Sunday, August 1, 2004
Report From Washington
The FAA steps up concern over changes of address, and the FAA reports a significant number of positive drug and alcohol tests for maintenance workers.
By Peter Rohrbach
Certificate Protection: The FAA is now offering online services through its registry website, which provides an easy way for airmen, both mechanics and pilots, to replace their certificates if they are lost or destroyed. The address is http://registry.faa.gov, and all the necessary information is displayed there. This FAA site also offers a way to change your address, order a supplementary certificate, and obtain copies of aircraft records. FAR 65.21 requires mechanics to notify the FAA of a change of address, but the FAA has reluctantly resigned itself to the fact that over many decades a great number of mechanics fail to do this when they move and therefore the registry is filled with many incorrect addresses of mechanics. However the FAA is now taking a different tack with pilots and in June the Aircraft Registration Branch announced that it is going to begin enforcing FAR 61.60 for pilots, which requires them to notify the FAA of a change of address within 30 days or otherwise "he may not exercise the privileges of his certificate," a penalty clause not contained in the mechanic regulation. The FAA said it is also going to begin enforcement of FAR 47.45, which requires address change notification of an aircraft's registration. Thus a pilot's certificate or an aircraft registration with an incorrect address might well be suspended, said the FAA. These strict enforcement actions aimed at incorrect addresses in the registry are today driven by security concerns in the government's efforts to combat terrorism, but the way to avoid them can be easily found by logging on to the FAA's registry website.
Maintenance and Substance Abuse: In a disturbing official statement the FAA claims that maintenance workers "have demonstrated a significant history of illegal drug use and alcohol use." This statement was part of a recent notice of proposed rulemaking published in the Federal Register and it was written by the FAA's Drug Abatement Division, which presents some hard statistics derived from actual drug/alcohol tests of aviation personnel. For instance, between 1990 and 2001 there were 30,192 positive drug test results for aviation workers and 15,340 of them were "attributable to maintenance workers." And between 1995 and 2001 there were 876 alcohol violations with 423 of them from maintenance. The FAA then concludes: "Since the inception of drug and alcohol testing regulations, annual statistical data indicate that a significant number of the positive results for both drug and alcohol occur in the maintenance field."
However, those stark figures are somewhat misleading. For one, all previous studies of drug/alcohol testing showed that the positive rate for actual on-the-job mechanics was well under 5 percent, far less than the approximately 50 percent indicated here. In response, the Drug Abatement Division admits that the term "maintenance field" is not limited to mechanics but also includes "a broad variety of aviation workers" doing a multiplicity of tasks including such occupations as bench work far removed from an airplane. Secondly, earlier studies differentiate between those on the job and those applying for work, and those tests showed that the great majority of positive tests came from applicants and not from working mechanics. Nevertheless, despite these adjustments to the figures, there still seems to be some serious drug/alcohol problems among employees or applicants in the broad field of people working on aircraft or aircraft accessories.
Small Plane Confusion: An old complaint about the FAA is that there is an astonishing lack of communication within the agency itself, with the result that one section does not know what the other section is doing. A recent example demonstrates this once again. The FAA issued a notice of proposed rulemaking that proposes to severely tighten the noise standards for single-engine airplanes. The notice was written and signed by the FAA's Environment and Energy Office, and when the public docket for comments opened, there were a number of extremely negative responses from the public. The Aircraft Owners and Pilots Association (AOPA), for instance, said the proposal should be withdrawn because it is totally unrealistic, such that a newly certified Cessna would have to be quieter than a lawnmower. Plus, any time you worked on a propeller or engine of an older airplane, you would have to meet 2004 noise standards, which would make it economically prohibitive.
Some of the harshest comments in the FAA docket were from one Scott Sedgwick who was totally opposed because he said small airplanes are not a significant source of airplane noise, and he also criticized the data and the studies that were used. But—amazingly—Scott Sedg-wick is himself an important FAA official; he is the manager of Standards in the FAA's Small Airplane Directorate. Sedgwick is based in Kansas City, Missouri, while the Energy and Environment Office is the 9th floor of FAA headquarters in Washington, D.C., and these two branches apparently have no communication before issuing a regulation and are now fighting it out in the public docket. The AOPA had the best comment about this current circus—"[The] FAA really needs to talk to [the] FAA."

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