I don’t mention this to tweak the nose of this particular DOM. However breaks in procedure happen more often in larger certificate holders than in your mom and pop airlines or avionics shops. But most important, it’s vital to ask … the … question! You see, in aviation it’s a lot harder to ask for forgiveness instead of permission.
Now for an extra special head-slap, consider these two points: 1. Your FAA Flight Standards Principal Inspector doesn’t approve your hazardous training; FAA Security does and they are a totally different division. It’s critical to not only know what training is required but where to get approval for it. 2. The requirements for this are found not in the aviation regulations we’ve come to know and love, but in other Department of Transportation regulations, particularly 49 CFR Part 172, Subpart H.
Ouch, we have to follow those too? Kee-rect because if you look on the front of your certificate under the big United States of America it spells out who holds jurisdiction on our A&P.
Several years ago I investigated a Part 121 incident and we were interviewing the Required Items Inspector (RII) for a 145 repair station conducting maintenance for the Part 121 operator. I asked him what a mechanic was doing on a particular aircraft:
RII: He’s never rigged an elevator before so I’m training him. Then I’ll sign off the task as the inspector.
Me: (Stunned) You … you do realize I’m standing here, right? (I opened my trusty FAR book and slid it over to him.) According to Part 121.371(c), you can’t do that; you’re signing off your own work.
Me: Where does it say in your company procedures manual how you perform maintenance and inspect?
RII: (His confidence returns; he smiles) We do maintenance the same way we’ve always done it for the last 10 years now.
Me: But your company’s changed hands two times. And you’re working on another certificate holder’s aircraft. Whose procedures manual are you following?
RII: (Forehead slap)
Look folks, these aren’t first year A&P school students but veterans with 10 to 20 years experience; they’re ultimately responsible for many human lives and millions of dollars of company assets. Consequently they get comfortable in the glow of their own experience and refuse to ask the question. Section 121.375 and 135.433 speak specifically to training to work an operator’s aircraft and what must be followed.
Now any certificated wrench turner or tweak believing that being unaware of a company’s procedures is a lead shield to hide behind, my reply would be an unequivocal NO. Have you ever had the pleasure of attending a NTSB hearing where an experienced questioner surgically eviscerates a veteran mechanic who ‘just didn’t know’? I have and it’s just not pretty. The fact is that everybody punching a clock is responsible to know; if you don’t know, find out.
Now let’s look at another pet peeve that’s dear to my heart: de-icing. With the dawn of regional airlines that contract to bigger main line carriers, I’ve seen interesting times. Let’s use the imaginary Conglomerate Air Express (CA Express), feeder to your employer/airline, Conglomerate Air.
You’re in the bucket hovering over the T-tail of a CA Express Bombardier DHC-8; Type I fluid hose poised to spray. Wait, have you been trained per CA Express’s deicing program? No problem, you think, it’s just another aircraft; some Type I here, some Type III there.
But no, the old ‘an-airplane-is-an-airplane’ rule doesn’t apply here. The truth is that even though the company logo on the tail is the same as mainline Conglomerate’s, you need to train to the ex-clu-sive CA Express operator’s approved de-icing program. After all, CA Express might not want you shooting hot Type I fluid on the leading edge deicer boots.
Hold off on the forehead-slap; that was a stealth example. Some airlines and their regional carriers actually have joint deicing programs to streamline the training, so you have to know what to ask. If you go to sections 121.629 (c) (2) and/or 135.227 (b) (3) it spells out that an operator utilizing deicing must have a program and the training to support it. A look at that airline’s OPSS A023 lists the approved deicing program(s) for that airline. Now you’re golden, except …
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