Workarounds and AD Compliance Don’t Mix

The FAA has zero tolerance for workarounds when an Airworthiness Directive is involved.


As mechanics, we are all aware of how often incorrect paperwork – including maintenance manuals and work cards – force us to resort to workarounds to accomplish the job at hand. While the FAA recognizes that workarounds exist, it has never officially sanctioned them nor has it done much to correct the problems occasioned by incorrect procedures. Other than establish some well-meaning industry-government study groups that are long on study and short on action, the FAA has done very little to address these problems. I should know; I have sat on a number of these committees and currently sit on one.

The closest the FAA has come to any action was a FAASTeam alert sent out in January 2011 to mechanics stating that incorrect maintenance manual procedures should be brought to the attention of manufacturers. Unfortunately, the bulletin failed to tell mechanics whom or where to send these reports. Clearly, most manufacturers have thousands — if not tens of thousands of employees — and hundreds of offices and probably a dozen or more addresses around the world. So the idea of mechanics writing up these reports and sending them out blindly seems, to put it bluntly, ridiculous.

And I don’t mean to minimize the problem of correcting the incorrect manuals or ensuring that new manuals are correct. But leaving the problem solely in the hands of mechanics is not only unfair but dangerous — to the public at risk when maintenance procedures are incorrect and, quite frankly, to mechanics whose certificates and livelihoods are at risk when the FAA decides to take enforcement action for resorting to workarounds.

That last issue was brought home to me very recently in two enforcement cases I was involved with as an expert witness. Without going into a lot of details because the cases are still on appeal, suffice it to say that the FAA has zero tolerance for workarounds when an Airworthiness Directive is involved. Even though the service bulletin incorporated by reference into the AD and resulting job cards were clearly incorrect, the FAA revoked the mechanics’ certificates for not following the job cards to the letter.

Report incorrect procedures to FAA Safety Hotline

My suggestion to all working mechanics based on this experience is to review, at a minimum, any AD-related procedures that you believe are incorrect and filing a report with the FAA’s Aviation Safety Hotline: www.faa.gov/contact/safety_hotline/. According to the FAA’s web site, every report is forwarded for review — what the outcome of that review will be or how long it will take is, of course, unknown. A report can be filed anonymously. (However, if you want feedback on your report or if the FAA needs additional information to act on your report that will not be possible if you file anonymously.)

In the meanwhile, if the maintenance manual procedures you are given to work with are incorrect you need to raise that problem to your supervisor (if you are lucky enough to have a union, raise the problem through your union rep). In the end, workarounds — especially when related to AD compliance — put your license on the line.

 

John Goglia has 40+ years experience in the aviation industry. He was the first NTSB member to hold an FAA aircraft mechanic’s certificate. He can be reached at gogliaj@yahoo.com.

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