Safety and Compliance

AMFA National Safety Initiative

Compliance Reminder: Non-Compliance Awareness
September 19, 2017

On July 13, 2017, Southwest terminated an Aviation Maintenance Technician (AMT) for deviating from “all required procedures included in MT 735-00-01.”

The letter of termination indicates that the Company relied on surveillance tape to determine that the AMT may have allowed a second mechanic to sign for work that the AMT had performed:  “security video evidences that a second AMT did not enter the area of the flight crew oxygen cylinder and therefore, required processes and/or procedures of MT 735-00-01 were not completed.”

Based on this single incident, Southwest justified the AMT’s termination in the following terms:

Southwest Airlines expects its Aircraft Maintenance Technicians to follow policies and procedures to ensure the safety of our customers and employees.  Based on the aforementioned conduct, which has led to Southwest Airlines losing confidence in your judgment and ability to properly follow regulations, policy and procedures, your employment with Southwest Airlines is terminated.

Disclosures to the FAA have also led to the AMT’s receipt of a Letter of Investigation.

The unfortunate AMT in question is one of several of your fellow aircraft mechanics Southwest has terminated in the recent months for alleged non-compliance with documented maintenance procedures.

All members are urged to carefully review maintenance documentation applicable to O2 bottle installation.  This installation requires a sign-off for verification by a second AMT confirming the O2 supply valve is open and safety wire has been performed.  The Aircraft Maintenance Manual (AMM) gives removal and installation procedures and should always be consulted when remove and replace or servicing of any O2 bottle. Wholly aside from written SWA company policy and procedures, every AMT has both the right and obligation to perform maintenance in accordance with the standards embodied in our maintenance manuals. When we say “obligation,” we refer to Federal Aviation Regulations (FARs) that mandate that all aircraft maintenance must be performed using the “methods, techniques, and practices” prescribed in applicable maintenance manuals.  14 CFR § 43.13(a).  The FARs further stipulate that maintenance work be properly documented. Reference 14 CFR § 121.701(a) which states:

“Each person who takes action in the case of a reported or observed failure or malfunction of an airframe, engine, propeller, or appliance that is critical to the safety of flight shall make, or have made, a record of that action in the airplane's maintenance log.”

As confirmed by these recent incidents, Southwest uses video surveillance to enforce its compliance policies and has apparently shared videotape with the FAA. We believe that our members recognize their moral and legal obligation to perform their maintenance work in a manner that complies with the FARSs and all applicable maintenance manuals; however, no one is perfect all the time.

A memorandum was distributed to all SWA Technical Operations employees on January 3, 2017, that concerned the reporting of potential non-compliance. As a licensed Airframe and Powerplant Technician you have the right to protect yourself and your license by utilizing the Aviation Safety Action Program (ASAP). We are all human and mistakes can happen, so take every precaution to avoid them, but know that AMFA’s involvement with ASAP is to utilize a non-punitive program to ensure the continued safety of flight where our AMTs are concerned.  All AMTs should become familiar with the ASAP process, particularly now that it has been forcefully brought to our attention that our momentary lapses may be recorded and used to terminate our jobs and revoke our licenses.

In closing, please remember to stay focused on the job you are performing and task at hand. Do not let the distractions of everyday life re-direct your attention away from what is happening in front of you. Please use the buddy system to help each other remain compliant. It is extremely important to watch out for ourselves and each other, that’s the essence of being in a Union.

We all need to ensure that each of us is able to return home each day to the families we love and support.

In Solidarity,

Scott King
National Safety & Standards Director

Compliance Reminder February 14, 2017

Awareness has been raised regarding damage to cargo panels as there are several maintenance documents that direct Aircraft Maintenance Technicians (AMTs) to inspect the cargo compartment panels for damage. The primary concern when inspecting these panels is the aspect of fire containment. The Aircraft Maintenance Manual (AMM) gives damage limitations and should be consulted when investigating any damage that has been noted. At Southwest there are maximum damage limits within the B737NG AMM for damage that may be repaired. Attention to tape condition is also important in sealing the cargo compartments to minimize the oxygen amount.

Another area of concern involves the types of tires on the Southwest B737-800 fleet. Radial tires have been introduced into the -800 fleet. These tires are marked with a blue stripe on the wheel and tire and the word “Radial” is stenciled on the sidewall. Of most importance is the fact that both tires on the landing gear must be of the same type, the intermixing of radial and bias tires is not allowed. Attention to detail is highly important when determining tire replacement type.

There was a memorandum distributed to all SWA Technical Operations Employees on January 3, 2017, that concerned the reporting of potential noncompliance. As a licensed Airframe and Powerplant Technician you have the right to protect yourself and your license by utilizing the
Aviation Safety Action Program (ASAP). We are all human and mistakes can happen, so take every precaution to avoid them, but know that AMFA’s involvement with ASAP is to utilize a non-punitive program to ensure the continued safety of flight where our AMTs are concerned.
All AMTs should become familiar with the ASAP process - it is a good idea to be prepared. In closing, please remember to stay focused on your task at hand. Do not let the distractions of everyday life re-direct your attention away from what is happening in front of you. We all need to ensure that each of us is able to return home each day to the families we love and support. It is extremely important to watch out for ourselves and each other, that’s the essence of being in a Union.

