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Saturday, July 1, 2006

Are Contract Maintenance Workers Safe?

Bart Crotty

First starting in the late 1970s in Western Europe and particularly in the United Kingdom (UK), maintenance-repair-overhaul organizations (MROs), both airlines and separate third-party companies, hired workers for short or medium periods of employment. Over the past years this practice has spread across the ocean to North America and especially to the U.S. This was seen as a way out of the problem of supporting increased work, such as aircraft modifications, cargo conversions, heavy maintenance checks or structural repairs. High on the list of these early kinds of workers has been the sheet metal and structural repairman, as well as cabin interior, electrical, wiring and painting specialists.

There are no hard statistics available concerning the global or regional use of maintenance contract workers. It is estimated that about three-fourths of the present contract workers have previously been employed full-time in aviation, but due to down-sizing, mergers, and involuntary layoffs they are content or forced to travel around working periods of less than a year or so. Many do so living in trailers or campers some-times set up in MRO parking lots. Some workers have moved away from and back and forth to military aviation maintenance jobs and allied trade industries, e.g. residential construction/modernizing and home servicing or auto repair. In this way, they can earn enough money to get by on and may choose to occasionally work MRO contracts at their leisure. In a large sense, they are viewed by permanent regular company employees as gypsy-like, drifting workers.

Employment Agencies

Typical employment agencies focusing on providing workers with aviation technical or trade skills are one of two sources from which MROs draw their contract workers. Although the agencies vary in their services to MROs in the degree of verifying a workers' past employment, work experience and personal histories, some agencies in the European Union (EU) are now reported to offer extensive background searches of prospective employees. In the U.S. around the period of 1960-1980, technical employment agencies provided large pools of aeronautical engineers, designer, draftsmen, etc. for fixed contract periods when the civilian and military aircraft industry was experiencing phenomenal growth. The agencies were then referred to as "body shops" in that they provided bodies for hire.

Specialized labor contractor agencies are the other source of providing maintenance workers to MROs. In this situation, a group of workers are furnished to perform project work or specific undertakings like passenger to cargo conversions, extensive airframe modifications, service bulletin incorporation or extensive airframe/structural airworthiness directive accomplishments. The MRO accepts the group of workers as a whole and usually doesn't pick or choose individual workers as they would with a reputable traditional employment agency. The labor contract has no organizational approval or certification status from civil aviation authorities, although workers could hold individual issued maintenance licenses.

Employers certainly don't look forward to spending a lot of time and money to screen, test, select, train, integrate, and closely monitor or supervise personnel who will be with them a relative short period of time. In theory, the contract workers are supposed to be highly skilled in their respective aviation trades, but this is not always the case. They possibly bring bad habits to MROs, such as sloppy workmanship, into a smooth functioning workforce of regular permanent staff, thus making the job of assigning additional supervision (for an MRO most likely already laboring shorthanded under full production) a double burden. In fact, until the new hired contract person is checked-out or vetted by an MRO, the employer has to, or should, pair the contract worker with a regular employee, and this may have to be a permanent safeguard if a worker's output quality is poor or marginal.

Uncertain Tenure

Contract workers generally cannot count on future return employment because of the vagaries of airline economics, maintenance schedule interval cycles and MRO questionable survival in a very competitive market. Probably, and again the writer's estimate, the chances of an employer ever hiring the same contract worker are less than 25 percent. And those workers reemployed would be the "creme de la cr�me" of workers and they would be in demand by other MROs as well.

However, for the rest of these temporary workers the incentive to do good or very good work is not always present and some poor quality work might not be identified until several months or years after the worker has departed. This is not to say most contractors are less than satisfactory workers. It's a question of how long it takes the MRO to determine the product quality of an unknown worker in a relative short time under less than ideal conditions.

