Trust and Collaboration are Not Dirty Words

I just read your editorial "Somthing’s Amiss" (see Editor’s Notebook, AM May 2008) and felt obligated to write you with my opinion on compliance, communications, certification and accountability of the FAA and air carriers. America’s commercial airlines have grounded aircraft causing thousands of cancellations over a difference in interpretation of a long standing rule. No matter what led to the problem, the solution will be a series of fixes about sharing information between the regulators and the carriers. The process of regulatory oversight of the nation’s airlines has a far reaching impact and despite a successful program of self-disclosure, appears to be in need of repair. Like many assets-based commercial businesses, revenue for the airlines is rooted on aircraft flying upwards of 10 hours a day to sustain profitability. It is imperative that the aircraft fleet utilization meet or exceed planned levels. The recent rush to make repairs indicate problems existed well before the grounding including: the carrier and FAA disagreed on regulation interpretation; communications between the carrier and the FAA failed; the process for resolving disputes failed and both sides failed to negotiate a solution; and there was a disagreement on corrective action. If a carrier is deemed "not in compliance" the regulations allow the FAA to demand an operation cease until the fault is corrected. By all accounts, FAA’s program of self-disclosure (which means a carrier disclosed known problems and worked out a solution with the FAA to avoid a non-complaint status) was a prudent and safe way to manage safety. What seems to have failed is the collaborative efforts to resolve problems and the trust that self-disclosure meant a carrier could keep flying and make needed repairs. The safety record of the nation’s air carriers is exemplary. The FAA’s system of self-disclosure was working. The solution is to bridge the communication gap between the FAA and the carriers. The two must commit resources to resolve issues before the fleet utilization so sorely needed to make a profit disappears in a cloud of non-compliance caused by failed communication.

Glen Gates, Principal, C3A Solutions, LLC

Blaming Who?

I recently received the latest copy of Aviation Maintenance and read your article "Blame Game" (see Editor’s Notebook, AM April 2008, page 4) and take a bit of an issue with it. I agree 100 percent that it was very honorable of Southwest to report the issue in every aspect. My issue with this is that once Southwest discovered the issue, it is reported that they had input in the development of the Service Bulletin (turned AD) so their knowledge of the issue was as great or greater than the OEM. One would think that with this knowledge they would be the last one to have an issue with this particular AD. I don’t find the FAA at fault in this with the exception of the "self-disclosure" policy. I think that the directors of maintenance and quality assurance of the individual companies, whether they are airline, Part 91, 135, etc. operators, are there to ensure compliance of their particular aircraft inspection programs including implementation of ADs and applicable Service Bulletins. The inspection programs, from my point of view, are crucial to the safe operation of any type aircraft, not just the airline, and should be followed. I don’t feel as if anyone (FAA) needs to "hold the hand" and tell anyone how to run the flight departments/airlines when a basic guideline already exists. There are too many database systems available to the operators to allow something like this to slip. We all want responsibility until something goes wrong then we want to point fingers and do the "Blame Game..."

Name Withheld