In Solidarity,
Scott King
National Safety & Standards Director

Compliance Reminder: Workplace Drug and Alcohol Policies, August 3, 2016

Since there has been increased employer activity lately in response to drug and alcohol policies, including some terminations, I would like to review some key points about this topic. All employees should review and become familiar with your employer’s Drug and Alcohol Policy. Employees are responsible for being free of alcohol and illegal/prohibited drugs and/or the metabolites of these drugs while at work/on duty.
To ensure safety and compliance, the Alaska Airlines (ASA) Policy has a prohibition of alcohol use within eight hours of reporting to work/duty. Southwest Airlines (SWA) calls for four hours, except for pilots and flight attendants. Use your judgement as in some cases four hours is certainly not enough time, and eight hours can be pushing the envelope depending on amount you drink. If you work third shift then go home and drink, you can lose track of time and fall under the “at risk” category. This is where most of the issues have arisen.
The DOT and FAA require that any covered employee who receives a DOT breath alcohol test result of .040 or greater be immediately removed from performing safety-sensitive duties. SWA employees with an alcohol concentration result of 0.042 or greater will be terminated. If an employee with an alcohol concentration result of 0.040 or greater is a Part 61, 63, 65, or 67 Airman Certificate holder, SWA is required to report such results to the FAA. Under ASA Policy an employee who receives a DOT or non-DOT alcohol test result of .040 or greater on a confirmation test will be discharged in accordance with applicable laws.
There are several types of testing with drugs and alcohol: pre- employment, random, reasonable suspicion, post- accident, and return to duty. Employees MUST submit to the test if requested to do so. Failure to submit to the test or comply with all testing procedures and instructions will be deemed a refusal to submit to testing and will result in termination. Employees represented by a Union may have Union representation, but failure to secure such representation in a timely manner will not delay the testing process.
We also have to be careful with marijuana as in some states the use is legal; however, in our safety-sensitive job, it is never acceptable to consume. Per 49 CFR, part 40 it does not authorize “medical marijuana” under a state law to be valid medical explanation for a transportation employee’s positive drug test result.
To be proactive, if you need assistance, both airlines have Employee Assistance Programs (EAP) that are available. SWA has a Drug and Alcohol Team available 24-hours a day and may be reached at 214-536-9225. You can also call ClearSkies at 1-800-742-8911 or go to (access code: swa7370). ASA employees can contact Lifeworks at (888) 456-1324 or go to (user id: alaska, password: spirit). Your job will not be in jeopardy by using this service. You will not be fired for using this service.
Whether employees are on or off duty, if they are in uniform and consume alcohol they are in violation of policy and may be subject to discipline or termination. Use good judgment and avoid getting yourself into a situation that might subject you to disciplinary action. Be safe, be aware of the rules of the road, and make sure you are in compliance.

David A. Brooks
National Safety & Standards Director

Compliance Reminder: Awareness, June 6, 2016

There has been a lot of talk lately about our “Safety Initiative” and having to adjust our maintenance culture; the problem is that it seems that no one is listening. We not only have maintained status quo on this issue, but seemed to have gained in areas that we do not need to have growth – we have noticed an increase in aircraft damage.

What is causing the increase? Can we blame the dirty dozen? This would be easy to do on paper in an ASAP report; however, sometimes we are just not following procedures as prescribed in the maintenance manual or we are in too much of a hurry to get the task accomplished. We all need to slow down, take a breath, evaluate, follow procedures prescribed by the manufacturer and our companies, and perform our duties as skilled Aircraft Maintenance Technicians (AMTs). We need to be aware of our past culture of “get er done.” We need to ensure that we are not being pressured by others or ourselves to “get er done.” Our regulations and demands are much greater than they were ten years ago. You will never be disciplined for doing the job correctly and should never be harassed by management or even your peers in the completion of your duties. The time that we spend by following our new culture will pay for itself tenfold when it prevents accidents or incidents of any type to aircraft or persons.

I want you to understand that most accidents can be prevented following these tenets. There is not only an increase in AMTs causing damage to aircraft system-wide, but there are also people that are doing paperwork incorrectly and not following procedures. Ignorance is not an excuse. Be aware of the
“know before fix” bulletins and related correspondence that come out almost daily to include new procedures. We need to make sure we are aware of these and follow them. Change, otherwise known as moving the cheese, is difficult. We need to be aware and overcome this, and do the task regardless
of how mundane or unimportant it might seem.

You also need to remember “big brother is watching.” This futuristic quote from George Orwell has come true today, not only at work, but in life in general. Be aware of your actions and realize that at any time you could be under surveillance. This is not only a camera, but the companies have been
tracking taxi speeds and have pointed out speeds and noncompliance such as not aligning IRUs before movement. We are also tracked other ways, so be conscience of your actions. If we are doing the right thing, following our manuals or other reference materials, this should not even be an issue.

Don’t let the distractions of stressful contract negotiations become a “human factor” that could diminish your work performance, and please take the time to review the AMFA National Safety Initiative at Be sure that you continue to work in full compliance of all maintenance manual requirements and continue to be the best and most professional in the business.

David A. Brooks
National Safety & Standards Director

Compliance Reminder: Attention To Detail,  March 3, 2016

In grade school I was always reminded to dot the i’s and cross the t’s, and in the military working on aircraft, I was always taught to remember the phrase “attention to detail.” These two items are our biggest challenges in maintenance today as most of our Letter of Investigation (LOI) and Aviation Safety Awareness Program (ASAP) reports are responses to these concepts. I am referring to paperwork and undocumented maintenance.
With today’s workloads and the complicated aircraft and new procedures, we must pay attention to detail. There has been a rash of undocumented maintenance lately, and some with greater consequences than others. If you are familiar with our “Safety Initiative” you will recognize some of the trends that are happening with our technicians and see the causes.
Let’s look at what some of the causes could be. Are you in a hurry? Do you just want to get done or are passengers waiting on the aircraft? Is this the way you have always done this procedure? Don’t let yourself get caught in any of these improper scenarios. Some of the issues that arise from this usually fall on the last person to have signed the procedure or installed the part. Not only are we supposed to comply IAW AMM, but we are also paid to do so and no outside factors should interfere.
We must remember Safety over Schedule (SOS). What we as AMT’s must worry about is the task at hand. We cannot worry about anything except our task, and the correct way to perform it. We need the correct references, tooling, parts and of course the time to complete our maintenance. Our concern is the correct way to perform the maintenance for our passengers and our safety, and to protect the license that we have worked so hard to acquire and need in order to make a living.
All of this has to do with our culture. We as technicians want to discover what is wrong and fix the issue. We will put in a starter motor and send the aircraft on its way in the quickest manner possible. We also need to remember the effectivity, maintenance manual procedures, and paperwork. We need to document removing or disconnecting anything, even just to facilitate maintenance as we may have to turn the job over to someone else. We do not want to have pressure put on us, whether it is by ourselves or by an outside source.
The membership has not yet realized that our culture is what needs to be fixed. It’s not the same aircraft, paperwork, FAA, or company. There are new strict regulations that have to be followed or consequences will, and have, occurred. We need to change the old mentality and realize that with new aircraft and procedures arriving every year we have to stay on top of the game - it is not business as usual. We need to change our culture.
Familiarize yourselves with the ASAP bulletins that your AMFA ASAP Representatives are distributing monthly. These reports have a myriad of information and examples of what to look out for. Familiarize yourselves with our safety initiative and its contents. Both union and company agree with this concept, and safety is our utmost objective. Be safe, be careful, and continue to do the outstanding job that we as essential Aircraft Maintenance Technicians perform daily.
David A. Brooks
National Safety & Standards Director

