Oversight Needs to Keep Pace With Expansion of Contract Maintenance

Airlines engaged in outsourcing maintenance are advised to practice self-defense and ensure that their on-site quality-control people are keeping a sharp lookout. Federal Aviation Administration (FAA) inspectors are spread too thin and are not able to provide effective oversight, according to a July 8 report by the Department of Transportation Inspector General (DOT/IG).

Its review of FAA oversight of in-house and outsourced maintenance shows that the agency has too few inspectors spread across too broad a front, with an ineffective and porous database that does not point to problems in a timely manner for better targeting of scarce inspector resources. In fact, the DOT/IG report presents staffing information suggesting how reassigning the FAA’s inspector workforce could provide more oversight of outsourced maintenance work.

FAA officials largely agreed with the DOT/IG’s findings but discounted any negative impact on safety.

“There’s no data in the report to support a safety issue,” FAA administrator Marion Blakey said in reaction to the report’s findings. The audit was done, the DOT/IG said, as part of its ongoing reviews of “the FAA’s oversight of aviation safety.” The DOT/IG couched its findings in terms of a potential “vulnerability” to safety. Recall that the FAA has often touted its commitment to “data-driven safety.” In this case, the DOT/IG has found a dearth of data at the federal level on which to assess the safety of maintenance practices.

Indeed, one could argue that the DOT/IG documented potentially fatal malfeasance at 85 percent of the facilities it checked over the course of its 16-month inquiry, as in this finding: “At 18 of 21 facilities checked by government investigators, contract mechanics used incorrect aircraft parts and improperly calibrated tools and had outdated manuals. Recall that the difference of forty-thousandths of an inch can determine whether a jackscrew assembly must be replaced or not (as was revealed during the investigation into the fatal 2000 crash of an Alaska Airlines twinjet from a stripped jackscrew). Hence, an improperly calibrated tool can put pilots and passengers at risk.

Improper procedures can do the same, as was the case in the Jan. 8 crash of an Air Midwest twin-turboprop. The elevator control cables had been improperly tensioned by the outside maintenance contractor, leaving the pilots with insufficient pitch control (see ASW, May 26, and June 16).

“The type and extent of problems we found at domestic and foreign repair stations … all relate to a lack of effective FAA oversight and, if not corrected, could lead to an erosion of safety,” the DOT/IG intoned.

FAA oversight of overseas repair stations is about to become more challenging. The DOT/IG report mentioned bilateral agreements the FAA has with Ireland, France and Germany for the regulatory authorities in those nations to provide maintenance oversight on the FAA’s behalf. However, on Sept. 28 the 15-member state of the European Union will stand up a single regulatory body, the European Safety Agency. As the DOT/IG remarked, “With the formation of this Agency, current agreements with individual European countries can no longer exist.”

“To provide oversight of FAA-certified repair stations, the United States would have to execute an agreement with the newly formed Agency,” the DOT/IG report explained.

Principal findings from the report suggest that the apprehended erosion of safety oversight is well under way:

• A lot of outsourcing. Airlines are increasingly outsourcing maintenance to repair stations both in the United States and overseas. As of December 2002, major air carriers outsourced from 33 to 79 percent of their total aircraft maintenance expense.
• Outsourcing trend is up. In 1996, major air carriers spent $1.5 billion (37 percent of their total maintenance costs) for outsourced aircraft maintenance. In 2002 the major carriers outsourced $2.5 billion (47 percent of their total maintenance costs) in maintenance work. Carriers that traditionally relied on in-house maintenance are re- evaluating their decision.
• Regional carriers may be leading. “While our audit focused on major air carriers … Atlantic Southeast Airlines, a subsidiary of Delta Air Lines, currently uses outsourced maintenance … for two-thirds of its maintenance costs,” the report said.
• Trend is not tracked. The FAA does not track how much maintenance work is outsourced, domestically or overseas, by air carriers.

Focus remains fixed on in-house facilities. From the report:

“Despite the increase in outsourcing, the FAA concentrates its oversight at the major carriers’ in-house facilities.”

“For example, in 2002, certificate management inspectors performed 199 reviews of 1 air carrier’s internal maintenance operators and only 7 reviews of repair stations used by this carrier. However, this air carrier outsourced 65 percent of its maintenance costs in 2002.”

Undetected discrepancies. Discrepancies in repair station operations went undetected at 86 percent of the stations visited. Findings that follow were culled from various places in the report:

“FAA’s oversight … did not verify that repair stations used FAA-approved parts and properly calibrated equipment in 71 percent [of the] facilities we visited.”

“We found instances where these repair stations used outdated maintenance manuals [and] failed to segregate scrapped parts from usable parts.”

“Of the 21 repair stations we visited, 2 foreign and 2 domestic repair stations failed to correct deficiencies previously identified by FAA inspectors.”

