There is No Better Way
Than following the manual
By John Goglia
July / August 1998
As I travel around the country, I am constantly asked questions about the Federal Aviation Regulations (FARs) and various company procedures.
Some of these questions are relatively easy, while others require a great deal of understanding of a given air carrier's policies and procedures. Sometimes, the company and the FAA certificate holding office do not agree on the meaning of certain wordings which can really cloud an issue.
Since the FARs allow an air carrier to create its own maintenance manual, there are differences not only between the manufacturer's maintenance manual and the air carrier's manual, but there are differences between air carriers as well.
This has caused problems as we have seen so many mergers and so many air carriers go out of business which in turn, caused technicians to suddenly find themselves working under similar but different policies and procedures. This has also caused problems within the FAA safety inspector ranks for the same reasons.
As human beings, we all get accustomed to doing things a certain way and when forced to change, we all tend to resist. Also, when something does not frequently occur and we become unsure of what action to take, we often fall back to the action we know best, which may be the policies of a previous employer.
A recurring problem regards the proper use of the minimum equipment list (MEL). Judging from the comments and questions I receive, there is a considerable amount of misunderstanding about the origins and use of the MEL system.
Under the FARs, all airlines are required to use the master minimum equipment list (MMEL) as a basis for their MEL. If the system is required as part of the type design, then the aircraft can only be released for flight if the MEL allows for the system to be inoperative.
A frequently asked question is "Where does the MEL originate?" The short answer is that the FAA, the manufacturers, the airlines, and labor (pilots and technicians) will meet to discuss what is appropriate to have on the MMEL.
This is an ongoing process and sometimes items actually get removed from a previously approved list. There is usually a lively discussion of each item on the list. This is also the point where any special instructions are added to the master list.
The special instructions are the area that get a number of technicians in trouble, as we must comply completely with the special instructions or we will be in violation of the FARs. Failing to follow the instructions completely is the number one reason for an FAA violation by a technician.
In the cases where I have been called to assist a technician in a MEL violation, it is common to find someone who thinks he has a better way and fails to complete all of the special instructions. Although the reasoning may be sound, it is still a violation — as neither the air carrier nor the certificated technician has the authority to deviate in any way from the procedures published in the master MEL.
In addition to the special instructions (tasks) that maintenance must complete, there may be operational limitations that the pilots must follow. An example of this may be the transfer of function to another operating component, or to require the flight crew to use other instruments.
From a technician's view, it is important to note that an airworthiness release is not compromised by the MEL and we are not in violation of the FARs when deferring items under the MEL — as long as we complete all of the special instructions, if any.
In today's operating environment, we as employees for an air carrier simply do not have the authority to deviate in any way from the published (manual) procedures.
All air carriers have procedures allowing deviations from the manual if approved by engineering. We must follow these procedures, or we, the technician who signs, will be in violation — not the air carrier.
