The Subcommittee will examine the growing aviation industry practice of outsourcing maintenance, repair, and overhaul (MRO) work. The Federal Aviation Administration (FAA) is responsible for and provides oversight of all MRO work, including that which is outsourced. Some outsourced MRO work is conducted at foreign repair stations, which may or may not be FAA certificated. The hearing will explore concerns raised by aviation stakeholders regarding MRO work conducted at non-certificated repair stations, foreign or domestic.
Chairman John D. (Jay) Rockefeller
Witness Panel 1
The Honorable Calvin L. Scovel IIIInspector GeneralU.S. Department of Transportation
Ms. Margaret Peggy GilliganDeputy Associate Administrator for Aviation SafetyU.S. Department of Transportation
Robert Roach Jr.General Vice President - TransportationThe International Association of Machinists and Aerospace WorkersTestimony ofRobert Roach, Jr., General Vice President of Transportation
International Association of Machinists and Aerospace WorkersBefore theSenate Commerce, Science and Transportation CommitteeSubcommittee on Aviation Operations, Safety, and Security
“Oversight of Foreign Aviation Repair Stations”June 20, 2007Thank you, Mr. Chairman, and members of this Committee for the opportunity to speak to you today. My name is Robert Roach, Jr., General Vice President of Transportation for the International Association of Machinists and Aerospace Workers (IAM). I am appearing at the request of International President R. Thomas Buffenbarger. The Machinists Union is the largest aviation union in North America, representing 180,000 airline and aerospace workers in almost every classification, including Mechanics, Flight Attendants, Ramp Service workers, Public Contact employees and production workers.Since 2003, nine major U.S. carriers (Air Tran Airways, Alaska Airlines, America West Airlines, Continental Airlines, Delta Airlines, JetBlue Airways, Northwest Airlines, Southwest Airlines, and United Airlines) have increased their amount of outsourced maintenance from 34 percent of total heavy aircraft maintenance checks to 67 percent. The trend of U.S. airlines increasingly subcontracting aircraft maintenance work jeopardizes the safety and security of our nation’s air transportation system. The lack of adequate Federal Aviation Administration (FAA) oversight of certificated and non-certificated maintenance repair stations is unforgivable.Many overseas repair stations exist only because U.S. airlines are constantly looking for ways to reduce their operating costs. Airlines utilize these facilities to take advantage of the low wages and lax regulations available at overseas repair stations when there are many U.S. repair facilities available and underutilized, such as the state of the art Indianapolis, Indiana facility abandoned by United Airlines, one of the most advanced repair stations in the world. Cutting back on food, pillows and other in-flight amenities is a business decision that only inconveniences passengers, but cutting costs in aircraft maintenance has serious safety implications.Our mechanics have found aircraft returning from overseas flights departed with obvious mechanical problems. When they tell FAA inspectors, the inspectors complain that their hands are tied. Budget constraints limit their ability to inspect overseas maintenance operations.A recent example of poor work performed by a maintenance vendor occurred at US Airways. The FAA recently issued an Airworthiness Directive requiring the replacement of the fuse pins that mount engines to Boeing 767 aircraft. A maintenance contractor for US Airways performed the modification, but installed the wrong fuse pins on three aircraft. These pins are designed to allow an engine to drop from the wing during an emergency to prevent excessive vibrations from causing the entire wing to break away from the aircraft. Such a catastrophic event would force the plane into an uncontrolled spiral toward the earth. Our members have also seen aircraft return from repair facilities with the flaps rigged improperly, engine fan blades installed backwards, improperly connected ducting that resulted in pressurization problems, airspeed indicator lines disconnected, inoperable thrust reversers and over-wing exit emergency slides deactivated. These aircraft had all been deemed airworthy by the repair stations. Although these mistakes were noticed and catastrophic accidents avoided, that is not always the case.FAA oversight of U.S. repair facilities is better than foreign repair stations, but still not adequate. On January 8, 2003 US Airways Express Flight 5481 crashed into a Charlotte, North Carolina hangar packed with IAM members, killing all 21 people on board. The subsequent National Transportation Safety Board (NTSB) investigation faulted Air Midwest, which operated the aircraft, the facility that performed maintenance of the aircraft and the FAA.US Airways, then headquartered in Arlington, Virginia, sold the tickets to the flight and the aircraft displayed the carrier’s logo. Air Midwest, based in Arizona, operated the flight and was responsible for the aircraft’s maintenance. But Air Midwest subcontracted that maintenance to Raytheon Aerospace in Huntington, West Virginia, who then contracted with Structural Modification and Repair Technicians to supply the mechanic workforce.The NTSB determined that a mechanic improperly adjusted cables that helped control the pitch of the aircraft. The mechanic had never done the job on that type of plane before and with his trainer’s approval, skipped steps that the NTSB said would likely have helped the mechanic catch his mistakes. FAA regulations require such flight critical work to be inspected, but in this case it was inspected by the same instructor who allowed steps to be skipped.NTSB Chairman Ellen Engleman Conners said at the time, “I think the entire system here was broken down. There were errors at every level.” Commenting on the