AIR CARRIERS MUST USE CERTIFICATED REPAIR FACILITIES

The Professional Aviation Safety Specialists, AFL-CIO (PASS) represents approximately 2,800 Flight Standards field aviation safety inspectors[1] and 132 Manufacturing Inspection District Office (MIDO) aviation safety inspectors. Federal Aviation Administration (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.

In recent years, the overall dynamic of the aviation industry has experienced dramatic changes. One such change is airlines increasing their reliance on outsourced maintenance work. According to a Department of Transportation Inspector General (IG) report, air carriers’ use of outsourced repair stations has grown from 37 percent of air carriers’ maintenance costs in 1996 to 64 percent during the first three quarters of 2006.[2]

“Non-certificated” means that the repair facility does not possess a certificate issued by the FAA to operate under Federal Aviation Regulation Part 145 and is therefore not subject to direct FAA oversight. A certificated repair station meets the standards as outlined in the Federal Aviation Regulation and is therefore subject to direct FAA oversight to ensure that it continues to meet those same standards. The differences in regulatory requirements and standards at the two facilities are extremely troubling. For example, in an FAA-certificated repair station, it is required that there be designated supervisors and inspectors and a training program. These items are not required at non-certificated repair facilities.

Effective oversight of non-certificated repair facilities gained attention in the aftermath of the January 2003 Air Midwest crash in Charlotte, N.C. The National Transportation Safety Board determined that incorrect rigging of the elevator system by a contractor contributed to the accident and pointed to “lack of oversight” by Air Midwest and the FAA.[3] The airline contracted out the work to an FAA-certificated repair station, which then subcontracted to a non-certificated repair facility. Under federal regulations, the airline is ultimately responsible for ensuring that the work is performed in accordance with standards and requirements.

According to the IG, the FAA does not know how many non-certificated maintenance facilities air carriers currently use, but the IG identified “over 1,400 non-certificated repair facilities performing maintenance and more than 100 of these facilities were located in foreign countries.”3 The IG also discovered that there are no limitations to the amount of maintenance work non-certificated facilities can provide, and that these facilities are performing far more work than minor services, including much of the same type of work FAA-certificated repair stations perform, such as repairing parts used to measure airspeed, removing and replacing jet engines, and replacing flight control motors. Some of these non-certificated facilities are even performing critical preventative maintenance.

Despite the fact that these facilities are performing safety-critical work, FAA oversight is practically nonexistent. In other words, these facilities are performing work pivotal to aviation safety with no guarantee that it is being done in line with FAA and air carrier standards. It is obvious that there must be modifications made regarding air carriers’ use of non-certificated repair facilities.

Congressional action requested:

The House FAA reauthorization bill (H.R. 2881) includes language requiring that within three years all air carrier maintenance work (substantial, regularly scheduled or required inspection items) only be performed by a certificated repair facility. PASS supports this language and would like to see similar language included in the Senate version of the bill (S. 1300).