Stop me if you’ve heard this one before.
Over the course of our careers, we’ve had the opportunity to get to know a lot of people who work at the FAA. One such person is a FAA Safety Inspector who was visiting a 14 CFR Part 145 Repair Station in the United States.
As part of his normal job, he’s out on the hangar floor when he decides to do an in-progress inspection on a job being accomplished. This time, it happened to be a job card from the 121 airline which was being performed by the repair station.
Interestingly enough, when this Inspector picked up the task card he sees that it reads American Airlines on the top of the task card. Naturally, he thought “Well, that’s a pretty neat trick,” since the airline in question (the provider of the task card!) is NOT American Airlines.
So, as any good Inspector does, he starts digging a little deeper… and in doing, so he finds a flap track inspection being accomplished by a Technician on the floor. When he asks to read over the work instructions, he notes that the work instructions state:
Inspect flap track per American Airlines Engineering Order XX-XXX-XX.
He then turns to ask the mechanic if the mechanic had ever accomplished this task before. Unfortunately, the answer is yes — even though he has NO access to the American Airlines Engineering document specifically called out in the work step… Yikes.
So once this discovery was made, the FAA Inspector shares that finding to the other Inspectors in the ranks, and they start looking around to find (as of the writing of this post) that the same problem has been found at 5 other airlines. It has been considered such a potential area of concern that the FAA has passed along the information to all of its personnel across the entire country.
So how did this happen?
We asked the same question — how does one airline end up using manuals and maintenance program task cards from another airline? Did they borrow them? Steal them? Buy them? Either way, it doesn’t really matter because in the eyes of the FAA it’s not the airline’s Maintenance Program… therefore it’s a problem.
What we found out was that this was more simple than you might expect. In all five of the cases, the airlines involved were somewhat smaller and they had purchased or leased used aircraft from a lessor or the original airline owner directly. And, as it turns out, when they bought these airplanes, the manuals were included as part of the purchase! Sounds great, right? No need to go back to the OEM and get the manuals. The problem with this is that your larger airlines have the ability to ask Boeing for what is called “Customer Originated Changes,” or COCs.
These COCs allow the airline, through its Engineering and Technical Publications departments, to replace the original Boeing instructions with their specific instructions – similar to the American Airlines’ EO being referenced for the flap track inspection. The problem, of course, is that if anyone other than the original airline tries to accomplish this work, they won’t have access to the source data… and how do you comply with something when you don’t have access to the work steps? And, even more importantly, it’s not in their maintenance program!
In each of the five cases, the FAA required the airline to purchase an aircraft manual subscription service from Boeing to ensure that their manuals did not contain Engineering data from any other airlines.
It’s important to note that in all the cases, the airlines purchasing/leasing the aircraft did not realize that things like the aircraft maintenance manuals and task cards were customized to the previous operator so they would be unable to comply with them, but the net result was the same: their maintenance program was ineffective and technically non-compliant with FAA regulations.
So, if you think your organization might be in the same boat, open up the introduction to the manual and look at the LEP pages to see if they contain the previous operators’ name… Also do a search to see if they contain evidence of COCs. If they do, it could cause you some financial (and regulatory) pain down the road!
And if you need frustration-free aircraft maintenance software to help you manage that maintenance program for your aircraft, we’d be glad to help.