Understandably, there is usually little camaraderie between the MRO regular employee and contract workers, and in situations where there is company union representation it makes matters worse. Contract workers usually don't have to join a union and are usually paid more than regular staff because they don't contribute to fringe packages or receive employment benefits. They usually work longer daily or weekly hours since there are no union restrictions and their overtime pay rate may be less than regular workers thereby saving the MROs some expenses, overtime work and extra pay denied regular workers.

MRO regular workers are in large part protected by union status can voice their views on workplace safety conditions, questionable maintenance being performed or refusal to sign off for jobs not done, according to Robert Roach, vice president of the International Association of Machinists (IAM) union. Roach makes another insightful comment in saying, "Congress can pass laws and the FAA can issue regulations, but unless the front-line mechanic isn't afraid to object when management puts profits before safety, they are meaningless." The average contract worker would have to very courageous or self- destructive to "blow the whistle" and complain about similar MRO situations or conditions.

Full-time regular maintenance workers of some MROs can also be employed moonlighting part-time by airlines operating in the locale of the MRO, or vice versa, and they are often engaged to work on their days off or, say, a half shift of four hours or less. They would have none of the drawbacks of the short-term itinerant worker but the big question of fatigue and stress obviously looms large with safety performance levels threatened. Civil aviation regulations do not yet specifically prohibit this practice, and although it is not thought to be widespread, it does still exist.

Time of Duty

U.S. Federal Aviation Regulation (FAR) 121.377 requires air carriers, or those (repair stations) that perform maintenance for the carriers, to relieve maintenance personnel from duty for a period of at least 24 consecutive hours during any seven consecutive days, or the equivalent thereof within one calendar month. Surprisingly, FAR 135, which applies to commuter and on demand operators, does not require them to periodically relieve their maintenance personnel from duty.

In Europe, aviation worker unions and interest groups have been lobbying civil aviation authorities for several years to restrict the number of hours maintenance workers are allowed to remain on the job. The EU has published a Working Time Directive that prescribes industrial working hours, including those for night shifts. Up until now, aircraft maintenance and engineering staff and other ground personnel in the air transport industry have been exempt from its provisions, but this changed on August 1, 2003, when the directive was implemented.

Just one example of misuse or overuse of contract workers occurred at a repair station in the U.S. in the 1990s during the push to complete a non U.S. registered VIP wide-body aircraft heavy maintenance check that had fallen seriously behind schedule. Quite a number of contract workers were added to the aircraft and they worked 12-hour shifts for six weeks without any days off. Many were viewed by the operator's on-site representative as "walking zombies" due to the resulting fatigue and amount of work having to be redone because of poor quality.

The UK Civil Aviation Authority (CAA) Safety Regulation Group in March 2003 issued CAA Paper 2002/06, Working Hours of Aircraft Maintenance Personnel. This 80-page research report presented recommendations on various aspects of worker health, sleep, fatigue, working hours and safety in the form of good practices. It will take some time until industry studies this report, and hopefully reacts in a positive way by piecemeal implementation of the good practices recommended, and assessing their results.

Civil aviation authorities, at the present, do not officially discriminate against the use of contract workers. The UK CAA and U.S. FAA have no written requirements, restrictions or formal advisory material on the subject. Some UK CAA individual surveyors have sent correspondence to various MROs on the matter of being cautious in employing contract workers, especially concerning their breath and depth of experience. This writer is not aware of any government special programs or monitoring techniques for collecting data or analyzing the impact of the spreading use of contract maintenance workers.

Depending on local national regulations, unless a contract worker possesses a suitable national license, then his work must be signed for or approved by an authorized/qualified regular staff worker. Here again, this is the making of more administrative work and loading up supervision and quality inspection for a company already experiencing a heavy and most often multi-shift operation that might involve work not previously performed by the MRO. Penalty clauses for late delivery of customer aircraft coming out of maintenance can and do add other pressures and stresses for a company already operating at its peak workload. All these factors taken together challenge even the best run MROs and certainly could overextend the management of mediocre organizations.

