From The FAA

If something doesn’t feel right, please ask questions to comply with the regulations, before an FAA inspector comes to visit

During my career in both industry and government I’ve been exposed to some original hyphenated adjectives. There’s the South’s rib-suckin’ BBQ sauce, of course some chicken is finger-lickin’ good, and an ear of corn in the Midwest is lip-smackin’ dee-licious; all expressions of good things to come. But it’s the hyphenated adjective: forehead-slappin’, that always makes me cringe (my generation knows it as the ‘V-8 slap’). Either way, it’s not a sign of good things to come.

In my job I meet people in all levels of aircraft maintenance including management or quality assurance; they’re often caught off guard when faced with a question regarding ‘must-do’ items as they apply to their operator or repair station. Consequently they’re answering a question of company policy or compliance with regulations that could generate consequences like: fleet groundings, certificate revocation, and/or doors being closed. It’s these three consequences in particular that should draw special interest from the work force because if the doors are closed, the work goes away.

I travel on inspection teams that go to various certificates, whether they’re 14 CFR Part 135, Part 121, and/or Part 145; the intent of a visit is to look into some aspect of their operation. In this world of ever-changing corporate structures it can be understandable when the ‘new guy’ has to correct the procedural mistakes of the former ‘guy-in-charge;’ consequently that doesn’t always happen. Most excuses sound feasible but they rarely stand alone and the worst alibi anyone can use is ignorance.

Procedures manuals and training

On a recent inspection we arrived at a Part 135 operator for a weeklong look into both the operations and airworthiness sides of the business. The director of maintenance (DOM), an extremely experienced and intelligent technician who had been in the position for several years, sat with us as we reviewed their procedures manual and the employee training records. As we dug through the training records we found that the operator’s maintenance personnel (including tool crib attendants) hadn’t received hazardous training since … well, it couldn’t be determined.

This particular operator is a worldwide air carrier moving people of the highest social standing and celebrities; before we arrived it had bookings going into the next year; that is … before we arrived. The operator is/was authorized to carry hazardous materials onboard — or ‘will-carry’ — per its Operations Specification (OPSS) A055. So we asked the question: why isn’t there hazardous training for your maintenance folks? The DOM replied that mechanics don’t load the aircraft, i.e. baggage; so as far as he knew, they’re exempt from hazardous awareness training. No, said I, they handle fuel, hydraulics, and oil on a daily basis; they’re all hazardous materials. His smile quickly faded; his hand poised in front of his forehead.

NOTE: You management types dashing to double-check employee training records, please let me finish the story first.

Now, the DOM talked to his upper echelons and they decided to amend their OPSS A055 to a ‘will-not-carry’ status. This was their strategy: divert attention and buy time to get training in order; a reasonable concept. But my teammate asks the DOM: How will you identify hazardous materials to reject if you aren’t trained on what to look for?

Consequently their operations hazardous training program — the only one they had — wasn’t revised, so technically everyone was expired. This would now require them to shop for training and have it delivered to the troops — both airworthiness and operations. We pointed out that the strategic decision to change direction mid-stride meant they still needed that training and P.S. they can’t fly until they get it. Now this time he manages to slap his forehead.

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