Compliance Reminder: TSA Directives,  November 2, 2015

There have been policy changes with the TSA in the past two months, and I wanted to clarify these changes for our members to prevent misunderstandings. I would first like to start with lithium ion batteries, especially the ones we carry in our tools such as drills, ratchets, and screw guns.

The newly revised 49 CFR 175.10 states that you can have lithium ion batteries in checked or carry on baggage, however, all spare batteries are prohibited from checked baggage. Spare batteries must be carried on and placed in original retail packaging or by otherwise insulating terminals by taping over exposed terminals or placing in a separate plastic bag or pouch. An individual may carry only two spare batteries and they must not exceed 12 volts.

Alaska Airlines considers these batteries as hazmat and must be shipped as such. Be careful to observe your company policies and adhere to them, especially when going downline. Southwest Airlines (SWA) takes this procedure a step further. In SAM 854A, the AMT Field Trip Checklist, it states that lithium ion batteries are unauthorized hazmat and instruct for them to be carry on only; lithium ion batteries cannot travel in your toolbox as checked baggage, only as spares that are carried on. This also means that if you sign this SAM Form and do not adhere to what you are signing, it could be indicated as falsification of records and you could be subject to termination .This falsification has already happened with a member and concluded in termination. Keep in mind that the FAA does allow you to check these batteries installed in the tools, but not spares. SWA policy prohibits this to employees going downline so be aware of and follow your company policies.

Please also keep in mind that you cannot take tools over seven (7) inches long onboard the aircraft as a carry on. It does not matter if you are a mechanic, you will be instructed to check these tools. If you have any issues at different stations with any of these policies, ask to see a supervisor to achieve a solution. Do not argue as not all stations are aware of the policy or adhere to it.

The TSA has also recently changed the rules with reference to the sterile area. All airline employees who are traveling as passengers must go through a TSA screening checkpoint with any accessible property they intend to carry onboard the aircraft regardless of whether you are on company business or personal travel. While on a downline trip you must go through the TSA security screening checkpoint after leaving your tools planeside and prior to boarding. No employee can use the jet bridge from the ramp to board an aircraft as a passenger. Keep in mind that this does not apply for test flights or ferry flights. The TSA has also been increasing random inspections in the aftermath of some incidents, to include a gun smuggling event.

After passing through the screening checkpoint and entering the sterile area, any employee who leaves the sterile area for any reason must be re-screened prior to boarding the flight as a passenger. An employee is permitted to exit the sterile area, go to the Security Identification Display Area (SIDA), and return to the sterile area without being re-screened prior to boarding a flight only as a crewmember. A crewmember is defined as a person assigned to perform duties onboard an aircraft during flight time. A mechanic on a downline trip is not a crewmember.

Pay attention to your company policies on travel, whether on duty or off. Keep in mind that if TSA decides to pull your SIDA badge, you cannot work and it takes a lot of paperwork to get it back. Also companies are very serious about hazmat because of the dangers and the fines associated with it. Be informed and pass along the information to other members. Remember that you do not need to rush while being re-screened. If you miss a connection because of this, it is the world we now live and it must be accepted. As passengers we are accustomed to being able to bring our tools and a bottle of whiskey on board; however, circumstances have changed, our cheese has definitely been moved, but this is today’s norm. Continue performing your duties as knowledgeable and skilled technicians. Above all, stay safe!

David A. Brooks
National Safety & Standards Director

Compliance Reminder: Taxi Awareness,  October 14, 2015

We recently had an incident involving two AMFA members while taxiing an aircraft that resulted in an aircraft being damaged. This incident has resulted in many conversations regarding what should or should not happen while taxiing an aircraft. This article in no way references the details of the above mentioned incident, rather its purpose is to clarify some of the proper procedures of taxiing an aircraft.

I would first like to discuss the phrase or command “without delay.” After discussing this phrase with an Air Traffic Controller (ATC) member, I would like to take this opportunity to offer further explanation and clarification. This phrase indicates a severe request. “Expedite” is also used by ATC when prompt compliance is required to avoid the development of an imminent situation. These phrases are similar but “without delay” is not in the AIM or in the ATC Glossary; however, it is mentioned in the Air Traffic Organization Policy and can be used interchangeably with expedite. Expedite is imminent danger, very similar to without delay which is severe, but is considered by ATC as more urgent. Always remember if you cannot move quickly, deny movement and request to stay or wait. “Taxi without delay,” means, move your tail. With this request you should offer a polite acknowledgment, and increase your taxi to no faster than the FAA’s mandated speed of a fast walk or whatever your procedures allow, or deny the movement.

Some other similar phrases that you might hear at different airports meaning the same thing are: PDQ, at once, directly, expeditiously, forthwith, immediately, in a hurry, in no time, instantly, now, on the instant, on the spot, pretty damned quick, promptly, pronto, quickly, right away, right now, smartly, speedily, straightaway, swiftly, this minute, without further delay. These phrases can all mean the same thing and have the same actions tied to them involving an imminent situation. Stop the aircraft and request ATC clarification if there is any confusion.

