Doug Dalbey, Chief Compliance Officer, MRO Holdings

Fast 5: MRO Holdings’ Approach To Safety Improvements Across Its Network

Doug Dalbey, MRO Holdings’ chief compliance officer, on how the relatively new company oversees safety and regulatory compliance at its facilities in the U.S., San Salvador and Mexico.

As MRO Holdings’ compliance officer, how do you oversee Flightstar Aircraft Services, Aeroman and TechOps Mexico and how that all works?

First and foremost, the question has always been, are we going to standardize everything? And the answer has always been no; we’re not about standardization. We’re not about taking away the individual identity because each facility has such a strong brand of its own. It doesn’t make sense. For instance, Google was just bought out, and I couldn’t tell you who bought them because Google is still Google. My title is chief compliance officer, but I feel more like a chief facilitating officer. Each of the facilities has very engaging employees and a really strong brand. The philosophy has really been to look at their safety and quality systems and try to harmonize and align those as much as possible, but not standardize. They each have different regulatory authorities. The officials in El Salvador, Mexico and the FAA look for different things, and each of the facilities has a safety management system. There are differences in them because of their own government regulations, so one of the things that we’re trying to do is to look at the best practices, and again, not standardize, but go in and find the best parts of each safety management system and tweak all three at the same time to align them as much as possible.

This entails a lot of workshops and reviewing procedures—looking at a particular area where all three of them are having some opportunities for improvement. We recently held a workshop where we actually invited one of our key customers, who sat in and participated in the workshop, so that’s what’s meant by trying to partner with our customers, and to bring them in and be transparent. My job is really to find those people that want to work on key issues—any of the weaknesses in the system—by looking at the other two facilities to figure out, “How do they handle this at their facility? And how do we go about integrating those things, while at the same time making sure we don’t have consequences by introducing something into a system that’s not going to be harmful to it?”

Going back to the workshop that you recently held with one of your customers, can you give me an example of what you go over during the workshop and maybe an example of something you might change?

I think I can speak in generalities on that. Each of the three repair stations brought a couple of case studies of a particular issue we were looking at and our operator brought a case study. We drilled into that—to look at the adequacy of the investigation that was performed—because we found that they all had different tools that they use during the investigating process. They all use slightly different root cause analysis processes, and in many cases, their corrective actions and preventive actions may not be drilling deep enough to find all of the root causes and try to correct those. The carrier—the client that came with us—I think had the same revelations as everybody else did, because we asked questions much deeper than you would on a normal investigation. We looked back at some of the organizational influences that might be in place that one would not normally connect to the root cause, such as training, stress that’s induced on the hangar floor, or just the way communications take place. Each of the three facilities have very different cultures, so we were very sensitive to that. We’re all human and it could still be something that is drawn out when you’re asking more questions in front of a crowd, and your peers are there asking questions such as, “How did you handle this?” “How did you look for that?” and, “What kind of action was taken?” Sometimes there’s a fine line between a true error that’s performed on the hangar floor versus a violation where an individual does something outside the process for one reason or another.

So really, it’s a matter of looking at the procedures, but also at human factors? 

Exactly, because sometimes procedures can’t be followed. In many cases procedures are written by engineers who have never spent one hour on the floor doing an actual maintenance task. Through peer pressure, or some other factor, the technicians will work around a bad procedure to get the job done because their peers have worked around that procedure for years without asking a question, and for peer pressure’s sake, they’ll continue to work around that procedure or process.

One thing we haven’t really drilled down to as much as we should is the human factors part of that, because it’s pretty easy to take the written word and bounce that against the other two facilities and find out, for instance, how somebody jacks an aircraft. But the harder part is to look at that procedure and figure out how the communications actually take place when that’s happening. What precautions and what controls are implied that may not be written? How does that work? The good news is that all three facilities have people that have a passion for this field. They all want to learn. It’s really rewarding to be working with all the facilities and their different personalities and characteristics. 

Is MRO Holdings looking at how to foster the differences and the diversity?

It is. Each of the facilities has sent several people to visit the other facilities. It’s kind of a familiarization; it’s been throughout the whole organization. One thing we’ve been trying to do is slowly integrate administrative functions, such as the commercial aspect, the supply chain, IT and finance, so there have been several trips trying to learn from each other’s systems, especially since they all have different IT and automation programs that are doing different things. We’re trying to figure out if one is better than the other—is one technique better than the other?

Are there other best practices in the safety and quality realm you’re exploring for the group?

We’re striving to get better in every way. For instance, when we look at the safety of our employees, even though neither Mexico nor San Salvador have oversight from the OSHA (U.S. Occupational Safety and Health Administration), the performance indicators that we’re establishing are OSHA-driven, so we can compare apples to apples. We want to know how our employees are being protected. We’re always looking for any kind of safety intervention, whether it be part of their protective personnel equipment or their uniform, we’re looking at all aspects to make sure that the employee is as safe as they could possibly be. From the quality aspect, I just have to say that’s all about the workshops that we’re doing and how we’re really trying to find the best practices and see if they can be carried over to the other facilities. That’s what it’s all about. We have some of the smartest individuals in the business—it doesn’t make sense to go outside when the people that know how to solve these things are already working on the premises. It’s about asking employees to come forward with any issues, whether it be anonymously or through any one of our voluntary programs. We want to know if there are processes that can’t be followed or if we don’t have proper tools or anything like that. It’s really about trying to show the workforce how transparent we are.

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