The fact AMFA is opposed to overseas outsourcing and is active in the battle against such practice!
If Checking it Out had half a brain, he would know UNIONS do NOT OUTSOURCE WORK, the CARRIERS DO! If you dispute that, show us proof that AMFA outsourced any work to overseas maintenance. It is only the company union minded fools that believe the UNION and management are the same thing.
November 12, 2002
Mr. Brian Huckaby
Office of Aviation Safety
U.S. Department of Transportation Office of Inspector General
Sam Nunn Atlanta Federal Center
61 Forsyth Street, N.W.
Atlanta, GA 30303
RE: Review of Air Carriersâ€™ Use of Repair Stations
Dear Mr. Huckaby,
I have included a synopsis for your evaluation regarding our opinion of the relationship of the airline industry in the United States and repair stations (3PMP). This information is based upon many certified aviation technicianâ€™s experiences in the field, newspaper articles, independent surveys and documentation from aircraft fatal accidents.
There are many factors that have contributed to the multitude of issues regarding repair stations that have surfaced in the aviation industry by the turn of the century, some obvious and others shrouded. Of interest is that a Boeing study of commercial jet airplane accidents from 1988 through 1997 cited only 6% maintenance attributed accidents during that time frame. The programs and regulatory structure that were intended to enhance aviation safety since the Boeing study have been overshadowed by a lack of oversight in recent years, as future statistics may prove. Recent National Transportation Safety Board findings determined that maintenance has played a major role in at least 50% of major aviation incidents as compared to 25% just a few years ago.
Following is information though not complete resulting from space constraints but that may provide insight into the shortcomings of Federal Air Regulation 145 and the current relationship between air carriers, repair stations and the Federal Aviation Agency.
- MSG-3 Maintenance Program (Maintenance Steering Group â€“ 3); Accepted by the FAA in 2001, MSG-3 allows air carriers the flexibility to adjust maintenance, inspection, and overhaul intervals based upon reliability data collected without prior FAA approval. The program requires three parameters to be used as a continuous review to determine when and if modification of the program is required â€“ Aircraft performance, reliability and maintenance accomplished data. The recent submission to the NTSB crash investigation of Alaska Airlines Flt. 261 by AMFA states in part: that AMFA believes the MSG-3 process is flawed, in that it allowed the extension of maintenance intervals to escalate beyond a reasonable requisite. A Seattle Times article dated November 8, 2002 stated that: the NTSB in the draft report from the Flt. 261 investigation, as expected, concludes that the probable cause of the crash was failure of the jackscrew mechanism. The report also states that Alaska, with the FAAâ€™s approval, reduced the frequency with which it lubricated the mechanism, increasing the likelihood of excessive wear. MSG3 focuses maintenance tasks on limited areas of an aircraft. A most recent example of is that of United Airlines mechanic George Gulliford, who was reprimanded after reporting a crack in the frame of an aircraft that was not in the assigned inspection area. Gulliford filed a complaint with the Secretary of Labor-OSHA and was afforded relief from discrimination from his employer, United Airlines. How would a non-certified mechanic supervised by George Gullifodâ€™s supervisor have responded to a similar situation? Reference: Yahoo newswire, Tuesday January 15, 2002 â€œAMFA Attorney Earns Victory for Aircraft Mechanicâ€.
- A Subcommittee on Aviation Hearing on Capitol Hill in August 2002, titled Adequacy of FAA Oversight of Passenger of Aircraft Maintenance analysis by AMFA states; Even though the (Continuing Analysis and Surveillance System (CASS) program has merit, the program is left incomplete, subject to erroneous data collection, with final analysis left to the carrier itself. The CASS is a program designed to provide surveillance and analysis of the air carrierâ€™s continuous airworthiness maintenance program for performance and effectiveness and to implement corrective action for any deficiencies, yet in our opinion will fall far short of the intent. The reality is, that the checks and balances in the CASS program leaves the responsibility of compliance (data collection that may be obscured) to the carrier itself that is reviewed by the FAA ATOS program guidelines. The agency is already over burdened and understaffed as stated in a April 9, 2002 Wall Street Journal article by the Transportationâ€™s Department Inspector General, faulting the FAA for failing to carry out adequately, an enhanced inspection regime designed to keep close surveillance on the nationâ€™s largest carriers.