If the aircraft is stopped, higher power settings and additional time may be required to get the aircraft moving. It may not be prudent to accept a clearance for an expedited runway crossing. Do not use excessive break away power. Southwest Airlines (SWA) is limited to 35% N1 on single engine taxi and states, “Use caution when exceeding 35% N1,” and Alaska Airlines (ASA) is at 65% N1 while taxiing the aircraft. Smoothly advance the thrust to begin taxi. Retard throttle to idle when practical after the aircraft begins to move. It is not recommended to operate both engines at high power (above 75% N1) simultaneously at any time. Don’t slam the throttles as the NG sees the demand and when it catches up the advance load is already provided as it results in higher speed than intended.

Both companies also require you to align IRS to display ground speed and to wear seatbelts, which is contained in the checklist. You must have a checklist at all times while taxiing and a current Jeppesen airport chart must be used. This checklist must be used by maintenance employees for all taxi and/or engine operations. A cultural norm should be to use the checklist .The Aircraft Maintenance Technician (AMT) must verbally call out the challenge and then perform the action and respond. All movements and indications are recorded in DFDR and also CVR is in operation and records all conversations; therefore, there should also be a sterile cockpit, only essential communication needed.

Maintenance taxi operations are performed at speeds allowing safe operation and control of the aircraft under existing surface and/or weather conditions. ASA allows a taxi speed not to exceed 60 knots for maintenance taxi check; however, states never to exceed 40 knots on a taxiway. The SWA taxi checklist states maximum taxi speed is approximately 20 knots unless directed to expedite by an ATC. Maintain a safe taxi speed commensurate with actual runway and weather conditions and anticipated braking action at the end of the runway or taxiway. Be aware that it is easy to overestimate the cornering and braking ability of the aircraft. It may be necessary to slow to taxi speeds as low as 5 knots when preparing to exit the runway or turn from a taxiway. It is a good policy to not exceed 20 knots and 12 to 8 knots in turns unless conditions dictate otherwise.

Any person knowingly deviating from these policies and procedures or operating an aircraft in a reckless and unsafe manner may have his Engine Taxi/Engine Run-up Certification revoked and may be subject to termination. AMT work culture has always been, “do whatever it takes to get it done,” however, we must follow proper policies and procedures. Don’t put pressure on yourself to expedite your task or to not properly follow procedures. These are the requirements. Take the time to follow procedures correctly and keep yourself proficient. Familiarize yourself with the safety initiative, our new culture, and follow it. Stay safe!

David A. Brooks
National Safety & Standards Director

Don't Put Your License in Jeopardy, Sept. 1, 2015

In the past several months we have had members involved in significant incidents that have resulted in not only losing their jobs, but also their livelihoods. By losing their licenses that they worked very long and hard to obtain, they also lost their livelihood.

Part of the issue is that we are currently experiencing a lack of manpower and a workload that is too large to be completed in the allotted timeframe. We can only do so much in the allotted time per the manuals, and we should not feel pressure by either ourselves or anyone else to expedite the process. We all know that it is nice to get things done and complete tasks, but if it results in causing an accident or being accused of falsifying records and, therefore, not qualified to hold an A&P license, then it is definitely not worth it. Remember that others’ lack of preparation on their part does not constitute an emergency on mine. We can go through our workdays for years and not have an issue and ignore this advice, but the times have changed and these examples are unfortunately becoming more commonplace. These are not the same days as we worked even ten years ago. There is a higher workload and a higher consequence for being involved in an incident. We do have the Aviation Safety Action Program (ASAP), but per its criteria it cannot be utilized for all events and the alternative consequences have been severe.

Please take the time to become familiar with our Safety Initiative which is detailed on the Safety and Standards page of the AMFA National Website. We have been stressing safety over schedule, changing our culture of how we have done work in the past. There is no need to expedite or rush through any maintenance procedure. You are paid to do a job and to do it safely and correctly. The consequences of a mistake due to one of the dirty dozen reasons could be the loss of income, cost of damages, or even loss of life. Either one of these is certainly not an outcome that we would prefer, so we need to takes steps to insure that these scenarios do not happen.

Review all paperwork and manuals every time you do a job, especially if it is a procedure that you have not done recently. We all know that paperwork and manuals constantly change and we need to make sure that we have the latest update, checklist, parts effectivity, and procedure to accomplish each task. As we well know, the people that write some job tasks have no clue how to do the job or how long it will really take to accomplish the task. Our job is to question and make sure that the job that we do and sign for is done correctly. Do not deviate unless authorization is given to you in writing. Our paper work and MELs are also a big issue with the company and FAA, and we need to give this the same attention to detail as we do our maintenance tasks.

In closing, work safe and be aware of our culture change. Protect your license and insure that your employer and passengers on our aircraft have the best maintained aircraft for a safe and comfortable flight. It doesn’t matter if you are on the land or in the air, safety must be observed everywhere.

David A. Brooks
National Safety & Standards Director

Big Brother Is Watching, Feb 2, 2015

What did George Orwell say in his book "1984?" He said that big brother was watching you as he describes a society where surveillance controls the citizenry. Well let me tell you, today we live in a similar society. We constantly hear on the news where individuals are caught on camera doing various things like driving infractions, illegal activities, delivering damaged packages, etc. We live in a society where we are being monitored and there are copies of what we are doing. This includes using the internet at home and at work. Why am I telling you this? I am neither a doom and gloom individual, nor a prepper that could be paranoid about the state of our nation, but I am talking about how the aircraft maintenance technicians that are just doing their jobs are affected by this type of surveillance.

All airports have cameras that at some stations are so high tech that they can clearly read the employee number on your badge. There are also cameras in our hangars, break rooms, parking lots, and at time clocks. We are just people doing our job so why should we be concerned? Well, these cameras can be used to view all of our actions. They have done this in the past and it has resulted in several mechanics losing their jobs. This is not paranoia, this is fact.

You might think this does not concern you and will never affect you; however, if you signed off on work completed by a coworker and there was a discrepancy with their work or paperwork, there very well might be videotape leaving you and your coworker with no defense. You could lose your job over something this simple.