airline’s layers of subcontracted maintenance work, Aeronautical Repair Station Association Executive Director Sarah Macleod said, “The more removed you get from the maintenance, the more training it takes. The more tiers, the closer you’d better be looking.” The Machinists Union wholeheartedly agrees with both of these statements.A July 2003 Department of Transportation (DOT) Inspector General Report highlighted the weak oversight of aircraft maintenance performed overseas by third-party contractors. In response to that report, Congress directed the FAA to submit a plan by March 12, 2004 to ensure that foreign repair stations working on U.S. aircraft are subject to the same level of safety and oversight as required here at home.Years past the deadline, the FAA finally submitted a plan that the Machinists Union believes is woefully inadequate. There is still a shortage of FAA inspectors, and when inspectors are permitted to make a rare inspection of an overseas repair station they must still give advance notice. Unscheduled surprise inspections, like those performed in the U.S. are necessary to ensure compliance. Unlike U.S. workers, foreign maintenance personnel are still not required to undergo drug and alcohol testing or pass criminal background checks. In fact, they are not even required to read English, which is the language in which aircraft manufactures write their maintenance repair manuals.A December 2005 DOT Inspector General report found that while foreign repair stations were widely used by U.S. carriers, some FAA certified foreign repair stations are not inspected at all by FAA inspectors because civil aviation authorities review these facilities on the FAA’s behalf. Airlines are subcontracting their maintenance and the FAA is outsourcing their inspections. The Machinists Union believes this only degrades aviation safety and endangers the traveling public.The FAA’s oversight of certified repair stations is insufficient to ensure compliance with regulations. FAA oversight of non-certificated repair stations, however, is non-existent.The Inspector General’s 2005 report found that non-certificated facilities operate without the same regulatory requirements as certificated repair stations and operate with no limit on the type or scope of work they can perform. The report also verified that the FAA does not monitor the maintenance performed at non-certificated facilities and the air carriers’ training and oversight of these facilities are inadequate. The report further revealed that the FAA did not know the extent of maintenance performed at non-certificated repair facilities.The Machinists Union is thankful the Inspector General’s office has repeatedly demonstrated the FAA’s lack of oversight of contract maintenance facilities. However, hearings and investigations do nothing to increase safety unless it is followed with action by both the FAA and the airlines who subcontract their maintenance work.Having U.S. aircraft repaired overseas also opens up this country to a great security risk. It is not hard to imagine how overseas repair stations working on U.S. aircraft could provide terrorists with an opportunity to sabotage an aircraft or components that will eventually re-enter the U.S. for domestic service. These stations should be immediately closed down until security audits can be conducted and security vulnerabilities addressed.There should be one standard for safety, security and FAA oversight at all aircraft repair facilities working on U.S. aircraft, regardless of where they are located. This must include equivalent standards for criminal background checks, drug and alcohol testing of workers and tightening the security at repair facilities.The FAA does not have sufficient funding to hire an adequate number of inspectors to ensure aviation maintenance safety, at home or abroad. Even the recent hiring of additional FAA inspectors does little to improve oversight. As of January 2007 there were only 103 international field inspectors for a total of 692 foreign repair stations. The Singapore field office alone is responsible for 103 stations, but has only 4 inspectors. An immediate increase in FAA inspectors, along with the resources they need, is necessary to safeguard the U.S. aviation industry.Mr. Chairman, members of this Committee, let my testimony today serve as more than a warning that the oversight of contract maintenance on U.S. aircraft is almost non-existent. I am here to offer the assistance of the Machinists Union and all our members who build and maintain aircraft to help safeguard our aviation industry.I thank the Committee for inviting us to participate in these proceedings and listening to our concerns.I look forward to your questions.
 Statement of The Honorable Calvin L. Scovel III, Inspector General of the U.S. Department of Transportation before the House Transportation and Infrastructure Committee Subcommittee on Aviation, March 29, 2007. NTSB Aircraft Accident Report, “Loss of Pitch Control During TakeoffAir Midwest Flight 5481 Raytheon (Beechcraft) 1900D, N233Y, Charlotte, North Carolina, January 8, 2003NTSB/AAR-04/01 Charlotte Observer, “NTSB faults FAA and airline in US Airways crash”, February 26, 2004 Department of Energy Aviation Flight Safety Notice 03-002, “ Subcontract Maintenance” DOT Inspector General Report, “Review of Air Carriers’ Use of Aircraft Repair Stations”, July 8, 2003 (AV-2003-047) DOT Inspector General Report Air Carriers’ Use of Non-Certificated Repair Facilities, December 15, 2005 (AV-2006-031) Statement of The Honorable Calvin L. Scovel III, Inspector General of the U.S. Department of Transportation before the House Transportation and Infrastructure Committee Subcommittee on Aviation, March 29, 2007.
Mr. Marshall S. FillerManaging Director and General CounselAeronautical Repair Station Association
Mr. Basil BarimoVice President of Operations and SafetyAir Transport Association
Tom BrantleyPresidentProfessional Aviation Safety Specialists