The operational consequence is that the dwindling population of carrier-employed technicians is confronted with an increasing volume of maintenance discrepancies and outright maintenance fraud with respect to aircraft returning from foreign and domestic repair stations. The result has been a ratcheting up of management pressure on technicians to turn a blind eye to aircraft damage that renders an aircraft unairworthy. In the last three years, the gravity of the situation at U.S. major carriers has been repeatedly recognized by the FAA.
Southwest Airlines, which has the lowest ratio of aircraft technicians to aircraft of any major carrier. FAA investigators have determined that Southwest suffers from a degraded supervisory maintenance culture, which manifests itself in the pressuring of the carrier’s Aviation Maintenance Technicians (AMTs) and Inspectors to subordinate safe maintenance practices to the carrier’s schedule. Moreover, the FAA has further determined that, in the last several years, Southwest’s practices have resulted in scores of aircraft operating in revenue passenger service in an unairworthy condition.
In a September 2017 report by the FAA’s Technical Aircraft Maintenance Branch addressing whistleblower complaints raised by Dallas-based Southwest maintenance inspectors, the FAA found that coercive conduct toward maintenance employees was having an adverse impact on “all forms” of the maintenance operations, including “troubleshooting, completion of work, inspections, technical support and training.”
The FAA reported that, despite the environment of intimidation, one inspector insisted on documenting damage to an aircraft’s flight control rudder balance weight that was “substantial,” but that, “rather than being praised for finding a serious airworthiness issue,” the inspector was “questioned as to how and why he came to notice” the damage. The courage of this particular inspector led to the fortunate disclosure of a “systemic” issue affecting fleet-wide safety:
In a separate and independent FAA field investigation of the carrier’s Los Angeles maintenance operations conducted on September 20, 2017, the agency’s investigators reported that:
FAA investigators determined:
"There is the absence of a “Just Safety Culture”. Safety Promotion, a key part of an effective SMS [Safety Management System] seems to be deficient. There seems to be a lack of an environment of trust, effective communication and the willingness for employees to share mistakes, concerns or failure without the fear of threats or reprisal. This ultimately leads to a degraded level of safety that the SMS is trying to maintain at the highest possible level."
In response to whistleblower complaints by aircraft mechanics at Southwest’s Las Vegas maintenance station, an FAA determination letter, dated October 5, 2017, “substantiated that a violation of an order regulation or standard of the FAA related to air carrier safety occurred,” which required “appropriate corrective and/or enforcement action.”
The FAA determined that Southwest had improperly issued a memorandum entitled “Cargo Door Handle Housing Assemblies” designed to accelerate the evaluation of delay-causing aircraft damage. The FAA’s regional investigators expressed their particular concern that “[Southwest Maintenance] Leaders did not remove it from circulation once aware of its existence.”
Southwest’s deliberate violation of federal aviation standards is echoed in an FAA complaint in November, 2014, which alleged that the company had flown 44 aircraft in an unairworthy condition as a result of improper repairs to skin panels that undermined the structural integrity of the fuselages.
The FAA determined that Southwest
continued to operate the unairworthy aircraft
for six months after the FAA had advised
the carrier that the aircraft were non-compliant.
The FAA also found that additional aircraft were rendered unairworthy by faulty wiring related to gray water drain mast modifications that were necessary to address the planes’ susceptibility to fires and electrical disruptions in the event of a lightning strike. Here again, the FAA determined that Southwest continued to operate these aircraft in an unairworthy condition even after it was discovered that the case ground wire terminal had not been properly relocated and connected.
Maintaining safe aircraft in accordance with federal aviation standards takes time and money. Violating the law is faster and cheaper. As a result, AMTs at Southwest found themselves subjected to a Hobson’s Choice – jeopardize your FAA license or lose your job. In Las Vegas, when an AMT expressed concerns about retaliation in response to his reports of aircraft discrepancies, his supervisor responded:
“If you’re worried about your [FAA] license …
write them up. …
If you’re worried about your job,
then I don’t know.”
Presumably in response to pressure from the FAA, Southwest has acknowledged in stark language that the carrier suffers from a maintenance culture that subordinates aircraft safety to on-time performance.
On December 6, 2017, Southwest’s Vice President Technical Operations Trevor Stedke described a problem-plagued maintenance program that ignores its own policies and procedures and releases unairworthy aircraft into revenue service:
"We’ve had several examples recently. Everything from calls to the FAA in DC, to AD over flies, engine operation. We had a wing that flew around [that] was damaged from an unknown period of time with of course nothing documented.
We’ve been through a dent program. We’ve had several dents found to be non-compliant, re-worked without anything documented in our maintenance systems. Damage events, lockout, carryout.
And you all know that the list goes on and on about several things that examples of where we’re bypassing or policies and procedures and we have got to get that rectified and cleaned up if we have any hope of getting ETOPS and maintain ETOPS in the future."
Safety Culture at Fault
Stedke identified the degradation of Southwest safety culture as the principal culprit behind these safety lapses:
"There is a perception, I think from some, that all On Time Performance trumps compliance. And our expectation as a Leadership Team is that we really want On Time Performance higher than compliance. And what we speak to On Time Performance and measure On Time Performance. We say compliance but it’s kind of a wink, wink, you know, make sure you get the airplane out, and that’s, nothing can be further from the truth."
Vice President of Maintenance Operations Landon Nitschke describes Southwest’s maintenance culture in the same disturbing terms:
"And, you know,
sometimes we hide our compliance issues
under the Warrior Spirit, right?"
In order to placate the FAA, and obtain lucrative Hawaiian markets that require prior ETOPs approval, Southwest has proclaimed that 2018 will be the year that it repents of its unlawful past. As the Vice President of Technical Operations declared in December, 2017:
"So compliance effectiveness is going to be a new item on our dashboard this year. We’re going to set those measures and make sure that’s part of our metrics that are driving the right behaviors across the organization."
Confirming that the Southwest’s interest in safe aircraft maintenance is a freshly discovered value, Vice President of Maintenance Operations Nitschke has announced, literally, that Southwest will be singing a new tune in 2018:
"So big effort this year. We definitely need to repair some things with the FAA not only as a Company, but, I think, as people. I think there are some things with, you know, AMTs getting questioned. Supervisors certainly getting questioned. Those are things we want to get into. We want to make sure that we handle that at a Company level, so again, compliance, compliance, compliance is going to be our theme song for 2018."
Southwest concedes that this wrenching shift in gears – from pushing out planes to a genuine concern for safety – has left both management and Southwest AMTs in a state of bewilderment:
"We had a discussion in Breakfast Club, our morning Ops meeting, this morning. And I think [Southwest Director of Quality Assurance] Gregg Brown said it, we are all so confused in the room. It’s like well can you imagine what our front line Mechanics think? And so as Leaders, that’s what we need to correct. But to Trevor’s point, it goes throughout the organization all the way through everyone to make sure that we are compliant."
Safety Culture Is
the Answer to Safety!
It's just so simple
to do the right thing.
One life lost is one too many.
If you have been violated for reporting safety
contact me, I will point you in the right direction.
Enjoy the Journey!
XO Karlene
