Layers of Maintenance Outsourcing, Use of Subcontractors Difficult to Track

Air Safety Week, Jan 30, 2006

Beyond all the publicity around a recent government audit about the lack of oversight by the Federal Aviation Administration (FAA) and airlines of non- certificated aircraft repair stations (Air Safety Week, Jan. 2), there are some important side issues in aviation repair work that have received less attention than they should, according to several safety experts and union officials.

One involves keeping up with quality control through multiple levels of outsourcing, such as when an airline engages a contractor to work on an engine, who in turn signs up a subcontractor to work on one part of the engine.

Another involves a 2003 law calling for the monitoring of foreign repair stations for security purposes, a task which federal officials have not yet started, according to the AFL-CIO (details in an upcoming Air Safety Week).

The government audit in December was actually the work of the Department of Transportation Inspector General's (DOT/IG) office, which noted that when an airline contracts its repair work out to another maintenance facility, that repair facility, whether certificated or not, becomes an extension of the airline's maintenance issue. Moreover, it is up to the FAA to ensure that the airlines have some way of monitoring the repair work.

But when there are multiple levels of outsourcing, monitoring gets complicated. Linda Goodrich, vice president for flight standards with the Professional Airways System Specialists (PASS), the union representing FAA safety inspectors, says that it's easy to lose track of how many times a particular repair function gets subcontracted out. In this one respect, DOT/IG only hit the "tip of the iceberg."

One recent example of the ill-effects of multiple layers of outsourcing, Goodrich says, is illustrated by the Jan. 8, 2003, accident involving Air Midwest flight 5481, a Raytheon (Beechcraft) 1900D, N233YV (Air Safety Week, April 18, 2005). The aircraft crashed shortly after takeoff from Charlotte- Douglas International Airport (CLT), killing two crew members and 19 passengers.

In its findings from early 2004, the National Transportation Safety Board (NTSB) said that Air Midwest contracted with Raytheon Aerospace to provide quality assurance inspectors, among other maintenance personnel, for the carrier's maintenance station in Huntington, W.Va. Raytheon, in turn, contracted with Structural Modification and Repair Technicians (SMART) to supply the mechanics. One of SMART's employees made the performance errors, which contributed to the accident.

But most examples are not quite as dramatic, Goodrich tells Air Safety Week. Smaller problems also can arise from something as simple as properly cleaning a particular part. In some cases, there are a lot of specifics in the original instructions, such as what exact cleaning agent to use or how much water pressure to apply, which may not get properly passed along the chain of subcontractors.

For its part, the Air Transport Association (ATA) contends that outsourcing is perfectly safe, because all the work is supervised in accord with FAA directives, ATA spokesman David Castelveter says. Furthermore, the recent safety record of the aviation industry speaks for itself, and there is no evidence that subcontracting maintenance work is degrading safety levels, he says.

But "thousands and thousands" of repairs are performed out from under the direct supervision of a certificated facility, Goodrich says. Some subcontractors, for example, set up shop in a small truck or van.

Concurring with Goodrich's basic assessment, John Goglia, formerly an NTSB board member and now director of the Center for Integrated Emergency Management (CIEM) at St. Louis University, points out that layered subcontracting is often justified. Certain components simply need specialized expertise.

Still, FAA needs to do more, he asserts, and when it does, costs will go up. For example, a big repair shop may be in the habit of sending some parts and specialized jobs to a subcontractor that literally is "just down the road." But if that subcontractor is not FAA-certificated, the larger repair facility may be forced under stricter rules to send the work elsewhere. That may involve shipping the parts out of town.

But Marshall Filler, managing director and general counsel for the Aeronautical Repair Station Association (ARSA), which represents FAA- certificated repair stations, believes there's really not much of a problem. If there were, he contends, then the international air safety record wouldn't be as good as it has been in recent years. When there are extra layers of subcontracting, there is more work to be done to ensure that the work is done right, but ARSA has no particular concerns.

Nevertheless, Filler tells Air Safety Week that he'd like to see "better coordination" between the carriers and the independent repair stations. Federal regulations require repair stations to follow the instructions in the carriers' manuals. The airlines are the ones who should revisit their procedures for ensuring that their repair procedures and instructions get passed along, he says.