As the National Executive Council (NEC) has been stressing all along, I am advising you to document all maintenance, to ensure the task is done per the manuals, and to be aware that you are most likely being recorded when you are at work. If the company wants us to do a task that will take eight hours to complete, and the aircraft arrives at 2 AM, then simple math tells us the task cannot be completed in that time frame. We also can only complete one task at a time. If we are given several aircraft to perform maintenance on, we should complete the first, including all paperwork, and then move to the next. There is only so much time in a shift to complete all tasks assigned.

To sum it up, make sure you have the proper paperwork, documents to do the maintenance, tooling, and you that you complete the paperwork-all per the manuals. We get paid to do a job and we do it very well and efficiently because we are experienced professionals. Our employers and the FAA are holding us to certain standards, and we in turn should hold them to the same level. We do not want any member to suffer the loss of their jobs, or to have to deal with the FAA in a Letter of Investigation. Be aware, follow procedures, stay safe, and keep doing the same excellent job that you do each and every day.

Situational Awareness, Dec 15, 2014

What is situational awareness and why is it so important to us as Aircraft Maintenance Technicians (AMTs)? It is defined as simply being aware of your surroundings and the conditions you are in. You must always consider where you are and what's going on around you. This requires a person or a group of people to assess and become aware of relevant factors in their current environment, consider any consequences of these factors, and foresee future implications. This means to be aware of the conditions in your work area and to recognize and address unsafe conditions before they become an issue.

Examples of a lack of situational awareness could be moving aircraft and not acknowledging existing structures or aircraft in area, aircraft not secured during a storm, or tools left in a position where they could easily fall and cause damage or injury if they are disturbed. It could be darkness, noise, or not using your personal protective equipment. The best people to identify problems are the AMTs as they are the ones performing the work and are familiar with the circumstances of each individual event. If the safety concern is beyond their control, they can report the issue to their Safety and Standards Chairman or group member for a remedy.

So, what is the best way to address situational awareness? Trust your gut – your instincts will begin to practice situational awareness well before your mind does. This is why you have heard listen to your gut or initial instincts as this is the first step of situational awareness. Learn to recognize the situation and then act on any red flags that arise. The workplace environment is the primary area where you will need to focus most of your attention to address situational awareness issues; however, you will also need to practice this at home and on your way to and from work. We want to eliminate unsafe practices which can lead to incidents/accidents. Keep in mind weather conditions, lighting conditions, communication, procedures and work conditions among other factors.

It can be easy to not worry about the workplace, as nothing has happened here before and it is not likely to happen in the future, but we must believe that prevention is the best way to represent safety and to be situationally aware. Starting from the time we leave home in the morning until the time we return, we get so busy because of all the things life throws at us, we sometimes forget about situational awareness. It does no one any good to get injured or killed either on the way to work or responding to a maintenance call at the aircraft. We being human can and do lose touch. It is imperative that we as professionals stop and get a handle on what is actually going on before we throw ourselves in overdrive.

We have all been caught once or twice being in too much of a hurry to get the job done to go put out the next fire. It seems that the simple task, or the task we do all the time, is the one that will come back to bite us. You may know that someone else is working on the aircraft, but has he or she done all the things required making the aircraft safe to work on? Go and check, have they left a door open, or a wrench in the wheel well? Maybe they have lost situational awareness in a way that will adversely affect you. You owe it to yourself, your passengers, and your family to stop and check on what is really going on.

Situational awareness can never be plateaued, and the AMT on the ground is responsible to combine many elements like safety, legality, and quality. Also remember that dialing 911 might not work at all stations, and some stations have individual safety numbers. You should have these numbers in your phone in case you need them in a hurry. You must recognize situations, and if you are feeling ill -- especially if you are in a position where you work alone or if you see something that requires an emergency contact -- you will have these numbers readily available so you can immediately call for help. Stay involved, recognize potential issues, and be situationally aware. It is better to call and not be needed than to be needed and not call. Protect yourselves and your coworkers. Stay aware and safe!

Safety Over Schedule, Oct 29, 2014

One of the most common themes for Aviation Safety Action Program (ASAP) Reports submitted from Aircraft Maintenance Technicians (AMTs) involve time constraints and pressure. It is not always a supervisor standing over us saying, "get the job done now," sometimes we as technicians put the pressure on ourselves. We need to realize this concept and correct the problem where it exists. This is where the idea of safety over schedule comes in to play.

The job we are hired for is to inspect, service, and repair the aircraft and then send it back in airworthy condition. We are the only ones that can deem the aircraft airworthy. We cannot base our work on aircraft schedules. The company is always trying to keep to their schedule, and that is what they should try to do however, we have no control over tooling, parts, arrival times of aircraft in the case of overnight work, or other unforeseen circumstances. Our job is to do the work according to the manuals, and return an airworthy product. If the aircraft is not finished, the work will have to be rescheduled, cancelled, or it will just have to wait until the correct procedures are accomplished. Do not rush, something as simple as paperwork not filled out correctly can get you a Letter of Investigation (LOI).

In the case of an accident, there is more financial benefit to the company to adhere to the policy of safety over schedule. It is also more beneficial to the AMT to prevent themselves from being hurt, receiving an LOI, possibly losing your job or worse. Of course, without being said it is always beneficial to our passengers.

Do we need another ASA Flight 261 to become safer? We all must take safety serious and be proactive instead of reactive, and this includes the company. Make sure you do things correctly, not quickly, and make sure you do the right thing even when no one is watching. You will never receive punishment for taking a delay on a turn or an originator if you are doing maintenance according to the correct procedure.

Another of the top human factors causes of incidents are not using or reading technical publications and culture as affected by leadership. We have addressed the former in past articles, but it serves to remind us that we need to check the proper manuals each time we perform maintenance and be aware of updates, read and sign, and make sure we have the newest revisions at all times. The latter is also a concept that we have discussed in the past. Our culture needs to change, not only ours, but also leadership’s. How can we assist them in changing their culture? We need to reinforce our newly changed culture with each other, and if questioned relay this to management. We have done this last month in meetings with the companies, explaining this concept with our Safety Initiative. If you have not heard of this presentation, contact your local President or Safety and Standards Chairmen.

