperwork to the actual work being done on any given day my individuals working on the fields and on the airports in the hangars are confronted by customs t s a homeland security any of the different individuals checking security they must wear their badges their background checks go in some locations to the sixteenth part those checks are not being accomplished in other places they may be a few out there that are now looking into it some of the airlines that are contracting out of starting to stated and they are they are watched daily daily the individuals overseas in these other locations as was said they have to notify them prior to inspection and we know how that goes when someone tells you they're coming to look at something you prepare for we are treated differently here in this country than they treated overseas and you know just the security and the background and the covering of the employees is not what work is that you represent are those that are working for one particular airline the large bulk of my employees we have them in multiples but the large bulk of them are american airlines we are the last major insourcing airline left so even on domestic soil american airlines at this point is h may have a random checkpoints set up at the top of the elevator what you're bringing into the terminal even if you're on duty those are the kinds of security protocols and measures that we have in place thank you  you can sense the line of my questioning is with a full recognition of the assets that this industry represents and repair stations domestic repair stations far repair stations and the attentiveness in which airlines address these crucial issues however the issue of security and securing the homeland is not a predictable job and incidences of terrorism unfortunately are not predictable and it causes one to have to be prepared all the time so the question goes to you in terms of the distinction in the security protocols that you may have or your companies your members may have in the united states versus in the foreign repair comment on the fact that there has to be notice given for  you will inspections versus the spot checks that are going on here in the united states thank you madam chairwoman let me first say that we support surprise inspections we think they're very effective and we believe that there's a way to conduct those inspections in a way that doesn't compromise challenges in conducting some of those surprise audit we think those challenges can certainly be overcome and we think as part of the rule making process we'll see that we'll see that happen  regarding the security aspects in the differences domestically versus foreign facilities we've got to keep in mind that we're talking about facilities when we're talking about  t a member airlines using facilities abroad we're talking about large airports that have security requirements that conform to our the international standards so there there is a there are in fact background checks and other requirements in place for facilities that in fact are located at an airport you talking about foreign repair stations that are located in airport and what individual countries to implement those protocols and it's optional no it's it's not optional and if i may let me defer to christian he's well versed in this area between the two of us  curity standards at international airports they would have to file an exemption with i k o so we would be on notice who doesn't have the higher security regulations and also i can just go back to one point this question of the surprise inspections to try to alleviate some of your concern there you're if you have notice of inspection you can certainly sweep the floors you can maybe put a fresh fresh coat of paint up on the walls but the reality is if the f a a is going in and looking at systematic deficiencies and organization systematic security deficiencies systematic safety deficiencies that's not something you can cover up in thirty days that's something that's going to be evident in the quality in the way the work being done and also again just a reminder here it's not just the f a a that's overseeing these foreign facilities there are literally scores of audit is happening every year at four and part one forty five certificate holders and it's not just the f a a it's the other civil aviation authorities that supervise the certificate repairs other repair stations and certificates of the cities might have or beyond what the t s a is talking about doing the just leave out agencies and shouldn't the united states have a security scheme that addresses the questions of foreign repair stations to protect americans who are traveling on these airplanes i certainly think that there is  have finally gave a yes which is that we do need to have a structure of security that is consistent which is what i think we are attempting to secure during this hearing outsourcing farm repair stations has increased over the decade and to the witnesses they think this train is going to increase or level all and what is the trend for our domestic repair stations can they maintain their presence in volume a work in the face of airlines mechanics numbers once twice as much twice as high as they are today u s airways a lot of work is being subcontracted out and level of employment this country has gone down to people the people used to itself that somebody is working and they can't read or write english and therefore someone else has to interpret what they're supposed to do and in terms of in terms of security nobody cares and that's the bottom line they keep saying well as for this reason and that reason there is no uniform policy on background checks to a no uniform policy on drunk and drug and alcohol testing there are no uniform policies anything that's going to happen let me just say one of the point is that aircraft today are built is regarding the