The FAA and Allegiant have been having problems for a while over the important issue of whether the carrier is meeting the requirements of the Federal Aviation Regulations. These issues may be parallel to and/or because of the airlines’ contentious labor relationships. The most recent example of this on-going dialogue, or is it debate, is three incidents in which it is alleged the company is responsible for unsecured fasteners in the MD-80’s tail elevators.
Should the FAA throw a red flag and issue a penalty or should it show a white flag symbolic of trying to find a win/win solution?
For decades, the FAA used a system of heavy civil penalties to enforce that airlines compliance with the safety requirements of the Federal Aviation Regulations. The announcement of a seven figure sanction was sure to create a big headline about the FAA cracking down on an airline’s lack of safety.
In fact, when one Flight Standards District Office was alleged to have been too soft in its efforts, the House Transportation & Infrastructure Committee in 2006 excoriated FAA management for being too soft or not aggressive enough. One of the Representatives equated the agency’s job function to be like a “traffic cop writing tickets.”
That hearing greatly reinforced the confrontational and punitive attitudes of the FAA flight safety teams in the field.
In the last few years, FAA senior management has adopted Safety Management Systems as its primary tool for assuring passenger safety. That innovative process relies on masses of data which advanced analytics (cybermetrics) search for statistically relevant statistics. Based on those trend lines, the team creates an agenda of what should be addressed in a preventative basis. Every carrier is now required to be implementing that system.
One of the principles of SMS is that the airline and the FAA will work collaboratively to develop a solution.
Several FAA executives and finally the Administrator have issued statements and then a formal policy which deemphasizes the punitive element of FAR enforcement and shifts the focus to compliance. It is such an institutional, attitudinal shift that the structure of the lawyers was changed to assure implementation.
So, this major new philosophy raises two obvious questions:
- What is the problem which needs to be fixed?
- What is the most effective means to implementing a solution?
The failure to adequately secure the fasteners of the tail elevator suggests several alternative and/or collective issues:
- When and where were these installations performed?
- Are the handbook and/or work card instructions wrong or unclear?
- Were the proper parts used for this installation?
- Are the shop tools the ones needed for this work?
- Were the Mx AMTs adequately trained?
- Did the AMTs assigned to install these fasteners complete the work in compliance with the manual/work cards?
- Did the manual/work cards include inspection of these installations?
- Was that inspection work performed on these three installations?
- Were the personnel assigned to install and inspect these fasteners the same or were different employees tasked with this work on the three aircraft?
- Is it possible that the fasteners loosened during normal or unusual flight operations?
These are questions for which the right answers must be determined NOW.
A focused safety audit would add new FAA Aviation Safety Inspectors to watch everything which Allegiant’s maintenance is doing. The arrival of such a team will delay rather than expedite the define the precise problem(s) for these bad installations. In fact, bringing in more ASIs will divert the airline from producing adequate inspection of its other Mx work.
On the other hand, placing these three incidents into a formal SMS process and working collaboratively will expedite the implementation of corrections will stop repetition of the past’s problems. Bringing management, labor, other internal relevant perspectives (training, parts purchasing, technical publications, personnel, QA/QC) and the FAA together now and getting their collective expert opinions increase safety now. PLUS (hopefully), this experience will pay benefits for future SMS work together.
Throwing a red flag of civil penalties will be more visible. Offering the white flag of resolution is the best path to safety as soon as possible and beyond.