Back Shop: Industry Insights

There is an active, yet unspoken, conspiracy against airline and charter safety in America. This conspiracy involves pilots, air carrier management and the FAA inspector corps. In the safety audit business, the common term for this is "Shirt-Pocket Maintenance." It’s relatively easy to spot and contrary to every operator’s ops specs. Although the FAA is aware of the practice, no pilot has been held in violation.

This is also a conspiracy against the aviation maintenance profession in that it allows airlines to eliminate maintenance staffing at outlying overnight stations. It involves flight crews’ failure to enter maintenance discrepancies in the journey log at non-maintenance stations or on through trips. By noting the problems on a piece of scrap paper for later log entry, they maintain short turnaround times, thus keeping to the schedule. The scrap paper is kept in their shirt pocket, for later transcription, which leaves the typical situation of an overnight maintenance crew that has to correct eight or nine fresh write ups, without time to get the required parts, where none of the write ups were deferred earlier.

There are several problems with this procedure, the foremost being that they then dispatch the aircraft with known unairworthy items, a clear violation of their safety obligations. Although this is why the MELs were developed, deferring an item takes time and time is the enemy of schedule. Parts could be at the ready if the items were deferred in a timely manner, but not if the supply chain is surprised on the last flight of the day.

Air carrier management applies subtle pressure on pilots to join with them in the conspiracy, by requiring delay reports, yet never admonishing them for "delayed log write ups." The pilots don’t tend to write up items that the MEL says they can fly without. They don’t follow the MEL procedures, but that’s just a technicality. If it’s not written up, who can prove it?

The FAA can prove it if they want to, quite easily. All one has to do is check the write ups for each leg. If all or even most of the write ups occur on the last (homeward) leg, that is the basis for a violation. Assuming that no items were deferred at intermediate stops, this type of delayed log entry is difficult to defend in front of an administrative law judge, who is empowered to use logic as well as the regulations in reaching a determination.

When shirt-pocket maintenance is brought to the attention of air carrier management, it should be through the carrier’s safety management system. The problem for mechanics who work for air carriers that condone this practice is that they, not the pilots, are held responsible for any subsequent system failures that result from the lack of pilot write ups.

It is high time that air carrier mechanics stood up for themselves in the face of the safety hazards endemic to shirt-pocket maintenance. Report any instance of this to the company’s safety committee and get mechanics actively represented on that committee. If the safety committee does not take a proactive approach, the next step is to notify the local FSDO that the safety committee is not functioning properly and is ignoring safety hazards.

I know you’re thinking that this is an extreme recommendation, but any safety problem is of vital interest to the FAA and you will not be discriminated against for going outside when your carrier’s safety management system is dysfunctional. In fact, that is written into the preface for the program. If the FSDO does not act, you have the FAA hot line as a last resort.

The players in this activity are the pilots, air carrier management and FAA safety inspectors (by default) on one side and mechanics on the other. If you think that’s lopsided, you’re right. As a mechanic, you have a HUGE advantage. The ops specs are on your side, as are the regulations and public opinion. Use that to your advantage. Give your company a chance to address the problems first, and only then seek relief from the FAA. The fact that shirt-pocket maintenance isn’t on their radar doesn’t mean that they won’t fully investigate your complaint. They are legally obligated to. To top it off, federal whistle-blower laws protect you from recriminations for reporting the problems. You could also be entitled to a percentage of the FAA fines if it comes to that.

If you are an FAA air carrier airworthiness inspector, check the logbook on your next ramp inspection for evidence of shirt-pocket maintenance. I’ll guarantee that at least 75 percent of all pilot write ups take place on the last flight of the day or on the pilot’s last flight leg on that aircraft.

If you’re a mechanic working for an air carrier, you should be aware that AM is read by a lot of FAA inspectors as well. You might be seeing a few spot checks during overnight layovers. Help out if you can. Remember, they’re mechanics as well, just not used to being up late.