as a nation of domestic repair places and for repair do you think they are going to increase as a going to be continued outsourcing how do you see the future somebody else to give us our aircraft back we have a fission sees in place and they have actually jointly together figured out ways to do it faster and better than outsource is right now unfortunate there is a trend of all of the airlines a we race to the bottom as we call it to outsource it's a cheaper way for people to not worry and it's coming down to people they're removing their people problem they're going to a paper album they're just going to take their aircraft ship it overseas and pay someone else and not worry about it we'd like to see more and house with the constricting of the airline industry right now i believe there is more facilities than aircraft to be repaired so there is a race to the bottom again for cheaper maintenance and that's even within this country there are companies out there who are looking to do it cheaper and cheaper to get the work in and as long as somebody offers a product or cheaper and gives a product that will make their flight from a to b doesn't matter if there is as mr roach says you know some small flaws as it comes out a check is redundant in the systems to make sure the aircraft can continue on so as long as the outsourcing continues and that the cheaper fa is more important than the quality the outsourcing will continue do your employees go overseas to work on planes on behalf of your company or the company that you work for their locations where we would ferry aircraft whether the aircraft down with us not people we have unionized workers in europe who work for american airlines who work on the aircraft we have workers in south america and they are american they are o increasing domestically but in particular the hearing is on foreign repair is that what is the bulk of the structure for airlines is the outsourcing on f chairman chairwoman what i would say is the domestic trend has been increasing it has been centered around aircraft heavy maintenance checks and it has stabilized in the depending on how you measure it in the in the forty to fifty percent range we think it will continue to creep up slowly but will remain in the forty to sixty percent range for the forseeable future regarding jobs outsourced yes based on total dollars that were around forty forty five percent today regarding jobs going overseas i would point out that other countries have recognized the value of the m r o business to their economy we believe that there's an opportunity here in the u s to reinvigorate m r o industry we have no there are opportunities to in fact grow that positive balance of trade beyond where it is today and then finally i would just feel obligated to counter something that mr roach said and it was about small defects being tolerated on airplanes and it will eventually bite us what i would point to is another chart in my testimony and again i want to take us back to data if we look at mechanical reliability for airplane levels is the highest level we've ever seen so something is happening that's right in the world and it's indicated not just by the absence of accident but by the reliability data contract maintenance as a contract maintenance is helping airlines become more competitive air a lot of that contract made his companies quite frankly get better returns on their investment in training equipment facilities etc the airlines because the repair stations are specialized companies that do contract maintenance makes a huge contribution to the u s economy as i said earlier we have a two point four billion dollars balance positive balance of trade in the market for contract maintenance services for air france the u s repair station in the u s economy and growing jobs of small businesses all around the country so again i think i think that the trend is here to stay because we're helping improve their patients let me ask these final questions and thank the witnesses and try to frame again that this is homeland security and the key is securing the nation and i've listened to mr baron moments decline on the economic aspect and the goodwill of the airlines and i agree but i started out by saying that terrorism is unpredictable being able to secure a nation requires this nation to be at the top of its gain and in the  report that i'm looking at and you listen to the testimony before pacifically knows every a needs to improve its system but determining how much and where outsourced maintenance is performed that is probably a domestic issue but certainly it is an international issue that gives me reason for concern that we have a federal agency that cannot get their hands around what's being outsourced when we talk about the economy i think the economy also deals with how many americans we can hire and i didn't hear anything from my two friends indicating that we transport american workers over to these foreign repair stations individuals who've been vetted list security clearances because that's the question the announcement that the senator made about an al qaeda person being on site at a singapore repair station is the kind of unpredictable actions that could be occurring around the world so i would indicate and ask for your comment on the f a a needs to ensure carriers or repair stations and have a strong oversight system to point make it clear f a a needs to ensure kerry is in repair stations have strong oversight systems and f a a needs to improve the system for determining how much and where outsource maintenance is and in your answer and that is of course in the backdrop of t s a in the midst of its rulemaking i'm prepared to discuss what t s a is to whether or not they need to narrow the focus  subject themselves to burden this rule making but the key here is to intertwine the utilization of already checked american workers