Loose Seats Bring Airline Heat

New air carrier contract maintenance regulations

Last November American Airlines (AAL) in the midst of its Chapter 11 proceeding got hit with a series of loose seats in some of its first line 757 and 767 aircraft. American had decided to reconfigure these planes to provide more leg room for the passengers by removing a row of seats and re-spacing the remaining. There were seats that came loose on at least four flights and a later incident where a ship was grounded because of installation problems. Nobody was ever injured, but we ask …why seat install problems?

I have personally seen passenger seats stacked in rows on the hangar deck while awaiting repairs, painting, or new upholstery … seat maintenance and installation is no mystery to those accustomed to doing it … it is a fundamental part of the airline business. Indeed, pilots in some airlines are also permitted to remove and replace seats on some small commuters to provide for changes in passenger or cargo loads. Well, that’s precisely where investigators found where the problem was: training and experience.

Company technicians for years have been installing and removing seats. AAL’s mechanics complained that they should have been given the job rather than sending it to outsiders.

AAL like many other carriers has had to reduce costs to stay alive. That usually includes outsourcing. It hired an outside company to make the seat installation changes. The FAA found out that the workers provided to do the work did not understand how to properly install the seats. Some were unlicensed and some were students supposed to be under supervision of licensed mechanics and AAL personnel.

Reports regarding the contractor personnel focused on the fact that most of them in some areas were temporary workers hired when the contract presented itself. They were usually on-call people who did not hold regular daily employment until a contract came along. This fact was usually a relevant factor in determining the quality of the work to be performed.

Whether or not the air carrier evaluated the background and experience of the contract workers was also a question raised by regular staff mechanics. There are at least two FAR sections that bear directly on this area as follows:

FAR 121.363 Responsibility for airworthiness

“(a) Each certificate holder is primarily responsible for (1) the airworthiness of its aircraft, (b) A certificate holder may make arrangements with another person for the performance of any maintenance or alterations. However, this does not relieve the certificate holder of the responsibility specified in paragraph (a) of this section.”

Time and again, this FAR has been used to require the air carrier to provide on site licensed inspectors to verify that the work is done in accordance with the company’s maintenance manual. In this case AAL said that the workers misinterpreted the manual. (The workers don’t get to interpret the manual, they are supposed to be told precisely what to do by people who do know the manual.)

Further details of the investigation revealed that one of AAL’s 767 aircraft had been grounded in Uruguay (South America) until it was fixed. An expensive event to say the least.

FAR 121.373 CAS program

An air carrier’s continuing analysis and surveillance (CAS) program should also include continual analysis and surveillance of any outside contract work to ensure its oversight and detection of any faults or errors. These ongoing analysis programs require routine audits to determine the status of the contract repairs or other work. FAA ASIs are supposed to examine CAS programs to ensure compliance.

My personal experience as a director of safety at a 121 air carrier was simply that we had to have our people on site at all outsourced locations to provide double inspection oversight (RII) of the work being done, to be sure it matched our maintenance manual requirements. Obviously this was not done in these cases. It might seem that here, AAL would have been much ahead of the game and spent less money and time if it had let its own trained technicians handle the work.

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