- Aviation maintenance is unique in that the complex equipment that personal are required to maintain requires an individual with a multitude of skills acquired over a period of many years. In our opinion, the number of experienced certified technicians performing maintenance on aircraft is directly proportional to overall air carrier safety. The question could be asked; Is it physically possible to provide close supervision of maintenance personal as some may suggest as a solution to the future shortage of qualified technicians? Even if the ratio were one supervisor for each non-certified mechanic, the reality is that an atmosphere would be created where there would no longer exist a series of checks and balances that the current system has. The lower level manager/supervisor employed by an air carrier usually receives a bonus based on measured accomplishment of goals which creates a tremendous pressure to shortcut maintenance. Historically, supervisors have been loyal to the needs of the air carrierâ€™s philosophy of providing a product at cost whereas the FAA certified technician has an ethical and legal responsibility to perform maintenance flawlessly as that responsibility is imprinted in a signature. The non-certified individualâ€™s performance is measured by criteria that the airlines establishes, unlike the influence that the Federal Air Regulations have on a certified technicianâ€™s performance. The typical air carrier/third party maintenance contract incorporates a penalty clause that heavily fines the repair station for each day the aircraft is overdue from a scheduled overhaul. The relationship between supervisory and the non-certified mechanic in a repair station environment that fosters maintenance shortcuts to meet schedule promotes unsafe practices in our opinion.
In summary, Federal Air Regulation 145 provides air carriers with self-regulating authority and the responsibility to monitor the results of aircraft maintenance performed by repair stations. That authority coupled with the MSG-3 maintenance program encourages shortcuts to expedite maintenance. A recent survey of 16 airlines with responses from over 1500 certified mechanics indicates that the system promotes unsafe practices. The question was asked; Have you experienced/discovered maintenance discrepancies (safety of flight issues) on aircraft shortly after being released from a maintenance check accomplished by a 3PMP (third party maintenance provider/repair station)? Fifty-eight percent (58%) answered yes and thirty percent (30%) answered no. Yet, if the answer was yes: Do you feel your airline has taken corrective action to eliminate the problem? Ninety percent (90%) answered no.
Major air carriers, having extensive overseas route structures, attempt to balance costs vs. safety by reducing maintenance performed by certified technicians in this country by sending the maintenance to a third party overseas. Air carriers are utilizing the language of FAR Part 145 that allows a foreign repair station to operate under different rules and far greater initial cost savings in countries such as China. A United States air carrier was recently forced to remove a Boeing 747 from service resulting from the discovery of over 2,000 maintenance discrepancies found by certified technicians after the aircraft recently returned to the United States from an extensive 3PMP overhaul in China.
Another area of concern is that uncertified mechanics employed by repair stations both domestic and abroad are not required to comply with the Federal Air Regulations that are quite specific regarding random drug and alcohol testing.
Security is another concern resulting from a recent arrest of an al Qaeda operant employed by a 3PMP in Singapore after many years of employment. Background checks are questionable in many countries outside of the United States.
In addition, the effectiveness of the regulatory authority of the Federal Aviation Agency is in question as the current shortage of airworthiness inspectors suggests.
Thank you for the opportunity to participate in this most important investigation. The Aircraft Mechanics Fraternal Association (AMFA) would be pleased to offer your office any further assistance in gathering information from those in the industry, the certified aviation technician, whose primary job function is insure the safety of flight on a daily basis.
The Aircraft Mechanics Fraternal Association (AMFA) currently represents certified technicians from six air carriers that include Alaska, Atlantic Coast, American Trans Air, Horizon, Mesaba and Northwest Airlines. Our motto â€œSafety in the Air Begins With Quality Maintenance on the Groundâ€ echoes the tremendous responsibility of certified technicians in the aviation industry today.
AMFA National Safety and Standards Director
c.c. O.V.Delle-Femine, National Director
Terry Harvey Assistant, National Director
Maryanne Demarco, AMFA Labor Administrator