From The FAA

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.

Ask the question

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.

(Uncomfortable silence.)

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.

Deicing procedures

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 …

You’re also contracted to de-ice the B-777 for Multinational Air. (Are you loving these names?) You ask: is an-airplane-just-an-airplane now? Sorry no, even if Conglomerate flies an identical B-777. Multinational Air has to either have Conglomerate’s deicing program approved for its fleet or you personally have to be trained to its program. And if you think that’s ridiculous, consider the fact that two separate airlines may fly the same model aircraft, but they’ll have significant differences, e.g. metal stabilizers versus composite stabilizers or ‘wet’ tails as opposed to ‘dry’.

People, these articles are just a taste, albeit they’re examples of serious flaws that I see regularly. Consequently ladies and gentlemen, you have to know the things your upper echelons might omit by accident … or, dare I say it’s possible, on purpose. So if something doesn’t feel right, please ask the questions. If you don’t, I’ll know; you’ll be the one walking around with a red, hand-shaped welt on your forehead. AMT

Stephen Carbone is an aviation industry veteran of 28 years. He works at the Boston regional office in the Flight Standards Airworthiness Technical Branch. He holds a master’s degree in aviation safety systems.

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