The Inspector General of the Department of Transportation has recently published, without fanfare, its report stating that the ATOS safety program started in 1998 has failed in its effort to implement a comprehensive safety and inspection process within the major Part 121 air carriers in our country. The report states, among other things, that FAA inspectors failed to complete more than 200 key inspections on time.
Now, one must recall that this ATOS system was introduced in 1998 as the safety system to end all safety systems. ATOS was designed to be a systematic approach to aircraft maintenance and safety. It was comprised of 96 elements, categorized as high, medium, or low in criticality. The high elements were supposed to be assessed twice a year, medium elements once a year, and low element items every three years … simple enough, but it was necessary to access the data through something called ACAT, the Air Carrier Assessment Tool, which was a system set up for the inspectors to periodically reassess all of the elements to see how safety risks were being handled and where the high risk areas were. Unfortunately, the system has never worked the way it was designed.
Final DOT audit report
On Dec. 18, 2010, DOT released its final audit report on ATOS effectiveness and in essence concluded it is a failure. It said:
1. The FAA did not perform timely ATOS inspections of policies and procedures for the air carriers’ most critical maintenance systems;
2. FAA inspectors did not effectively assess whether critical maintenance systems were performing as intended;
3. The FAA finally completed including all Part 121 air carriers in ATOS in 2007, almost 10 years after initiation, but effective implementation of ATOS was hindered due to inspectors’ frustrations with adapting ATOS principles to smaller air carrier operations, citing problems with redundant inspection checklist questions, air carrier staffing limitations, and insufficient data to support the ATOS “data driven” approach.
Although the IG is highly critical of the FAA’s approach and the work of the inspectors in the report, it goes on to say that the FAA is hindered in its ability to effectively target inspector resources to the areas of greatest need. But, DOT will make recommendations to the FAA to improve its data, training, and risk assessment processes for ATOS, in an attempt to salvage something out of it.
Further observations by the IG
The most important items of concern include adherence to airworthiness directives (ADs), which are mandated by federal law, and major repairs and alterations. Inspectors have admitted that inspections regarding ADs for example, considered to be of high criticality, had not in fact taken place over a passage of some five to seven years! Most of us in this business consider ADs of significant importance to require almost immediate attention to determine risk and then perhaps request delays in completion.
FAA inspectors in some cases stated that they missed inspection intervals (for airworthiness directives) due to confusion over the FAA’s guidance on when ATOS design assessments should be completed. Even after the confusion was supposed to have been cleared up, inspections were still not completed on time. The FAA even reduced the number of maintenance program inspections and this still did not allow inspectors the time to comply with the inspection intervals. Most observers consider ADs immediate attention items. (Unlike other mandates these are required by federal law and failure to complete them could be considered a crime. If FAA inspectors were proved complicit in avoiding completion of ADs on time, they could be considered co-conspirators in such cases.)
If such failures had occurred in private industry, heads would roll big time. Indeed, you may recall the Southwest and American Airlines recent past failures to complete certain required maintenance items, revealed by whistleblowers. Some FAA inspectors’ heads did roll within those companies. However, there was no evidence of government employee heads rolling. In some cases the most we saw was employee transfers to other locations, in order to hush up well-deserved criticism.
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