With all this being said, be aware of your surroundings, pay attention to safety, and have all these concepts in your thoughts as you conduct maintenance. Familiarize yourself with our new Safety Initiative and we will all be more efficient and safe in our jobs as professional AMTs.

Is Safety Your Priority?, Sep 9, 2014

The crash of Continental Express Flight 2574, where missing screws on the horizontal stabilizer led to the disaster, was the most dramatic turning point for "safety culture" in the United States. The probable cause of this accident included "the failure of Continental Express management to establish a corporate culture which encouraged and enforced adherence to approved maintenance and quality assurance procedures." They placed far too much emphasis on getting airplanes to take off on time than correctly following safety procedures. As a result of this and other similar aviation accidents, what we now know as "safety culture" came to the forefront. This movement for air safety continued with the enactment of the Wendell H. Ford Aviation Investment and Reform Act for the 21st Century on April 5, 2000, which is also called AIR 21.

Our carriers have said time and again that their number one priority is safety – not profit, airplanes, or routes. They say it is the safety of our passengers and employees that they are concerned with. This is a bold statement, and it has been reemphasized very recently. AMFA has always agreed with that sentiment, and we want to confirm our commitment to safety by connecting the words of our carriers to real action on behalf of the flying public.

Safety is our number one priority, but how do we accomplish this? What can we do as Aircraft Maintenance Technicians (AMTs) to further safety in our field? First of all we need to be vigilant in thinking about how we are doing things, how others are doing things, and ultimately being safe. We have to be alert and make sure we are aware of our surroundings. Another thing we need to do is be more accountable. What does that mean? When it comes right down to it, we are accountable for our own actions, and everything that we do has a consequence. If you forget to lockout a system, go work on that system, and by doing so cause damage or injury, is it your fault? There are a lot of factors that are in play here, but in the end it could be your fault. Perhaps there are problems with procedures, training, or even the maintenance manual, but the bottom line is you are responsible for your actions. Another point is that we need to be informed by reading safety bulletins, maintenance manuals, and alerts that get posted to ensure the latest information is available to us.

We have to realize that we are all members on a safety team, and are accountable for safety, not just your safety representatives. If there is a puddle of oil on the floor, don’t wait to tell the safety representative, as it is your job as well to clean up that spill. We need to be proactive and not reactive when it comes to items that could cause unsafe results. It is always your place to point out and rectify safety issues while on the floor or on the line, because that’s what a safety team member does.

Another thing we need to consider is our culture. Culture is a word for people’s "way of life," meaning the way groups do things or how we think while performing our jobs. We cannot continue with our current culture and need to change it. I am not talking about the company culture, such as getting cookies at Christmas; I am talking about our work culture. One thing that is constant in our profession is change. We change shifts, aircraft types, and maintenance programs, and another thing that has to also change is our work culture.

It has been said by management that we do need to change our culture. With different programs and the extended maintenance packages, we do not need to rush and should rather take the proper precautions. With recent events including members being terminated, we need to make sure that the work is accomplished per our new program instructions, and use approved tooling to finish the tasks. We can no longer afford to follow the old culture of just getting it done by using belt loaders or other unapproved items to accomplish maintenance. We need to be cognizant of this change, and work accordingly.

Compliance Reminder: AMT Danger Prevention, Jul 29, 2014

Aircraft Maintenance Technicians (AMTs) have an awesome responsibility entrusted to them, but it is also an inherently dangerous job. Many of us have heard of or seen close calls where injury or death was imminent. I would like to discuss some recent incidents.

In the mid 1990’s at Dee Howard, a MRO in Texas, an AMT was doing a routine card on the thrust reversers of a Boeing 757. During his maintenance, he had to place his body halfway in the reversers to get access to the components he was replacing. Because of norms, complacency and other factors, he did not go into the cockpit to ensure that there were lockout tags on the controls and the hydraulics. Someone in the cockpit was doing checks in another area and activated the hydraulics, resulting in the AMT being crushed to death.

In January 2006 in El Paso, Texas, an AMT was sucked into a jet engine as he and other technicians looked for an oil leak. The AMT had stepped into a designated hazard zone near the engine. He was doing a leak check on the engine at 70%. This was a failure of the mechanic to follow written procedures and directives.

Another accident occurred in Minneapolis in 2010 where an AMT was caught in the nose landing gear doors of an Airbus A319. The AMT was working on the nose gear of the aircraft when he somehow got trapped in the gear doors. When emergency crews arrived at around 5:30AM they found him lying at the wheels of the aircraft – he had no detectable pulse.

In 2010 there was an incident at SWA involving the collapse of a nose gear. Two AMTs received minor injuries; however, the incident could have been much worse. One of the AMTs was pinned in the nose gear wheel well and could have been crushed were it not for some lucky circumstances.

There are lots of safety procedures when maintaining aircraft. In our manuals we have three levels of warning:

• WARNING – is something that could kill, seriously injure, or cause significant damage to the aircraft or equipment

• CAUTION – is something that will likely cause injury or damage

• NOTE – is an advisory of things to be aware of, but unlikely to result in injury or damage

Anything that involves moving parts usually has a WARNING as most are hydraulically or electrically powered. When working in these areas you are normally instructed to deactivate the system, install safety lock pins, and placard the controls so they are not inadvertently operated. These procedures works well if people adhere to the instructions, but human nature and short cuts leads to complacency and errors due to either being lazy or rushing the job. Just like an aircraft crash there is usually a sequence of events that lead up to a tragedy on the maintenance floor.

These are some of the reasons we need to have a continual talk with our AMTs about safety, the dangers involved and how we can prevent them. Read your AMMs and refer to them every time you do a job. Follow the warnings and be safe as we don’t want to hear about one of our members being hurt or injured, or having us injure someone else.

Compliance Reminder: Be Safe, Work Safe, Stay Safe, Jun 19, 2014

It is important to discuss a couple of issues that we are having around our respective systems. The first one is the safety of the aircraft. We have had several aircraft damaged this year due to various reasons. Some of them are procedural problems where certain steps were not followed and damage resulted. Some of them were problems where we were in a hurry, and we damaged aircraft during movement. The answer to most of these incidents is to follow the current maintenance manual reference, don’t rush the job and miss steps, and to make certain correct procedures have been followed before you move that aircraft or pull that switch. We are all on time constraints; however, if it is at the cost of damage, injury or your job, it is not worth the rush.