MROs operating under EU joint aviation requirements and UK CAA approval must have written policies and procedures covering company issued authorizations to individuals for approving maintenance work. Many MROs have a minimum time of employment with the MRO (usually six months or more) besides training and experience requirements. This safeguard would seem to restrict many contract workers from having a significant level of approval in deciding airworthy matters-a good restriction, one might say.


Another troubling matter is the number of maintenance workers, regular or contracted, licensed or not, that a first level supervisor (foreman, etc.) can reasonably be expected to oversee. Considering work performed in the hangar or on the line, until 10 years ago the number was generally considered to be about five. Whereas in component shops the number could be as high as 10 since the workers were usually always in sight or in close contract with the supervisor. However, in recent times of cost cutting and tighter economies, when considering hangar or line maintenance in some operations, the number has grown to eight or more. A former UK aviation employee stated that 15 was the high water mark at one UK MRO a few years ago, until the UK CAA pressured the MRO to considerably reduce the number.

The International Civil Aviation Organization (ICAO) annexes covering aircraft maintenance standards and recommended practices do not address this issue of maximum numbers of workers to be overseen or supervised, nor do the major civil aviation authorities. With the growth of the use of contract workers, that situation would necessitate closer supervision than regular workers and with the absence of firm civil regulation, many MROs may not meet the challenge of increased supervision. The resulting consequences would in most cases lead to an increased degradation of quality and safety.

Briefly looking at the lighter side of the issues involved, it would not be surprising if a new industry term of "fourth-party" maintenance were coined to describe or refer to the heavy use of contract maintenance workers. The term third-party is widely used and understood to mean work performed by those MROs other than an airline or the operator of an aircraft.

An egregious example of how bad things can get is the case of the US Airways/Air Midwest fatal crash of a Beech/Raytheon 1900D at Charlotte, N.C., on March 16, 2003. The flight, US Airways 5481, was being operated by Air Midwest, who had contracted scheduled overnight maintenance to Raytheon Aerospace, who then contracted to a Florida company named SMART to provide maintenance workers who improperly rigged the elevator control cable, directly contributed to the accident. There were several violations of maintenance regulations concerning this work, to say nothing of the FAA being clueless about these convoluted contracted arrangements for maintenance.

Unless a prospective employer establishes written policies, procedures, and standards for engaging and managing contract workers, it is near impossible to adequately manage and ensure that quality and ultimately safety will be maintained at an acceptable level.

New or expanded MRO management functions or provisions at a minimum should cover the following:

  • Choose to deal with only a few established, reputable employment agencies.
  • Decide what pre-employment screening requirements/steps will be assigned to the employment agencies and what will be done in-house, i.e., verifying work employment and experience histories, criminal/character checks, knowledge/skill and/or written/oral tests, etc.
  • Establish efforts to explain to and desensitize regular worker regarding conditions/terms of employment of contracted workers, thereby reducing resentment.
  • Provide company training covering indoctrination/familiarization/workplace safety and type/equipment. Be mindful of all possible outside employment of workers.
  • Set probation periods, initial and continued supervision requirements, pairing of workers, etc.
  • Establish training of supervisors in new or modified methods of handling contract worker quality/safety issues.
  • Set realistic contract work output expectations or learning curve related production targets.
  • Limit the number of contract workers within groups to be supervised.
  • Establish periodic management/project/meetings reviews of maintenance performed by contract workers.

    Civil aviation authorities should establish or expand their knowledge and databases in order to quantify the dimensions of changing business practices and worker demographics regarding aircraft maintenance personnel.

    Employment of temporary maintenance workers can be properly handled only with the realization and full commitment of MRO management of the necessity for additional planning, training, supervision and support services and a realistic expectation of worker output or accomplishment.

    About the writer:

    Bart Crotty is an airworthiness, maintenance and safety consultant, and the maintenance human factors chairman for the International Society of Air Safety Investigators. He's a former FAA airworthiness inspector. He has worked for repair stations, airlines, aircraft manufacturers, safety organizations and several foreign civil aviation authorities.

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