[sampling of the AA facilities under the DOM]
One of five positions defined by FARs
DOM command of regulations and of the AMT real world
Now must be able to deal with Compliance, Collaboration–SMS
Friday, November 30, 2018, 1:00 PM
Ft. Worth, TX
“There are five key positions essential for any airline to operate as required by the Federal Aviation Administration’s Code of Federal Regulations: Chief Pilot, Director of Operations, Director of Safety, Chief Inspector and Director of Maintenance. On Nov. 13, Evita “Evie” Garces, Managing Director of Maintenance Operations Control at American Airlines, was named the company’s new FAA-certificated Director of Maintenance (DOM). As the first female and the first Latina team member to occupy this position, American is making history as it upholds its commitment to diversity.”
That is not just typical PR hyperbole. Ms. Garces’ job description is not just some words written by the AA HR department. Her qualifications and duties are prescribed in 14 CFR §§119.65 (a), (d) and 119.67(c); the FARs do not establish minimum standards for the Chairman, the CEO, the President or even the Chief Operating Officer. Part 119 set criteria for the Chief Pilot, the Chief Inspector, the Director of Operations, the Director of Safety and the DOM. Those are the five positions which the FAA relies upon for the safety of a Part 121 or Part 135 carrier. If something goes wrong, the FAA will begin its review with these five positions.
Here is what the FARs expect of the DOM:
- 119.65 Management personnel required for operations conducted under part 121 of this chapter.
(a) Each certificate holder must have sufficient qualified management and technical personnel to ensure the highest degree of safety in its operations. The certificate holder must have qualified personnel serving full-time in the following or equivalent positions:
(1) Director of Safety.
(2) Director of Operations.
(3) Chief Pilot.
(4) Director of Maintenance.
(5) Chief Inspector.
(d) The individuals who serve in the positions required or approved under paragraph (a) or (b) of this section and anyone in a position to exercise control over operations conducted under the operating certificate must—
(1) Be qualified through training, experience, and expertise;
(2) To the extent of their responsibilities, have a full understanding of the following materials with respect to the certificate holder’s operation—
(i) Aviation safety standards and safe operating practices;
(ii) 14 CFR Chapter I (Federal Aviation Regulations);
(iii) The certificate holder’s operations specifications;
(iv) All appropriate maintenance and airworthiness requirements of this chapter (e.g., parts 1, 21, 23, 25, 43, 45, 47, 65, 91, and 121 of this chapter); and
(v) The manual required by §121.133 of this chapter; and
(3) Discharge their duties to meet applicable legal requirements and to maintain safe operations.
(e) Each certificate holder must:
(1) State in the general policy provisions of the manual required by §121.133 of this chapter, the duties, responsibilities, and authority of personnel required under paragraph (a) of this section;
(2) List in the manual the names and business addresses of the individuals assigned to those positions;
- 119.67 Management personnel: Qualifications for operations conducted under part 121 of this chapter.
(c) To serve as Director of Maintenance under §119.65(a) a person must—
(1) Hold a mechanic certificate with airframe and powerplant ratings;
(2) Have 1 year of experience in a position responsible for returning airplanes to service;
(3) Have at least 1 year of experience in a supervisory capacity under either paragraph (c)(4)(i) or (c)(4)(ii) of this section maintaining the same category and class of airplane as the certificate holder uses; and
(4) Have 3 years’ experience within the past 6 years in one or a combination of the following—
(i) Maintaining large airplanes with 10 or more passenger seats, including at the time of appointment as Director of Maintenance, experience in maintaining the same category and class of airplane as the certificate holder uses; or
(ii) Repairing airplanes in a certificated airframe repair station that is rated to maintain airplanes in the same category and class of airplane as the certificate holder uses.
Ms. Garces’ work experience more than meets these regulatory mandates:
With a strong background in aircraft maintenance, Evie has made a name for herself in an otherwise male-dominated arena. She started her career on the aircraft maintenance track, earning her Airframe and Powerplant (A&P) license to eventually become an Aviation Maintenance Technician. She has continued to work her way up within the company, serving in various positions, including Manager of Aircraft Maintenance and Managing Director of Line Maintenance. Prior to her current position, she served as the Managing Director of Maintenance Planning — Base and Strategic. It was in this position that Evie led the efforts around Base Maintenance operations, including the launch of several successful initiatives such as domestic satellite Wi-Fi modifications and Boeing 737 cabin retrofits.
American’s announcement of Ms. Garces’ new responsibilities are written in traditional airline jargon, with little acknowledgement of the new FAA-Airline Compliance regime:
As the new DOM, Evie is responsible for ensuring that all work on the airline’s aircraft is performed in accordance with Federal Aviation Regulations (FARs); staying up to date on, and maintaining access to, all FARs; and serving as the main maintenance liaison between the FAA and American. She and her team also oversee the day-to-day technical operations of American, which includes oversight of aircraft maintenance, vendor operations in more than 150 cities, ownership of the aircraft maintenance deferral process and the management of out-of-service aircraft.
. Geographically, she and her team have a broad span of management including:
Alliance (Fort Worth) The Alliance Maintenance Base serves as the fleet base and modification work center for the B767-300 and B777 aircrafts. It is also home of the Texas Aero Engine Service LLC (TAESL) repair facility, a joint venture with Rolls Royce for engine repair.
Tulsa The Tulsa Maintenance Base serves as the main headquarters for Maintenance and Engineering division. Maintenance work performed at the facility includes:
• All work on the MD-80, B757, A300 and B737 • Overhaul the Pratt and Whitney JT-8 and General Electric CF6-80 engines • Wheel and brake overhaul faculties • Composite repair center
Line Maintenance Line Maintenance includes all non-base maintenance employees (approximately 4,500 people) that perform scheduled and routine maintenance and provide operation support.
Her team must respond on a real time basis to requests for interpretations of FARs, ADs, etc. The requests require the application of the one-size-fits-all FARs to the unforgiving, time-pressured and complicated real world. Answers must both meet the requirements of the letter of the law and the capabilities of the AMTs to perform PLUS the quintessential safety requirements.
What is new and different about Ms. Garces’ job is the challenge of the FAA’s new compliance philosophy. Collaboration and cooperation demand a new skill set. Knowledge and persuasion now are paramount assets. The premise of ASIAS/FOQA/VDRP/ASAP/SMS etc. is the disclosure by the airline of errors and then working with the regulator to devise solution.
The Meta Data of this program compels AA and the FAA to have expert grasp of statistics while at the same time, both parties must have excellent familiarity with the context of the risk. The working conditions, weather, describability of the MX procedures, the repeatability of the remedial actions and the capacity of the AMTs to complete the recommended actions have bearing on the SMS recommendations.
AA’s new DOM appears to have the relevant experience and her command of the FARs should help to reduce risks through Cooperation and Collaboration.
It is well known that the management-labor relationships in AA MX’s organization has been stressed. Perhaps as a consequence of that friction, the OIG is investigating the current conditions and safety adherence. Those challenges will be part of Ms. Garces daily agenda.
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