The Airlines for America (A4A) Engineering, Maintenance and Materiel Council (EMMC) made significant progress in 2015 on areas of concern for member airlines. Initiatives on guidance for airworthiness directive exception management and minimum equipment-list dispatch deviations are two examples where EMMC members worked with FAA leadership to clarify and enhance existing regulatory processes. For 2016, the EMMC has set its sights on reducing the complexity of maintenance tasks at the technician level.
When we look at the safety gains in the airline industry over the past 20 years, considerable progress has been made regarding professionalism on the flightdeck, with an intense focus on following standard operating procedures. Flight operations have done an excellent job of focusing on human factors and making sure any changes in procedures are fully vetted before incorporating them into checklists and flight manuals. This approach has shown to be a very successful method of ensuring that human factors are adequately considered.
In maintenance and engineering, our industry has tended to address significant safety issues by developing special programs. The A4A EMMC, airlines and the FAA have approached safety challenges by assembling groups of experts who develop guidance material on how to incorporate the new safety objectives into maintenance instructions. Incorporating new procedures has tended to focus on making technicians aware that they are working on something “special,” instead of focusing on standard operating practices.
One or two special programs may be manageable. However, as the number of programs has grown, technicians now face a daunting number of special programs, each with a unique slant on implementation, which leads to unique sets of training, nomenclature and emphasis. This suggests that if the majority of these tasks are special and important, the other tasks may be perceived as less important.
Maintenance task cards now read like legal documents, with cautions and warnings about all of the special programs, which implies the level of regulatory importance that the technician must be concerned about.
A typical work package can include references to programs such as AWL (airworthiness limitations), ETOPS (extended twin-engine operations), CPCP (corrosion prevention and control program), RVSM (reduced vertical separation minimum), SFAR88 (Special Federal Aviation Regulation for fuel tank system fault-tolerance evaluation requirements), FCBS (fatigue-critical baseline structure), CAT (Category II and III avionics maintenance), EWIS (electrical wiring interconnect systems), RII (required inspection items), FRM (flammability-reduction means), SSID (supplemental structural inspection document), CDCCL (critical design configuration control limitation), RAP (repair assessment program), etc. Complicating the issue, each airline works on an implementation plan for each of these programs with their individual FAA Certificate Management Office. This leads to each airline having different programs for the same objectives, creating a difficult training problem for MROs and contract maintenance providers that are required to follow each airline’s unique instructions.
The identification of each of these programs to technicians does not enhance the performance of maintenance tasks. Rather, it is critical that technicians perform the tasks as written on job cards and in aircraft maintenance manuals consistently.
We have had good discussions with FAA leaders on revisiting the implementation of special programs. A new emphasis on how human factors affect technicians must be considered. Our goal is revised guidance for each special program to ensure the focus is on technicians accomplishing every task to achieve the intent of all special programs, with less suggestion that certain tasks are more “special” than others.
The focus for development of all maintenance tasks should be on standard operating practice—to perform each task with the same diligence for compliance. By pursuing a similar strategy of “professionalism on the flightdeck,” we hope to make human factors related to maintenance tasks a primary emphasis so that technicians’ undiluted focus is on following maintenance instructions with the highest degree of professionalism.