“Problems can be attributed to FAA inspectors’ inability to perform continuous, comprehensive surveillance.”

Overseas and out of sight. The FAA conducts few inspections of overseas repair stations and is unable to determine if they meet its standards.

Unrequited recommendations. Because of 10 accidents tied to improper or mistaken maintenance, the National Transportation Safety Board recommended in 1997 that the FAA improve its oversight of in-house and outsourced repair stations. “While these recommendations were made over six years ago, we found that the same weaknesses in repair station oversight prevail today.”

Stretched thin. From the report:

“The district office inspectors in the 9 offices we reviewed had oversight responsibility for an average of 23 operators, 9 of which were repair stations.”

“One FAA inspector was assigned oversight responsibility for 21 repair stations, 21 agricultural operations, 12 service-for-hire operators, 3 general aviation operators, 2 helicopter operations, and 1 maintenance school.”

“One inspector admitted there is not enough time to perform thorough repair station inspections and that he just ‘skims the top’ of repair stations’ operations.”

“Compounding the weaknesses in FAA’s oversight structure is the fact that the district office and certificate management inspectors do not share limited repair station inspection information they have obtained.”

Swift and superficial. From the report:

“FAA inspectors do in fact record thousands of … inspections [but] the number of inspections recorded is misleading.” (Emphasis in original)

“We found that an inspector recorded completion of 10 different inspections in 1 day for a visit to 1 repair station … we found that inspectors generally conduct full facility inspections … only once or twice a year.”

“District office inspectors do not document what they did to complete the inspection.”

Data deficient. From the report:

“Key pieces of inspection information are omitted from the SPAS (safety performance analysis system) database.”

“This database is only as good as the information put into the system. For example, certificate management inspectors are not required to provide the names of repair stations they have inspected, and district office inspectors are not required to provide what was inspected at each repair station in the databases that are entered into SPAS.”

“As a result, certificate management and district office inspectors are unable to use the database to… help FAA better target its inspector resources.”

Concise conclusion. From the report: “Air carriers’ increased use of repair stations and the procedures FAA uses to provide oversight of these facilities have left vulnerabilities in the quality of aircraft repairs performed at these facilities.”

The FAA already has stepped up its inspections of contract repair stations. According to the FAA, some 20,000 such inspections were conducted in fiscal year 2002. As of June 1, the agency had conducted 15,685 repair station inspections. This tally was at the two-thirds point in fiscal year 2003, indicating that the FAA already has completed 75 percent of the total number of inspections it conducted last fiscal year.

It may be possible to provide more coverage of repair station activity. Consider a few facts. The ratio of in-house to outsourced maintenance work has changed, from about 1.7- to-1 in 1996 (63/37 percent) to about 1.1-to-1 today (53/47 percent).

The FAA reports that its oversight workforce presently numbers 1,745 inspectors. Of this number, 708 provide oversight of 5,250 repair stations doing 47 percent of the work. The remaining 1,037 inspectors provide oversight of 139 airline shops, which do 53 percent of the work. The FAA states that these 1,037 inspectors also look at the outsourced repair stations used by carriers. However, the DOT/IG report shows that this does not happen very often. For example, of nine carriers using a mix of in-house and outsourced work, only about three percent of the FAA oversight inspections were of contractor facilities. There appears to be an opportunity to switch some of the 1,037 inspectors to the work being done by the 708.

>> The full DOT/IG report may be viewed at http://www.oig.dot.gov/item_details.php?item=1124 <<

One Man’s Perspective on Contract Maintenance

John Oxley, Air Midwest regional site manager, Jan. 31 interview with National Transportation Safety Board investigators, following Jan. 8 crash of Air Midwest flight, in which faulty maintenance at the contractor maintenance facility in Huntington, W. Va., has been implicated (extracts):

Q: You have been with Air Midwest for 21 years.

A: Actually, 23 years.

Q: How do you feel about the ones who are contracted, as opposed to keeping —

A: I didn’t like it. But … we are trying to keep in business and the way things are now, I can see it is going to save money. I never did like it.

Q: Do you have any concerns about it?

A: Not particularly. I am just of the opinion we ought to do our own maintenance. It just has always been my opinion. I think that Air Midwest had their own QA [quality assurance] inspectors … if we are going to have contract maintenance I think we ought to have our QA inspectors.

Q: [Technician] turnover is a problem?

A: Yes … what is the use of somebody coming in here for a month and you are training for a month and he has gone? You have to start all over again. To get experience on the floor, that is what the benefits would be, to keep experience on the floor … I probably have had more people quit than I had on the floor … I probably had 15 files of people who quit; in six months that is a high turnover rate [the facility had slots for nine mechanics].

Source: NTSB, see http://www.ntsb.gov/events/2003/AM5481/docket/default.htm