The next issue is workplace safety. We never want an OJI. They cost us time and injury, and it also has a cost to the company. Prevention and awareness are the answers because most injuries can be avoided. Some of the most common injuries that occur are the back and shoulders due to improper lifting. Make sure that you use proper lifting techniques, and if there is ever a question then ask for help. Remember that we are all getting older and more susceptible to injury, so protect yourself. Of course the majority of this is common sense, but worth a review. Wear your safety glasses when needed; if you are in doubt then wear them. Make sure you also have adequate ear protection available and use it when needed. Be aware and stay alert as to what is going on around you. If you hear someone call for power, hydraulics or flight controls, then make sure you are clear of anything that could harm you and let others in the area know also. Be aware that long hair and baggy clothing could get caught in moving parts. If you wear a badge lanyard, make sure that you have the kind that breaks away at the back of the neck; otherwise, if it gets caught it could hang you.

Floor cleanup is also very important. Clean spills ASAP – don’t assume it is a job for someone else. If someone slips and hurts themselves, this could have been easily prevented. The take-away is to clean your messes as you go. Going along in conjunction with cleanliness is to put away your tooling, stands, ladders and any other items when not in use. The clutter of these items could also cause an accident and putting these items away is a good habit to get into. Make sure you wear fall protection. It is not worth your life to save five minutes by not wearing it. I know we are better today at this, but I am sure we all remember seeing someone walking the crown of the aircraft without any protection. We have come a long way, but still need to be vigilant. I know it should not have to be said, but when working around live busses, make sure there is no power on that bus, or even better no power on aircraft. You would be surprised at the injuries we have seen because of this.

Finally, be aware and always use the AMM specific locks to keep your hands, legs, or head from being crushed by a spoiler or pinched by an aileron or even worse. Clean your areas, and don’t be in such a rush as to forget procedures, or leave tools behind. The life or limb you save might even be your own. Our goal is to service or repair the aircraft without damage or injury and this can be accomplished with the above ideas in mind. Be safe, work safe, stay safe.

Compliance Reminder: Be Safety Compliant, Apr 30, 2014

I have been involved with safety for quite some time now and I still don’t understand why some people disregard it or say nothing severe will happen to them. A major concern of mine is with people working around hydraulics, particularly when they are moving and not locked out. Don’t stick your head in that Kruger flap, and don’t operate the TR's without being cleared! I know we have been very lucky in the recent past not to have had a maintenance related death, and we certainly want no part of that, or even an injury. If you follow the manuals, to include company policy and industry standards, then you should not even be in the area of these dangers if not properly locked out, disabled, or correctly prepared. My point is that we do not need to be in such a big hurry that we sacrifice perhaps our limbs or life, or that of someone else.

Follow procedures. In this day and age these machines can be very unforgiving and we don’t need to rush anything. We also need to make sure that we are rested enough to perform these tasks. This means that you need to take your assigned breaks, to include lunch. If you indeed have to work through lunch, then put in for a paid lunch. In most cases you get a paid lunch even if your lunches are already paid for by contract. My point is that you should not have to skip lunch, as you need breaks during the workday and need to eat your lunch. This will nourish you and help you to get through the workday. This is especially true for those on the graveyard shift.

Tasks are becoming more complicated, and we as technicians are getting more and more of them piled on our plates. Make sure that you read and follow the maintenance manuals as they are continuously changing. You are the one that will get an LOI, not the company. In this more profit-oriented environment that we are employed in, we need to be even more conscious of our actions and to remember to CYA.

Compliance Reminder: Cover All the Bases, Feb 18, 2014

Our members have become accustomed to change, and we have certainly experienced our fair share of it in the past few years. One of the biggest changes is that companies are trying to operate status quo in a leaner environment. As technicians we are expected not only to do more with less, but we also have major changes in current practices to include paperwork, policies, and procedures. All of which, if not done correctly, can lead to a Letter of Investigation (LOI) or a possible safety issue on the aircraft itself that could result in an air return or worse.

To protect our craft, our individual licenses, and the flying public, we must take care that we are aware of and follow our current regulations, procedure manuals, and maintenance manuals. Some management individuals have said that, “we will keep adding on the work until you cry uncle.” We must understand that to do the job properly, we need the proper documentation, references, tools, and must have enough time to do the job properly. Be aware of your environment and ensure that you remain in compliance with safety protocols to protect yourself, your licenses, and public safety.

It has been stated that poor planning on your part does not necessarily constitute an emergency on my part. Make sure you manage your time effectively and dot the i’s and cross the t’s. We all appreciate where we work and want nothing negative to happen because of our oversight, or because we were in a hurry to push an aircraft without completing everything required. We live in a different world today than we did ten years ago, and our job and skill is even more important. Keep up the good work, and remember to think safety always.

Compliance Reminder: Doing More With Less, Dec 19, 2013

Our members have become accustomed to change, and we have certainly experienced our fair share of it in the past few years. One of the biggest changes is that companies are trying to operate status quo in a leaner environment. As technicians we are expected not only to do more with less, but we also have major changes in current practices to include paperwork, policies, and procedures. All of which, if not done correctly, can lead to a Letter of Investigation (LOI) or a possible safety issue on the aircraft itself that could result in an air return or worse.

To protect our craft, our individual licenses, and the flying public, we must take care that we are aware of and follow our current regulations, procedure manuals, and maintenance manuals. Some management individuals have said that, “we will keep adding on the work until you cry uncle.” We must understand that to do the job properly, we need the proper documentation, references, tools, and must have enough time to do the job properly. Be aware of your environment and ensure that you remain in compliance with safety protocols to protect yourself, your licenses, and public safety.

