Goglia’s AMT Fatigue needs SMS for solutions

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AMT Fatigue SMS

AMT fatigue

What former NTSB Member Goglia calls out as problems, indeed, needs to be torqued, but the man, who is expert at using tools for maintaining aircraft, may need to update his regulatory toolbox.

He understands the workload and psychological stress of being an AMT with heavy production pressure. His essay well lays out the fatigue issues of his profession. His choice of how to fix them is where he relies on old procedures.

As he notes in the article, the gestation periods of the FAA NPRM process and its Chief Counsel’s opinion are exceedingly slow. Some of the issues, which he highlighted, cannot be universally addressed; a single rule cannot deal with so many variations in the tasks. Fatigue may exist across Airline Maintenance Technicians (AMT) job descriptions, within an airline or even as to airlines with different operational profiles or geographic location or size.

Mr. Goglia also stated that the most effective regulations are specific; precise language makes compliance easier by the certificate holder as well as enforcement by the FAA. The more exact the wording of an FAR, however, makes it more difficult to apply to all potential situations under a single rule. {As guidelines for behavior, probably only the Ten Commandments are simple in statement and universal in application [even then there are many ministers/mullahs/priests/rabbis around to interpret and enforce them.]}

The hypothesis of the NTSB alumnus’ paper is that the FAA should not issue an Advisory Circular, but must issue an improved FAR, i.e. to make the very general 14 CFR§121.377 to be more specific in its mandate. In support of his position, Mr. Goglia’s article cites the following problematic fatigue examples:

  • “Of concern to [theFAA] is the finding that maintenance personnel tend to get three hours less sleep per night than is recommended. That is a sleep debt twice the national average. Sleepiness and fatigue associated with sleep debt is cumulative. This means that losing even an hour of sleep every other night over the course of a week will produce conditions that negatively affect performance.”
  • “…theFAA took the position that the phrase “or the equivalent thereof within any one calendar month” had its limits: “The equivalent standard, however, does have limits. The tenants [sic] of statutory and regulatory interpretation suggest that the specific standard of one day off every week cannot be rendered completely inoperative by the more general equivalent standard. A previous interpretation allowed that a work schedule that provides for personnel to have a group of four days off followed by up to 24 days of work, or vice versa, would still meet the standard of being ‘equivalent’ to one day off in every seven within a month… That interpretation, however, was issued prior to the findings relating fatigue to maintenance related errors in the air carrier industry… Today, we would not view as compliant a schedule that provides over the course of eight weeks for four days off followed by 48 straight days of duty followed by four more days off. Such a work schedule that generally provides for an average of one day off over several weeks cannot be said to be ‘equivalent’ to the more specific standard requiring one day off out of every seven days.”
  • Clearly, workers performing maintenance forS. airlines should be covered by the same duty and rest rules, regardless of where the work is performed. After all, it’s the safety of the aircraft after maintenance that the FAA is concerned with, not the health of maintenance workers generally. U.S. employers should not be put at a competitive disadvantage by safety rules such as this one that apply only within the U.S.
  • But as our knowledge of the effect of fatigue on human performance grows, it’s not possible to deny that long hours, day after day, without catch-up rest degrade a maintenance performer’s abilities to perform maintenance tasks properly, especially the most safety critical and complex tasks. While improperly performed maintenance could result in a crash in the worst case, improper maintenance also results in costly incidents. So, if theFAA doesn’t come up with a rule, employers should create their own workplace standards, especially since fatigue can drive up worker injuries and Workers Comp claims.

He, then, correctly points out that an AC is not mandatory (as the preamble says “This constitutes one means of compliance”)John concedes that  “the specific advice contained in draft AC 121-MFRM is “excellent information and advice that employers should use regardless of where the maintenance work is being performed.” The Goglia thesis is that the good airlines are already implementing this FAA guidance and the overworked, fatigued AMTs will continue to be at risk.

AMT fatigueThe new tool box of FAA regulations involves data-based, preventative, 3600 collaborative (i.e. unions sit at the table, among others) and risk-based process called Safety Management System. It was created to make the FAA staff more effective, to avoid the horrendous delays required to issue a new FAA and to move the focus from enforcement to positive, preventative process. All risks, to which an airline is exposed, are the subject matter for this new cooperative approach to safety. Issues are brought to the SMS team and proactive solutions are designed.

As Member Goglia’s paper describes, risks vary in a number of ways.

  • AMT fatigueFatigue is more likely for those who work rotating shifts; by being on duty in inconsistent patterns, the need for specific rest remedies may be greater.
  • Personnel whose jobs are indoors and who work regular hours may have less need to rest rules than the AMTs who work outdoors with adverse weather.

AMT fatigue

  • Work involving very exacting or strenuous tasks may need different treatment.

AMT fatigue

 

A single FAR, even a discretionary AC, may not be able to design appropriate solutions which address each of these specific, almost unique risks. SMS can, and the union participates in the deliberation, design proactive strategies for each identifies job fatigue source. Even better than any regulation, SMS provides the flexibility to respond quickly—when the data shows that the SMS is not as effective as it was projected, the continuous improvement principle will bring the issue back for refinement.

Mr. Goglia, when he was an A&P mechanic, always had the best wrench. His assessment of the need to address AMT fatigue is well stated. Today’s tool for fixing such a problem is not the 5 year NPRM process, but a finely tuned mechanism which uses all involved to find repairs for each specific safety risks.

One might suggest that the unions should assure that the statistical analytical tools capture the risk relation between fatigue and degraded MX performance. With that data the SMS team will be able to fashion remedial steps for each job for which there is risk. The science of fatigue management has recently been well researched. The SMS answers will better serve mechanics than a compound, complex 14 CFR§121.377 with multiple dependent clauses. Only lawyers will benefit from that response to this problem.

AMT fatigue

 

ARTICLE: Torqued: AC Is Not Good Substitute for Maintenance Fatigue Rule

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3 Comments on "Goglia’s AMT Fatigue needs SMS for solutions"

  1. More evidence of a broken regulatory system: “the gestation periods of the FAA NPRM process and its Chief Counsel’s opinion are exceedingly slow”.

  2. You say “The more exact the wording of an FAR, however, makes it more difficult to apply to all potential situations under a single rule” but you admit elsewhere that the FAA is not consistent because of its 100os of pages of regulations…

  3. Agreed Mr. Enders– both points were made in the post.

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