with clearances and who we know have a an understanding of the concept of what we are doing to be working in this field for security purposes versus what i sense is  a unchecked system foreign repair stations so mr roach would you answer that long question please are flying very expensive aircraft boeing triple seven to red china so there is no restriction on where planes go and they could be being maintain any place in the any place in the world the lives of people that we don't need we don't have to being trained in places where they're smuggling cocaine and heroin back into this country so we think they need to know who's working on the plane to where they're working on this plane and we need to background checks that we are  would be flown back into united states and carry thousands of thousands of people when you become to go with the rulemaking was limited or directed at farm repair stations in particular it's a broad bill making now for all stations again i haven't been able to read it means we focus on foreign repair stations but i think it's premature to jump there and i think we need to let the experts do the analysis it's great to have t s a on board now and we look forward to working with them to develop a rule that  effective and does address your concerns so you take some issue with the fact that it would be too much of a burden to put a general out that impacted domestic and foreign repair stations  yes i think it skips a step in that step is the risk analysis and i think that's been so critical for us on the safety side and it's helped us channel our resources to where they could really be effective in they have been i think we need to take the same approach with the security side in not skip that all important risk analysis we may end up at the same place but i think we need to follow the path it's come to my intentions and not all countries have signed the international agreement so let me pose this question do you recognize the importance of having security background checks for individuals in farm repair shops that work on airlines that are headed toward the united states absolutely mr klein your comment on  e idea of narrowing the focus of the rule making and the importance of the f a a having greater oversight and responsibility for the security of these fine not the security but push out regulatory compliance information or member so we take this very very seriously and in fact we have been on the record for years is coming to congress to beg for war oversight resources for the f a a because when the f a a doesn't have the money to do its job and oversight  that directly impacts our members bottom line is a reference a survey that we conducted last week thirty percent of our members reported losing business opportunities because the f a a didn't have the resources to approve applications and changes to operations specifications of things like that so again it's a resource absolutely critical and we would certainly support that on the question of the extending or limiting the scope of the t s a rule making to small companies i think you didn't hear me limiting to that congress has already mandated this that they be applicable to both u s and foreign companies and that's my that's my to say a lot of i'm sorry you're now speaking to congress so i'm asking your input on whether or not you believe it should be narrowed  burdens are our small member companies around the country and i think if the rule is drafted in such a way that it reflects the realities of the industry the fact that many of these are small companies where you have two or three employees maybe you don't need to have badge you get a company with two or three employees that we can craft a rule that's going to work for everybody and do you believe that it is important imperative to have background checks for all individuals in foreign repair stations that are working on airlines destined airplanes destined for the united states i think that it's appropriate have rules that are proven to be the background investigations that we have here and again i mean it's not every airline employee in the united states gets background investigation as i understand the see the  if you have on a corded if you require onyx or access to the aircraft of the rapper you have a criminal background investigation so again equivalency absolutely well that's why we're in the midst of a rule making  obviously if you are in the midst of working on a aircraft that could be carrying passengers whether you are in the area that is on the ramp or near the ramp you could be in a repair shop and have the ability to undermine the viability of an aircraft so my question is do you think it's important when airplanes are repaired on foreign soil to have those who have access to that airplane have a background check if they're doing safety sensitive work and have what is accorded access the aircraft or the  well let me thank you for all of your testimony and your patience in the questioning i think this is been instructive and constructive as it relates to the f a a and t s a moving forward on  i think an important loophole that is glaring and i hope as we have had this discussion with the fine members from america's workforce and also the business community that we find an opportunity to come together i think it's important again that we look a second time around about the utilization of american workers to continue to ensure the security of this nation so let me thank you again for your testimony and this the value of your testimony is most important and i will believe that this hearing will help to inform the final rule for the security of foreign repair stations the members of the subcommittee may have additional questions for the witnesses and we ask that you respond to them expeditiously in writing and hearing no further business the subcommittee stands adjourned thank you