It has been stated that poor planning on your part does not necessarily constitute an emergency on my part. Make sure you manage your time effectively and dot the i’s and cross the t’s. We all appreciate where we work and want nothing negative to happen because of our oversight, or because we were in a hurry to push an aircraft without completing everything required. We live in a different world today than we did ten years ago, and our job and skill is even more important. Keep up the good work, and remember to think safety always.

Compliance Reminder: Safety Culture, Oct 4, 2013

There is a new phrase going around the safety community and it is “safety culture.”  What is safety culture? Safety culture is the ways in which safety is managed in the workplace, and often reflects "the attitudes, beliefs, perceptions, and values that employees share in relation to safety."

What is safety? Safety is the condition of being safe from undergoing or causing hurt, injury, or loss. There are different types of safety.  One, the most thought of, is personal safety.  This is thought of when you are wearing your safety vests, your harnesses, or performing a myriad of tasks that we do every day on the job. Another type is process safety; this is thought of as task fulfillment.  This is what we do every day as a matter of procedure.  Is the way we are doing things safe, or are there better processes to do the job more safely?  You are accountable for your actions, but dependent on procedures or current norms.  With an improved safety culture you look for things that affect you in every work day and in your personal life, not only that, you look at the way you accomplish tasks, and identify problems if the norm or status quo is not working as it should.

We as mechanics have seen that most procedural changes are reactive rather than proactive.  Safety culture is trying to change this, to see ahead, to hear from all concerning safety or procedures that need to be addressed. We have seen many cases of OSHA violations and FAA inspections or Letters of Investigation (LOI) that could have been prevented if we had been more diligent in our efforts or more bold with our decisions to address the situations instead of burying our heads and letting the other person worry about it.

“Do the right thing even when nobody is watching.”  This was a statement made by  Deborah A. P. Hersman, Acting Chairman of the NTSB while talking about “safety culture.”  This is something that all AMTs should embrace, and with the continuous additions to all tasks, manuals, paperwork, and workload they should recognize the potential for safety and to manage the tasks, risks, and to know the consequences of not being able to perform these correctly and safely.

Compliance Reminder, Jul 31, 2013

One of the dirty secrets of the airline industry is that maintenance managers regularly subordinate aviation safety to on-time performance. This ugly phenomenon arises from the fact that airlines rate their maintenance managers’ performance, not on their technicians’ proficiency in detecting safety items, but on keeping aircraft in revenue service.

The principal bulwark against deteriorating maintenance standards is the individual mechanic who has the courage and integrity to resist the pressure to pencil-whip unairworthy aircraft back into service. Fortunately, in most developed countries, mechanisms exist to protect a technician who is determined to do the right thing.

In the United States, a federal whistleblower statute, commonly referred to as “AIR 21,” provides remedies – including back pay and attorney’s fees – for employees who are subject to discipline in retaliation for making good faith reports.

At one major U.S. airline, maintenance managers advised that series of 737 aircraft arriving for maintenance were known to have cracks in a section of the fuselage that was not part of the scheduled maintenance package. Management warned that anyone discovering these cracks would be subject to discipline work for leaving his/her assigned work area.

Notwithstanding this warning, one brave avionics mechanic wrote up a frame defect which, according to the applicable maintenance manual, constituted a “major repair.” In response, the airline condemned the employee for “viewing cracks located on frame locations outside your work area,” which would “no longer be tolerated or acceptable.” The airline warned that a repetition of this offense “will result in disciplinary action up to and including discharge.”

Not willing to be intimidated into substandard maintenance practices, the avionics mechanic pursued an action through the AIR 21 complaint process. The final result was an order directing that the airline purge his disciplinary file and pay his attorney’s fees.

At another major airline, a unionized mechanic availed himself of the arbitration process to combat retaliatory discipline. An aircraft experienced oil loss of such magnitude (over seven liters) that a potential engine problem was indicated. The aircraft mechanic initially assigned the discrepancy replaced the CSD oil cooler to see if that was the problem. In order to confirm that this was the proper fix, an oil leak check had to be performed and documented on the appropriate discrepancy card. Nevertheless, the crew chief released the aircraft into revenue service without any documentation confirming that an oil leak check had been performed.

A lead mechanic, upon discovering the open discrepancy, reported the matter to the Federal Aviation Administration, which resulted in the grounding of the aircraft. While the airline took no action against the crew chief who committed this error, it terminated the lead mechanic.

The lead’s labor union stood behind its member by engaging legal counsel and demanding a full evidentiary hearing before a neutral arbitrator. The process was a grueling one, lasting three years, but ultimately resulted in the lead mechanic’s reinstatement with full back pay.

As a labor attorney, I have come to recognize that a critical element of the U.S. airline industry's safety has been the rule of law. While the remedies afforded by both AIR 21 and the standard union contract are properly characterized as merely “make whole” relief – which do no more than restore the technician to his pre-retaliation economic status without imposing a substantial economic disincentive on the carrier – these remedies support an aviation technician’s faith that his adherence to safe aviation practices will ultimately be vindicated.

Unfortunately, major carriers have responded to the costs of maintenance in developed countries – including the costs imposed by the rule of law – by outsourcing thousands of jobs to countries where the rule of law does not prevail.

If airline managers in the developed world frequently pressure their mechanics to engage in substandard maintenance practices, it is distressing to contemplate what happens in the context of authoritarian regimes where a growing share of aircraft maintenance is being performed. One cannot pretend that a Chinese aircraft technician, or one in El Salvador for that matter, has any choice but to do what he is told.

Is the airline industry safe? Whether it's the dramatic reduction of domestic maintenance staffing, the outsourcing of maintenance to vendors in authoritarian countries, the elimination of pre-flight and post-flight inspections, or the evaporation of spare parts inventories, the answer is this – we are a lot less safe than we used to be and we are on a downward slope that has been heavily greased by greed and indifference.

To halt the slide, it is imperative that aviation technicians in every country enjoy the protections afforded by the rule of law. To the extent these protections do not exist at the now-favored destinations for outsourced maintenance, governmental aviation regulators from the developed world need to recognize that, when they perform mandated inspections of maintenance operations in authoritarian countries, they must do double duty.