Certificate of Responsibility
By John Goglia
February 1999
Do you remember how proud you were when you finally passed all the requirements for your airframe and powerplant certificate? I can still remember the feeling of accomplishment I had when I was told at the end of my practical test that I had passed. I was finally ready to use my newfound knowledge to follow a dream in aviation and to earn a living. In those days, the financial rewards were not impressive, but the love of aviation surpassed the reality of the pay rates.
I also remember the endless times that our instructors pounded into our heads the fact that our certificates carried with them a considerable burden. Our certificates are issued by the government [public administration] because we have demonstrated a level of competency, in both mental ability and the ability to translate that into the accomplishment of repairs to aircraft or the components that make up an aircraft. Broadly stated, we have been granted a degree of public trust in that we will use our brains and our physical abilities to follow the proper processes in insuring the aircraft we work on are repaired properly.
Since my appointment to the National Transportation Safety Board, I have seen examples of maintenance personnel who have failed to use their knowledge or who accomplished some task improperly. These improper procedures result in enforcement actions taken by the FAA against the certificate they hold. They were held responsible for their actions or lack thereof.
The dictionary lists under the word responsible as "being legally or ethically accountable for the care of another," also, "involving personal accountability or ability to act free from guidance or higher authority," and finally, "capable of making moral or rational decisions on one's own, thereby being answerable for one's behavior."
When you look at all three together it is clear that the public, through the government, expects a certificate holder to act responsibly and will hold us accountable when we are found to have violated this public trust.
We are not the only professions that are held responsible for our actions as individuals. Doctors, Attorney's, and Certified Public Accountants, to name a few, are also held accountable for their actions. They also hold a form of certificate issued from some official body, which grants special privileges to them based on a measurement of mental and physical ability. They are also held accountable with not only action against their certificates but, they may also face civil and criminal charges. They are recognized as professional — aviation maintenance personnel are not. There is something wrong with that, but I won't go there.
As part of my responsibilities as an NTSB Board member, I review and formally vote on the appeals of certificate holders that the FAA has found its actions warrant enforcement action. It is surprising to see the numbers of mechanics who have found themselves in the enforcement process and even more revealing to look at the reasons why. A considerable portion of our training is focused on processes that include understanding what we are faced with and thinking through the problem and applying our good judgment within the confines of the appropriate manual. Remember, we receive our authority to perform maintenance from the manuals and it is difficult [not impossible] to get into trouble when we follow the manual.
Are we following the manual when we ask and receive verbal instructions from a co-worker? Many times in my career, I have followed instructions from a maintenance control person who is located miles away and whose job it is to provide such information in an effort to expedite repairs. I recall only once asking for the manual reference for the guidance I received. If these instructions are wrong, who carries the responsibility?
The answer is the person who signs for the accomplishment of that task — no if, ands, or buts — the person who signs for the task is responsible and will be held so for the satisfactory completion of that task.
This holds true if the guidance comes from the person working next to you, or from your supervisor or manager. When you sign your name for accomplishing a task, you are saying that you followed all the appropriate provisions in accomplishing this task. If that guidance is wrong, the person signing will be held responsible.
There is another area that we must pay close attention to, and that is in preparing the paperwork for signing. I have prepared paperwork for a large number of mechanics who worked for and with me, and I do not believe I ever put them in harm's way with the paperwork I created, but that may not hold for others who have performed the same function. If you allow someone else to prepare the paperwork for your signature you need to review the paperwork carefully to insure that it accurately reflects the work that was accomplished. Our responsibility to maintain accurate records is clearly spelled out in the FARs and can result in an additional violation when things go wrong.
Why am I writing about our responsibility and the process that maintenance uses to insure a safe air transportation system?
For most of this year, I have reviewed maintenance cases which have as the core charge, a failure to follow the very basic process outlined above. As I review some of these cases, I am forced to just pause in disbelief at the numbers of otherwise good mechanics that will have the certificate blemished for ignoring the basics.
Every task we accomplish must be considered as critical. Although the role of the passenger entertainment system in the SwissAir accident is not clear, the fact that it possibly could have been involved makes the point that there is no task that is unimportant. Everything we do must be accomplished to the highest standards. I realize that there are pressures we put on ourselves and that are put upon us, but we cannot allow even the smallest task to be accomplished in a substandard manner — and that includes all the paperwork.
Responsibility is what separates a certified aircraft mechanic from a plumber or a plasterer. There are many careers in our society that require knowledge and ability to accomplish, but when you add the public trust and the individual responsibility, the list becomes much shorter. We must never lose sight of our responsibility.
