The Professional Aviation Safety Specialists, AFL-CIO (PASS) represents 11,000 Federal Aviation Administration (FAA) employees, including approximately 2,900 Flight Standards field aviation safety inspectors located in 109 field offices in the United States including eight international field offices. FAA inspectors are responsible for certification, education, oversight, surveillance and enforcement of the entire aviation system, including air operator and air carrier certificates, repair station certificates, aircraft airworthiness, pilots, mechanics, flight instructors and designees.

FAA aviation safety inspectors responsible for overseeing the certification of and the work performed at foreign repair stations have serious concerns regarding the oversight of these facilities. Whereas much of this work was once done at the air carrier’s facility, according to the IG, major air carriers outsourced an average of 64 percent of their maintenance expenses in 2007, compared to 37 percent in 1996. [1] For the most recent report, the IG reviewed nine major air carriers. These carriers sent 71 percent of their heavy airframe maintenance checks—including performing complete teardowns of aircraft—to repair stations in 2007, up from 34 percent in 2003. Foreign repair stations performed 27 percent of outsourced heavy maintenance checks for these nine air carriers in 2007, up from 21 percent in 2003.[2]

FAA inspectors at international field offices (IFOs) are charged with certifying foreign repair stations and then recertifying them approximately every two years. FAA inspectors at certificate management offices (CMOs) in this country provide oversight of the maintenance work performed on their assigned air carriers at FAA-certificated foreign repair stations. However, many inspectors say that they are not confident with the level of oversight of FAA-certificated foreign repair stations and that serious safety issues are not being addressed.

There is also considerable concern over the regulations governing foreign repair stations. For example, as opposed to domestic airline or repair station employees, workers at contract foreign repair stations are not required to pass drug and alcohol tests. In addition, criminal background checks are not required at foreign repair stations. There also continues to be major concerns regarding security at these facilities, with many of the repair stations lacking any security standards. If a foreign repair station wants to work on U.S.-registered aircraft or any aircraft that operate in this country, those repair stations should be required to meet the same safety standards as domestic repair stations.

Another concern is that the FAA continues to expand the use of bilateral agreements with foreign countries to oversee repair of U.S. carriers. The Bilateral Aviation Safety Agreement (BASA) with Maintenance Implementation Procedures (MIPs) allows foreign authorities to provide oversight of the work performed at FAA-certificated foreign repair stations. According to the IG, however, foreign authorities do not provide the FAA with sufficient information on what was inspected, the problems discovered and how these problems were addressed. The IG cited an example in which FAA inspectors for one air carrier had not visited a major foreign engine repair facility even though the repair station had performed maintenance on 39 (74 percent) of the 53 engines repaired for the air carrier. Furthermore, FAA inspectors had not conducted any spot inspections of this facility in five years.[3]

Congressional Action Requested

PASS supports the inclusion of language in Section 303 of the FAA Reauthorization Act of 2009 (H.R. 915) mandating that all certificated foreign repair stations must be inspected at least twice a year by an FAA inspector and that all workers working on U.S. aircraft at foreign repair stations be drug and alcohol tested. PASS does not support Section 521 of the FAA Air Transportation Modernization and Safety Act (S. 1451), which exempts FAA-certificated foreign repair stations in countries with bilateral aviation safety agreements from twice annual inspections and restricts drug and alcohol testing of workers to countries that recognize such testing.